Privacy Policy
PRIVACY NOTICE
The nutritional therapy and health coaching business run by Moira Newiss holds some information about you. This document outlines how that information is used, who we may share that information with and how we keep it secure. This notice does not provide exhaustive detail. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to hello@moiranewiss.co.uk. We keep our Privacy Notice under regular review. This Privacy Notice was last reviewed in August 2024.
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website. Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
• Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here.
• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.
• Your right to erasure - You have the right to ask us to delete your personal information. You can read more about this right here.
• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. You can read more about this right here.
• Your right to object to processing - You have the right to object to the processing of your personal data. You can read more about this right here.
• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here.
• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.
If you make a request, we must respond to you without undue delay and in any event within one month.
Consent – means that we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – means that we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
1. What We Do
Moira Newiss provides nutritional therapy and health coaching services to clients to improve their health through diet and lifestyle interventions. We focus on preventative healthcare, the optimisation of physical and mental health and chronic health conditions. Through nutritional therapy consultations, dietary and lifestyle analysis and biochemical testing, we aim to understand the underlying causes of your health issues which we will seek to address through personalised dietary therapy, nutraceutical prescription (supplements) and lifestyle advice. Through health coaching we aim to educate and inform you and empower you to make behavioural changes to change your lifestyle. In addition, we also run courses, workshops, retreats and educational seminars with similar aims to help improve your health and wellbeing.
2. How We Obtain Your Personal Data
Information provided by you
You provide us with personal data in the following ways:
- By completing a nutritional therapy questionnaire
- By signing our terms, conditions, privacy and information consent form as part of the engagement process
- During a nutritional therapy consultation
- Through email, over the telephone or by post
- By taking credit card and online payment
- By downloading free or paid resources.
- By signing up to receive marketing emails.
This may include the following information:
- basic details such as name, address, contact details and next of kin
- details of contact we have had with you such as referrals and appointment requests
- health information including your previous medical history, dietary, lifestyle, supplement and medicine details, biochemical test results, clinic notes and health improvement plans
- GP contact information
- Payment Information for Online Purchases
We use this information to provide you with direct healthcare. This means that the legal basis of our holding your personal data is for legitimate interest.
Following completion of your healthcare provision we retain your personal data for the period defined by our professional association BANT and our registrant body the CNHC. This enables us to process any complaint you may make. In this case the legal basis of our holding your personal data is for contract administration.
Information we get from other sources
We may obtain sensitive medical information in the form of test results from biochemical testing companies. We use this information in order to provide you with direct healthcare. This means that the legal basis of our holding your personal data is for legitimate interest.
We may obtain sensitive information from other healthcare providers. The provision of this information is subject to you giving us your express consent. If we do not receive this consent from you, we will not be able to coordinate your healthcare with that provided by other providers which means the healthcare provided by us may be less effective.
3. How we use your personal data
We act as a data controller and processor for the use of your personal data to provide direct healthcare. We also act as a controller and processor in regard to the processing of your data from third parties such as testing companies and other healthcare providers. We act as a data controller and processor in regard to the processing of credit card and online payments.
We undertake at all times to protect your personal data, including any health and contact details, in a manner which is consistent with our duty of professional confidence and the requirements of the UK General Data Protection Regulation (UK GDPR) concerning data protection. We will also take reasonable security measures to protect your personal data storage.
We 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. Also, where there is a legal requirement such as a formal court order. We may use your data for marketing purposes such as newsletters, but this would be subject to you giving us your express consent.
4. Do you share my information with other organisations?
We will keep information about you confidential. We will only disclose your information with other third parties with your express consent with the exception of the following categories of third parties:
- Our registrant body, CNHC, and our professional association, BANT, for the processing of a complaint made by you.
- Any contractors and advisors that provide a service to us or act as our agents on the understanding that they keep the information confidential.
- Anyone to whom we may transfer our rights and duties under any agreement we have with you.
- Any legal or crime prevention agencies and/or to satisfy any regulatory request e.g., CNHC if we have a duty to do so or if the law allows us to do so
We may share your information with supplement companies and biochemical testing companies as part of providing you with direct healthcare. We will not include any sensitive information.
We will seek your express consent before sharing your information with your GP or other healthcare providers. However, if we believe that your life is in danger then we 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.
We may share your case history in an anonymised form with our 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. We will seek your explicit consent before processing your data in this way.
If you are part of a group program that involves live sessions conducted via zoom or some other meeting software provider, it is possible that a recording will be made. This is usually so that group members can replay it afterwards for an additional learning opportunity or because they couldn’t attend the live session. You will be asked to give your consent specifically for this purpose. On occasions a live session maybe recorded for future marketing purposes, if this is the case you will be informed beforehand and again asked specifically for your consent which you can refuse to give.
