Privacy Policy

The Green Doctor (TGD) holds some information about you. This document outlines how that information is used, who TGD may share that information with and how TGD keeps it secure. This notice does not provide exhaustive detail. However, TGD is happy to provide any additional information or explanation needed. Any requests for this should be sent to mahesh@thegreendoctor.uk. TGD keeps the Privacy Policy under regular review. This Privacy Policy was last reviewed in July 2020.

1. What The Green Doctor Does

TGD provides nutritional therapy services to clients to improve their health through diet and lifestyle interventions. TGD focuses on preventative healthcare, the optimisation of physical and mental health and chronic health conditions. Through nutritional therapy consultations, workshops, educational seminars, dietary and lifestyle analysis and biochemical testing, TGD aims to understand the underlying causes of your health issues which TGD will seek to address through personalised dietary therapy, nutraceutical prescription (supplements) and lifestyle advice.

2. How The Green Doctor Obtains Your Personal Data

TGD uses this information in order to provide you with direct healthcare. This means that the legal basis of TGD holding your personal data is for legitimate interest.

Following completion of your healthcare TGD retains your personal data for the period defined by our professional association BANT and registrant body, Complementary and Natural Healthcare Council (CNHC). This enables TGD to process any complaint you may make. In this case the legal basis of TGD holding your personal data is for contract administration.

Information TGD gets from other sources

TGD may obtain sensitive medical information in the form of test results from biochemical testing companies. TGD uses this information in order to provide you with direct healthcare. This means that the legal basis of TGD holding your personal data is for legitimate interest.

3. How TGD uses your personal data

TGD may obtain sensitive information from other healthcare providers. The provision of this information is subject to you giving TGD your express consent. If TGD does not receive this consent from you, TGD will not be able to coordinate your healthcare with that provided by other providers, which means the healthcare provided by TGD may be less effective.
TGD acts as a data controller for use of your personal data to provide direct healthcare. TGD also acts as a controller and processor in regard to the processing of your data from third parties such as testing companies and other healthcare providers. TGD acts as a data controller and processor in regard to the processing of credit card and online payments.
TGD undertakes at all times to protect your personal data, including any health and contact details, in

a manner which is consistent with TGD’s duty of professional confidence and the requirements of the General Data Protection Regulation (GDPR) concerning data protection. TGD will also take reasonable security measures to protect your personal data storage.
TGD may use your personal data where there is an overriding public interest in using the information e.g. in order to safeguard an individual, or to prevent a serious crime, and also where there is a legal requirement such as a formal court order.

TGD may use your data for marketing purposes such as newsletters but this would be subject to you giving TGD your express consent.

4. Do you share my information with other organisations?

TGD will keep information about you confidential. TGD will only disclose your information with other third parties with your express consent with the exception of the following categories of third parties:

• TGD’s registrant body, CNHC, and professional association, BANT, for the processing of a complaint made by you
• Any contractors and advisors that provide a service to TGD or act as agents on the understanding that they keep the information confidential
• Anyone to whom TGD may transfer rights and duties under any agreement TGD has with you
• Any legal or crime prevention agencies and/or to satisfy any regulatory request (CNHC) if TGD has a duty to do so or if the law allows TGD to do so

TGD may share your information with supplement companies and biochemical testing companies as part of providing you with direct healthcare. TGD will not include any sensitive information.
TGD will seek your express consent before sharing your information with your GP or other healthcare providers. However if TGD believes that your life is in danger then TGD may pass your information onto an appropriate authority (such as the police, social services in the case of a child or vulnerable adult, or GP in case of self-harm) using the legal basis of vital interests.

TGD may share your case history in an anonymised form with peers for the purpose of professional development. This may be at clinical supervision meetings, conferences, online forums, and through

publishing in medical journals, trade magazines or online professional sites. TGD will seek your explicit consent before processing your data in this way.

5. What are your rights?

Every individual has the right to see, amend, delete or have a copy, of data held that can identify you, with some exceptions. You do not need to give a reason to see your data.
If you want to access your data you must make a subject access request in writing
to mahesh@thegreendoctor.uk.

Under special circumstances, some information may be withheld. TGD shall respond within 20 working days from the point of receiving the request and all necessary information from you. TGD’s response will include the details of the personal data TGD holds on you including:

 Sources from which TGD acquired the information
 The purposes of processing the information
 Persons or entities with whom TGD is sharing the information

You have the right, subject to exemptions, to ask to:

• Have your information deleted
• Have your information corrected or updated where it is no longer accurate
• Ask TGD to stop processing information about you where TGD is not required to do so by law or in accordance with the BANT and CNHC guidelines.
• Receive a copy of your personal data, which you have provided to TGD, in a structured, commonly used and machine readable format and have the right to transmit that data to another controller, without hindrance from TGD
• Object at any time to the processing of personal data concerning you

TGD does not carry out any automated processing, which may lead to automated decision based on your personal data.

If you would like to invoke any of the above rights then please write to the Data Controller by emailing mahesh@thegreendoctor.uk.

What safeguards are in place to ensure data that identifies me is secure?

TGD only uses information that may identify you in accordance with GDPR. This requires TGD to process personal data only if there is a legitimate basis for doing so and that any processing must be fair and lawful.
Within the health sector, TGD also has to follow the common law duty of confidence, which means that where identifiable information about you has been given in confidence, it should be treated as confidential and only shared for the purpose of providing direct healthcare.TGD will protect your information, inform you of how your information will be used, and allow you to decide if and how your information can be shared.

TGD also ensures the information held is kept in secure locations, restrict access to information to authorised personnel only, protect personal and confidential information held on equipment such as laptops with encryption (which masks data so that unauthorised users cannot see or make sense of it). TGD ensures external data processors that support TGD are legally and contractually bound to operate and prove security arrangements are in place where data that could or does identify a person are processed.

TGD is registered with the Information Commissioner’s Office (ICO) as a data controller and collects data for a variety of purposes. A copy of the registration is available through the ICO website (search by business name).

6. How long do you hold confidential information for?

All records held by TGD will be kept for the duration specified by guidance from TGD’s professional association BANT.

7. Website technical details

Forms

TGD uses electronic forms on the website making use of an available ‘forms module’ which has a number of built-in features to help ensure privacy. TGD also aims to use secure forms where appropriate.