Caroline Lynch Nutrition holds certain information about you. This document outlines how that information is used, who we may share it with, and how we keep it secure. This notice does not provide exhaustive detail, but we are happy to provide any additional information or explanation as needed. Any requests for further information should be sent to carolinelynchnutrition@gmail.com. We keep our Privacy Policy under regular review. This Privacy Policy was last reviewed in August 2024.

1. What We Do

Caroline Lynch Nutrition provides nutritional therapy services to clients, aiming to improve their health through diet and lifestyle interventions. We focus on preventative healthcare, optimizing physical and mental health, and managing 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 address through personalized dietary therapy, nutraceutical prescriptions (supplements), and lifestyle advice.

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 a terms of engagement form

– During a nutritional therapy consultation

– Through email, over the telephone, or by post

– By taking credit card and online payments

This may include:

– 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 medical history, dietary and lifestyle details, supplement and medication details, biochemical test results, clinic notes, and health improvement plans

– GP contact information

– Bank details

We use this information to provide you with direct healthcare. The legal basis for holding your personal data is legitimate interest.

Following the completion of your healthcare, we retain your personal data for the period defined by our professional association, NTOI. This enables us to process any complaint you may make. In this case, the legal basis for holding your personal data is 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 to provide you with direct healthcare, based on legitimate interest.

We may also obtain sensitive information from other healthcare providers. This information is provided subject to your express consent. Without this consent, we may not be able to coordinate your healthcare effectively with other providers.

3. How We Use Your Personal Data

We act as a data controller for the use of your personal data to provide direct healthcare. We also act as a controller and processor concerning the processing of your data from third parties, such as testing companies and other healthcare providers. Additionally, we act as a data controller and processor in regard to the processing of credit card and online payments.

We are committed to protecting your personal data, including health and contact details, in a manner consistent with our duty of professional confidence and the requirements of the General Data Protection Regulation (GDPR). We also take reasonable security measures to protect your personal data in storage.

We may use your personal data where there is an overriding public interest, such as safeguarding an individual or preventing a serious crime. We may also use your data if required by law, such as in response to a formal court order. We may use your data for marketing purposes, such as newsletters, but only with your express consent.

4. Do You Share My Information with Other Organisations?

We will keep your information confidential and will only disclose it to other third parties with your express consent, except in the following circumstances:

– To our professional body, NTOI, for processing a complaint made by you

– To contractors and advisors providing a service to us, acting as our agents, with the understanding that they keep the information confidential

– To anyone to whom we may transfer our rights and duties under any agreement with you

– To legal or crime prevention agencies, or to satisfy any regulatory request, if we are required to do so by law 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. However, 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 your life is in danger, we may pass your information on to an appropriate authority (such as the police, social services in the case of a child or vulnerable adult, or GP in the case of self-harm) using the legal basis of vital interests.

We may share your case history in anonymized form with our peers for the purpose of professional development. This may occur 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.

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 provide a reason to see your data.

If you want to access your data, you must make a subject access request in writing to carolinelynchnutrition@gmail.com. Under special circumstances, some information may be withheld. We will respond within 20 working days of receiving your request and all necessary information. Our response will include 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 request:

– Deletion of your information

– Correction or update of your information where it is no longer accurate

– Cessation of processing of information about you where we are not required to do so by law or in accordance with NTOI guidelines

– A copy of your personal data, which you have provided to us, in a structured, commonly used, and machine-readable format, and the right to transmit that data to another controller without hindrance from us

– To object at any time to the processing of personal data concerning you

We do not carry out any automated processing that may lead to automated decision-making based on your personal data.

If you wish to invoke any of the above rights, please contact the Data Protection Commissioner at www.dataprotection.ie. 

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 GDPR. This requires us to process personal data only if there is a legitimate basis for doing so and that any processing is fair and lawful.

In the health sector, we also have to follow the common law duty of confidence, meaning that identifiable information about you given in confidence is 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 ensure that the information we hold is kept in secure locations, restrict access to information to authorized personnel only, and protect personal and confidential information held on equipment such as laptops with encryption. 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.

Caroline Lynch Nutrition is registered with the Data Protection Commissioner as a data controller and collects data for a variety of purposes. A copy of the registration is available through www.dataprotection.ie. 

7. How Long Do You Hold Confidential Information?

All records held by Caroline Lynch Nutrition will be kept for the duration specified by guidance from our professional association, NTOI.

8. Website Technical Details

**a) Forms**

We use electronic forms on our website with a built-in ‘forms module’ that includes several features to help ensure privacy. We also aim to use secure forms where appropriate.

1. b) Cookies

In compliance with EU legislation, the following table lists the use of cookies on this website:

Cookie Name

These cookies are used to collect information about how visitors use our site. We use the information to compile reports and help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from, and the pages they visited.

Cookies are small. We do not use 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. Note also 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. 

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 use analytics software to help us understand the trends in popularity of our website and different sections. We make no use of personally identifiable information in any of the statistical reports we use from this package. We use Google

 Analytics, which provides details of their privacy policy on the Google website.

10. Complaints

If you have a complaint regarding the use of your personal data, please contact us by writing to the Data Controller at www.dataprotection.ie or email carolinelynchnutrition@gmail.com, 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 Data Protection Commissioner, you can do so at www.dataprotection.ie.