Sarah Flower, a nutritionist based in Exeter, Devon, can hold information about you but we take privacy very seriously and do not share, sell, spam or make public your personal information. 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 Sarah Flower We keep our Privacy Notice under regular review. This Privacy Notice was last reviewed in May 2018.
What We Do
Sarah Flower 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.
Sarah Flower also provides educational seminars, workshops, talks, cookery classes and corporate consultancy as part of our service offering.
You can also subscribe to Sarah Flower recipe website www.everydaysugarfree.co.ukin order to be kept informed of any new recipe and news. You can unsubscribe from this at any time (see below on Newsletters and Contact Forms).
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 payment
Filling in an online contact form
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
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.
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.
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 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 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.
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:
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, 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.
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 SarahFlower 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
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 an automated decision based on your personal data.
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 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.
Sarah Flower 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).
How long do you hold confidential information for?
All records and personal data will be held for the period of 5 years, as advised by our insurance and our professional association FNTP (The Federation of Nutritional Therapy Practitioners). 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.
For Website Data – SarahFlower.co.uk and Everydaysugarfree.co.uk
You may have contacted us through one of our websites, purchased from the online store or signed up to the newsletters. Both websites are created using Wix.com. The following will apply to you.
Should you choose to contact us using the contact form on our Contact us page the email address that you submit to us will be stored in our Wix website platform in the 'Contacts' database, which we use contacting you. We consider Wix to be a third-party data processor (see below). The email address that you submit will be stored within this website’s own database but not in any of our internal computer systems.
Your email address will remain within the Wix 'Contacts' database on our website for as long as we continue to use the Wix platform or until you specifically request removal from the list.
You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that you used on the contact us form.
If you choose to join our regular newsletter mailings (which is sent via email), the email address that you submit to us will be stored in our Wix website platform in the 'Shout Out' database, which we use for our email marketing. We consider Wix to be a third-party data processor (see below). The email address that you submit will be stored within this website’s own database but not in any of our internal computer systems.
Your email address will remain within the Wix 'Shout Out' database on our website for as long as we continue to use the Wix platform for email marketing or until you specifically request removal from the list.
You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by emailing Sarah Flower When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.
If you are under 16 years of age you MUST obtain parental consent before joining our email newsletter.
While your email address remains within the Wix 'Shout Out' database, you will receive occasional newsletter-style emails from us.
Third party data processors
We use two third parties to process personal data on our behalf. The third parties we use are PayPal and Wix.
PayPal process payments for any products purchase from our website. Neither us or PayPal retain any financial information you may submit as part of the purchasing process. PayPal monitor every transaction, 24/7 to prevent fraud, email phishing and identity theft. Every transaction is heavily guarded behind PayPal's advanced encryption. If something appears suspicious, their dedicated team of security specialists will identify suspicious activity and help protect you from fraudulent transactions. PayPal, Wix or Sarah Flower will never ask for any sensitive information.
Your data as mentioned below is encrypted before transmission to prevent misuse of the transmitted data by third parties. SSL (Secure Socket Layer) is a security technology which guarantees that your personal data, including credit card information, login data and payment method, are securely transferred via the Internet. The data is encrypted so that is only readable by the PayPal payment system.
Your data which is encrypted, is as follows:
personal data (address data, telephone number, etc.)
login data (username and password)
all methods of payment selected, credit card and bank account
Wix provides the Customer Engagement platform we use to manage and fulfil your orders. No personal financial information is ever taken or stored in this system as, during the process, everything is transferred out to PayPal so that neither Sarah Flower nor Wix has access to your financial information.
What Wix do to ensure data protection to all our customers
Wix employ full-time security consultants, dedicated to the security of our customer information.
Wix is Payment Card Industry Data Security Standards (PCI DSS) compliant and is accredited as a level 1 service provider and merchant. This standard helps create a secure environment by increasing cardholder data, thus reducing credit card fraud. Wix regularly perform internal security audits to maintain our ISO/PCI security certifications:
ISO 27001:2013 and ISO 27018:2014 Best Practices Certificate
ISO 27108 Certificate
PCIDDS Compliance Certificate
Wix's signup and login services are completed through a secure server (HTTPS/SSL).
Wix uses cryptography hash functions to protect your information. Your password is stored as a hash digest and, in the event of a security breach, your original password cannot be recovered from ours or Wix servers.
Wix is certified under the EU-US Privacy Shield Framework and the Swiss-US privacy Shield Framework as set forth by the U.S. Department of Commerce, regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, and therefore adheres to the Privacy Shield Principles.
Website technical details
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.
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To opt out of being tracked by Google Analytics across all websites visit Here
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.