GDPR Privacy Notice
PRIVACY NOTICE
Kusala Nutrition & Lifestyle 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 the tara@kusala.co.uk.
We keep our Privacy Notice under regular review. This Privacy Notice was last
reviewed in September 2025.
1. What We Do
Kusala Nutrition & Lifestyle provides nutritional
therapy 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.
2. How We Obtain
Your Personal Data
Information provided
by you
You provide us with personal data in the following ways:
- During booking of a discovery call
- By completing a nutritional therapy
questionnaire
- By signing a terms of engagement form
- During a nutritional therapy consultation
- Whilst engaging in the online portal
- Through email, over the telephone or by post
- By taking credit card and online payment
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
- Bank details
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.
Following completion of your healthcare we retain your
personal data for the period defined by our professional association BANT and registrant
body 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 for 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 (eg, 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.
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 <tara@kusala.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 email tara@kusala.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.
Kusala Nutrition & Lifestyle 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 the Kusala will be kept for the duration
specified by guidance from our professional association BANT.
8. Website
technical details
a.
Forms
We do use electronic forms on our website
making use of an available ‘forms module’ which has a number of built-in
features to help ensure privacy. We also aim to use secure forms where
appropriate.
In compliance with EU legislation, the following table lists
the use of cookies on this web site:
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Cookie |
Purpose |
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Cookies are small. 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. 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 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. Complaints
If you have a complaint regarding the use of your personal
data then please contact us by emailing the Data Controller at tara@kusala.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.