Wellbeing Edit / WellbeingEdit.com
Our Data Protection Policy is GDPR Compliant
1.1 Purpose of Policy
Wellbeing Edit needs to gather and use certain information about individuals.
These can include clients, suppliers, employees and other people the organisation has a relationship with or may need to contact.
This policy describes how this personal data will be collected, handled and stored to comply with the General Data Protection Regulation.
1.2 Policy Statement
Wellbeing Edit is committed to a policy of protecting the rights and privacy of clients, staff and others in accordance with General Data Protection Regulation.
Wellbeing Edit commits to:
· comply with both the law and good practice
· respect individuals’ rights
· be open and honest with individuals whose data is held
· Register our details with the Information Commissioner’s Office (ICO)
1.3 Personal Data
Wellbeing Edit may hold data for the following purposes:
- Provision of direct healthcare
- Marketing and newsletters
- Case histories
Special categories of data included race, ethnic origin, politics, religion, trade union membership, genetics, biometrics (where used for ID purposes), health and sexual orientation.
Wellbeing Edit may hold special category data for the following purposes:
Provision of direct healthcare
1.4 Data Protection Principles
There are six data protection principles that are core to the General Data Protection Regulation. Wellbeing Edit will make every possible effort to comply with these principles at all times in our information-handling practices.
The principles are:
1) Lawful, fair and transparent
Data collection must be fair, for a legal purpose and we must be open and transparent as to how the data will be used.
2) Limited for its purpose
Data can only be collected for a specific purpose
3) Data minimisation
Any data collected must be necessary and not excessive for its purpose.
The data we hold must be accurate and kept up to date.
We cannot store data longer than necessary.
6) Integrity and confidentiality
The data we hold must be kept safe and secure.
1.5 Key risks
The main risks are in two key areas:
· information about individuals getting into the wrong hands, through poor security or inappropriate disclosure of information
· individuals being harmed through data being inaccurate or insufficient
Wellbeing Edit is the data controller for all personal data held by us and is responsible for:
Analysing and documenting the type of personal data we hold
Checking procedures to ensure they cover all the rights of the individual
Identifying the lawful basis for processing data
Ensuring consent procedures are lawful
Implementing and reviewing procedures to detect, report and investigate personal data breaches
Storing data in safe and secure ways
Assessing the risk that could be posed to individual rights and freedoms should data be compromised
3 Data Recording, Security and Storage
3.1 Data accuracy and relevance
Wellbeing Edit will ensure that any personal data we process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.
3.2 Data security
Wellbeing Edit will keep personal data secure against loss or misuse. Where other organisations process personal data as a service on our behalf, we will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third-party organisations.
3.3 Storing data securely
In cases when data is stored on printed paper, it will be kept in a secure place where unauthorised personnel cannot access it
Printed data will be shredded when it is no longer needed
Data stored on a computer will be protected by strong passwords that are changed regularly. A password manager will be used to create and store passwords.
Data stored on CDs or memory sticks will be encrypted or password protected and locked away securely when they are not being used
Cloud services used to store personal data will be assessed for compliance with GDPR principles. An authenticator app will be used to access cloud data.
Servers containing personal data must be kept in a secure location, away from general office space
Data will be regularly backed up.
All servers containing sensitive data must be protected by security software
All possible technical measures will be put in place to keep data secure
3.4 Data retention
Wellbeing Edit will retain personal data for no longer than is necessary. This shall be in accordance with the guidelines of our professional association ANP
4 Accountability and Transparency
Wellbeing Edit will ensure accountability and transparency in all our use of personal data. We will keep written up-to-date records of all the data processing activities that we do and ensure that they comply with each of the GDPR principles.
We will regularly review our data processing activities and implement measures to ensure privacy by design including data minimisation, pseudonymisation, transparency and continuously improving security and enhanced privacy procedures.
Wellbeing Edit will ensure that consents are specific, informed and plain English such that individuals clearly understand why their information will be collected, who it will be shared with, and the possible consequences of them agreeing or refusing the proposed use of the data. Consents will be granular to provide choice as to which data will be collected and for what purpose. We will seek explicit consent wherever possible.
We will maintain an audit trail of consent by documenting details of consent received including who consented, when, how, what, if and when they withdraw consent. For online consent, we may use a cryptographic hash function to support data integrity. Alternatively we will maintain the consents information in a spreadsheet with links to the consent forms.
We will regularly review consents and seek to refresh them regularly or if anything changes.
6 Direct Marketing
Wellbeing Edit will comply with both data protection law and Privacy and Electronic Communication Regulations 2003 (PECR) when sending electronic marketing messages. PECR restricts the circumstances in which we can market people and other organisations by phone, text, email or other electronic means.
We will seek explicit consent for direct marketing. We will provide a simple way to opt out of marketing messages and be able to respond to any complaints.
7 Subject Access Requests
7.1 What is a subject access request?
An individual has the right to receive confirmation that their data is being processed, access to their personal data and supplementary information which means the information which should be provided in a privacy notice.
