Privacy Policy
What we do
The Hearty Sprout Provides naturopathic nutritional therapy to clients who wish to improve their health through diet and lifestyle interventions. Focusing on preventative healthcare, optimising physical and mental health, and chronic health
conditions.
Through nutritional therapy consultations, dietary and lifestyle analysis and biochemical testing, our aim is to understand the underlying causes of your health issues which we seek to address through personalised dietary therapy, supplements and lifestyle advice.
How we obtain your personal data
INFORMATION PROVIDED BY YOU
You privide us with data in the following ways:
This may include the following information:
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 interests.
Following completion or your healthcare we retain your personal data for the period defined by our professional association Naturopathic Nutrition Association (NNC), and registrant body General Naturopathic Council (GNC). 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 interests.
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 healthcare providers, which means the healthcare provided by us may be less effective.
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 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 General Data Protection Regulation (GDPR) concerning data protection. We will also take reasonable security measures to protect your personal data storage.
We may use your 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 a newsletter, but this would be subject to you giving us your express consent.
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:
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 the 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 express explicit consent before processing your data in this way.
WHAT ARE YOUR RIGHTS?
Every individual has the right to see, amend, delete or have a copy, of the data held that can identify you, with some exceptions. You do not need to give a reason to see your data.
If you would like to access your data you must make a data subject request in writing to help@theheartysprout.co.uk. Under special circumstances, some information may be withheld. We shall respond within one month from the point of receiving the request. This time will be stopped if further clarification is needed and restarted once you have provided the clarification requested. Our response will include the details of the personal data we hold on you including:
You have the right, subject to exemptions, to ask to:
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 help@theheartysprout.co.uk.
WHAT SAFEGUARDS ARE IN PLACE TO ENSURE DATA THAT IDENTIFIES ME IS SECURE?
We only use data 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 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 could or does identify a person, are processed.
HOW LONG DO YOU HOLD CONFIDENTIAL INFORMATION FOR?
All records held by The Hearty Sprout will be kept for the duration specified by guidance from our professional association NNC.
WEBSITE TECHNICAL DETAILS
FORMS
We do use electronic forms on our website making use of an available ‘forms module’ which has a number of build-in features to help ensure privacy. We also aim to use secure forms where appropriate.
COOKIES
In compliance with EU legislation, the following table lists the use of cookies on our website www.theheartysprout.co.uk:
| COOKIES | DISCRIPTION |
| sbjs_migrations | Sourcebuster sets this cookie to identify the source of a visit and stores user action information in cookies. This analytical and behavioural cookie is used to enhance the visitor experience on the website. Analytics. Duration; Session |
| sbjs_current_add | Sourcebuster sets this cookie to identify the source of a visit and stores user action information in cookies. This analytical and behavioural cookie is used to enhance the visitor experience on the website. Analytics. Duration; Session |
| sbjs_first_add | Sourcebuster sets this cookie to identify the source of a visit and stores user action information in cookies. This analytical and behavioural cookie is used to enhance the visitor experience on the website. Analytics. Duration; Session |
| sbjs_current | Sourcebuster sets this cookie to identify the source of a visit and stores user action information in cookies. This analytical and behavioural cookie is used to enhance the visitor experience on the website. Analytics. Duration; Session |
| sbjs_first | Sourcebuster sets this cookie to identify the source of a visit and stores user action information in cookies. This analytical and behavioural cookie is used to enhance the visitor experience on the website. Analytics. Duration; Session |
| sbjs_udata | Sourcebuster sets this cookie to identify the source of a visit and stores user action information in cookies. This analytical and behavioural cookie is used to enhance the visitor experience on the website. Analytics. Duration; Session |
| sbjs_session | Sourcebuster sets this cookie to identify the source of a visit and stores user action information in cookies. This analytical and behavioural cookie is used to enhance the visitor experience on the website. Analytics. Duration: 1 hour |
| tk_or | The tk_or is a referral cookie set by the JetPack plugin on sites using WooCommerce, which analyses referrer behaviour for Jetpack. Analytics. Duration: 1 year 1 month and 4 days |
| tk_r3d | JetPack instals this cookie to collect internal metrics for user activity and in turn improve user experience. Analytics. Duration 3 days |
| tk_lr | The tk_lr is a referral cookie set by the JetPack plugin on sites using WooCommerce, which analyses referrer behaviour for Jetpack. Analytics. Duration: 1 year |
| tk_ai | JetPack sets this cookie to store a randomly-generated anonymous ID which is used only within the admin area and for general analytics tracking. Analytics. Duration: 1 year |
| flexible_cookies_accepted | Other. Duration: 1 month |
| flexible_cookies_accepted_categorie | Other. Duration: 1 month |
| flexible_cookies_accepted_all | Other. Duration: 1 month |
| wpEmojiSettingsSupports | WordPress sets this cookie when a user interacts with emojis on a WordPress site. It helps determine if the user’s browser can display emojis properly. Necessary. Duration: session |
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 – which in no way collects or discloses and 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 use 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
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.
COMPLAINTS
If you have a complaint regarding the use of your personal data then please contact us by emailing us at help@theheartysprout.co.uk and we will do our best to help you.