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 hello@moiranewiss.co.uk. Under special circumstances, some information may be withheld. We shall respond within 20 working days from the point of receiving the request and all necessary information from you. Our response will include the details of the personal data we hold on you including:
- Sources from which we acquired the information.
- The purposes of processing the information
- Persons or entities with whom we are 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 us to stop processing information about you where we are 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 us, in a structured, commonly used, and machine-readable format and have the right to transmit that data to another controller, without hindrance from us.
• Object at any time to the processing of personal data concerning you
We do 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 at Moira Newiss, Broombank, North Connel, Argyll PA37 1RD or email hello@moiranewiss.co.uk.
6. What safeguards are in place to ensure data that identifies me is secure?
We only use information that may identify you in accordance with UK GDPR. This requires us 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, we also have 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. We 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.
We also ensure the information we hold 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). We ensure external data processors that support us 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.
Moira Newiss 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).
7. How long do you hold confidential information for?
All records held by Moira Newiss will be kept for the duration specified by guidance from our professional association BANT.
8. Website technical details
Forms
We do use electronic forms on our website making use of an available ‘forms module’ which has several built-in features to help ensure privacy. We also aim to use secure forms where appropriate.
Cookies
A cookie is a tiny data file that is used to store information. Most websites use cookies for a number of purposes, including providing essential functionality (e.g., a shopping cart), providing useful information about the way in which the website is being used (e.g. analytics), for marketing purposes, and for many other functions such as enhanced security. For more information about cookies, and how to disable cookies, visit the ICO.
We do not make use of cookies to collect any private or personally identifiable information. The technical platform of this website uses cookies solely to aid the proper technical functioning of the website. The cookies used contain random strings of characters alongside minimal information about the state and session of the website – which in no way collects or discloses any personal information about you as a visitor.
Advanced areas of this site may use cookies to store your presentation preferences in a purely technical fashion with no individually identifiable information. Also note our statement on analytics software below – as analytics software also uses cookies to function.
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.
In compliance with UK legislation, the following lists the use of cookies on this web site:
Google Analytics
We use Google Analytics to provide us with statistical data about the way our Site is used.
Google Analytics sets the following cookies:
• _ga. Persistent for 2 years. Registers a unique ID that is used to generate statistical data on how the visitor uses the website.
• _gat. Sessional. Used by Google Analytics to throttle request rate
• _gid. Sessional. Registers a unique ID that is used to generate statistical data on how the visitor uses the website.
You may block the collection of the data related to your use of this and all other websites, as well as the processing of this data by Google, by downloading and installing a browser plugin available from this link.
Wix
We use WIX as our website provider and our website, like most e-commerce websites, is dependent on cookies for its functionality. If you disable these cookies, it will not be possible to use our website.
Cookie Name
• XSRF-TOKEN - Used for security reasons
• Hs - Used for security reasons
• svSession - Used in connection with user login
• SSR-caching - Used to indicate the system from which the site was rendered
• _wixCIDX - Used for system monitoring/debugging
• _wix_browser_sess - Used for system monitoring/debugging
• consent-policy - Used for cookie banner parameters
• smSession - Used to identify logged in site members
• TS* - Used for security and anti-fraud reasons
• bSession - Used for system effectiveness measurement
• fedops.logger.sessionId - Used for stability/effectiveness measurement
• wixLanguage - Used on multilingual websites to save user language preference
To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout
9. Analytics
Like most websites, we make use of analytics software in order to help us understand the trends in popularity of our website and of different sections. We make no use of personally identifiable information in any of the statistical reports we use from this package. We use an analytics package called Google Analytics who provide details of their privacy policy on the Google website.
10. Marketing Purposes
For marketing purposes, we use a third-party provider to manage email marketing subscriber lists and send emails to our subscribers. Should you wish to unsubscribe from our mailing list, you can do so at any time by clicking the “unsubscribe” link in any of the email campaigns you have received from us. Or if you prefer you can contact us to request that we unsubscribe you.
11. Complaints
If you have a complaint regarding the use of your personal data then please contact us by writing to the Data Controller at Moira Newiss, Broombank, North Connel, Argyll PA37 1RD or email hello@moiranewiss.co.uk and we will do our best to help you.
If your complaint is not resolved to your satisfaction and you wish to make a formal complaint to the Information Commissioner’s Office (ICO), you can contact them on 01625 545745 or 0303 1231113.
​
12. Data Breach
We will report any data breach of the UK GDPR rules to the ICO within 72 hours of discovery it or being notified or it. We will follow the ICO advice on guidelines for dealing with a data breach and any corrective action that is necessary.
​
13. Privacy Statement Review
​
We regularly review and update this privacy statement. The latest review was completed in August 2024.