7.2 How to deal with subject access requests
Wellbeing Edit will provide an individual with a copy of the information requested, free of charge. This will occur within one month of receipt. We endeavour to provide data subjects access to their information in commonly used electronic formats (as described in section 4.3).
If complying with the request is complex or numerous, the deadline can be extended by two months, but the individual will be informed within one month.
We can refuse to respond to certain requests, and can, in circumstances of the request being manifestly unfounded or excessive, charge a fee. If the request is for a large quantity of data, we can request the individual specify the information they are requesting.
Once a subject access request has been made, we will not change or amend any of the data that has been requested. Doing so is a criminal offence.
7.3 Data portability requests
We will provide the data requested in a structured, commonly used and machine-readable format. This would normally be a PDF file, although other formats are acceptable. We must provide this data either to the individual who has requested it, or to the data controller they have requested it be sent to within one month.
8 Transferring data internationally
There are restrictions on international transfers of personal data. We will not transfer personal data abroad without express consent.
9 Third Parties
9.1 Using third party controllers and processors
As a data controller and/or data processor, we will have written contracts in place with any third-party data controllers (and/or) data processors that we use. The contract will contain specific clauses which set out our and their liabilities, obligations and responsibilities.
As a data controller, we will only appoint processors who can provide sufficient guarantees under GDPR and that the rights of data subjects will be respected and protected.
As a data processor, we will only act on the documented instructions of a controller. We acknowledge our responsibilities as a data processor under GDPR and we will protect and respect the rights of data subjects.
Our contracts will comply with the standards set out by the ICO and, where possible, follow standard contractual clauses. Our contracts with data controllers (and/or) data processors will set out the subject matter and duration of the processing, the nature and stated purpose of the processing activities, the types of personal data and categories of data subject, and the obligations and rights of the controller.
10 Reporting breaches
Any breach of this policy or of data protection laws will be reported as soon as practically possible. This means as soon as we become aware of a breach.
Wellbeing Edit has a legal obligation to report any data breaches to UK Supervisory authority which is the Information Commissioner's Officer within 72 hours.
The owner, developer and content curator of WellbeingEdit.com is Nutritional Therapist Sarah Shakespeare.
The information and resource provided in and by way through this website is for educational information and of the opinion of Sarah Shakespeare only.
Sarah Shakespeare is a Nutritional Therapist and not a medical doctor or nurse or other medical health practitioner .
Therefore any information, comments, social media comments and resource links found and made available by and through WellbeingEdit.com should not be used or misconstrued to diagnose, prescribe, treat, prevent or cure any medical condition.
We recommended to consult your GP or health professional before implementing any dietary, lifestyle, exercise, medication or supplemental changes. It is the responsibility of the individual to consult with their GP or health professional before making any change.
Any statements, claims regarding any health benefited derived from any food, exercise, lifestyle, supplements are for information purposes only and Wellbeing Edit and cannot be liable.
Nutrition Therapy Consultations, Products, Services and Programmes
Sarah Shakespeare is not a medical doctor, nurse or medical practitioner. She is a qualified Nutritional Therapist. A graduate of the London College of Naturopathic Medicine and member of the Association of Naturopathic Practitioners (ANP) As a Nutritional Therapist, Sarah cannot diagnose, prescribe, treat, prevent or cure any medical condition. It is not a replacement for medical advice.
Nutritional Therapy is not a substitute for medical advice or treatment. Nutritional Therapy is a science based therapeutic approach that uses the latest health and nutrition based research to help support and promote individual optimal health.
The focus is improving physiological function of a number of bodily systems including the digestive, immune and endocrine systems.
Nutritional Therapists have been trained to use a wide range of tools to assess and identify potential nutritional imbalances and understand how these may contribute to an individual’s symptoms and health concerns.
Nutritional Therapy is recognised as a complementary medicine and is relevant for individuals with health conditions, and for those looking for support to enhance their health and wellbeing.
Nutritional Therapy takes an individual approach and not a ‘one size fits all’ approach.
In the event a client may reveal a ‘red flag’ signs or symptoms, a Nutritional Therapist will communicate this to a Doctor or specialist healthcare professional. This will have been agreed to by the client during the terms of engagement form before the consultation (should it be necessary).
If any health symptoms or concerns is suspected. It is advised to contact your GP or Health Professional as soon as possible. It is recommended to consult your GP or health professional before implementing any dietary, lifestyle, exercise, medications or supplemental changes. It is the responsibility of the individual to consult with their GP or Health Professional before making any of these changes.
Nutritional Therapy Consultations, Products, Services and Programmes
The Products, Services, and Programmes that can be found on wellbeingedit.com are available for information and educational purposes only and not providing medical, health or nutritional advice.
Any information shared via, Skype, or other online connections including but not limited to webinars, social media, speaking engagements, classes, handouts/.pdfs, videos, audio recordings, or otherwise through my website programs, products and services, I am serving solely in the role of a Wellness Coach and providing this information solely for your educational and informational purposes, and I am not providing medical advice.