Information Governance

Data Protection Policy

Standards, operational principles, and governance rules ensuring personal and special category health data are processed fairly, lawfully, and securely.

Compliant with UK General Data Protection Regulation (UK GDPR) & Data Protection Act 2018

1. Introduction & Policy Statement

1.1 Purpose of Policy

Conscious Nutrition needs to gather and use certain information about individuals, including clients, suppliers, and contacts. This policy describes how this personal data will be collected, handled, and stored to comply with data protection regulations.

1.2 Policy Statement

Conscious Nutrition is committed to protecting the rights and privacy of clients and others in accordance with the UK General Data Protection Regulation. We commit to:

  • Comply with both the law and professional codes of conduct
  • Respect individuals’ rights and choices
  • Be open, honest, and transparent with individuals whose data is held
  • Maintain registration with the Information Commissioner’s Office (ICO)

1.3 Personal & Special Category Data

Conscious Nutrition processes personal data for the provision of direct nutritional healthcare, appointments, invoicing, and optional newsletters. Health information, dietary histories, and biochemical test results constitute Special Category Data, processed strictly under direct healthcare exemptions and legitimate professional interest.

2. The Six Core Data Protection Principles

Conscious Nutrition adheres strictly to the six core principles outlined in Article 5 of the UK GDPR:

1. Lawful, Fair & Transparent

Data collection is fair, lawful, and clear as to how it will be used.

2. Purpose Limitation

Data is collected solely for specified healthcare and administrative purposes.

3. Data Minimisation

Information gathered is adequate, relevant, and limited to clinical necessity.

4. Accuracy

Records are kept accurate, verified, and updated upon notification.

5. Storage Limitation

Retained for no longer than required by clinical and professional guidelines.

6. Integrity & Confidentiality

Protected by robust technical and physical security measures against unauthorized access.

3. Data Security & Storage Controls

Conscious Nutrition keeps all client data secure against loss, theft, or misuse:

  • Physical Paper Records: Kept in locked storage when not in use; cross-shredded when retention periods expire.
  • Electronic Security: Computers and mobile devices are protected by multi-factor authentication, complex password management, and disk encryption.
  • Cloud Storage & Encryption: Cloud providers handling patient scheduling or laboratory records are vetted for strict UK GDPR compliance.
  • Backups: Encrypted automated backups are maintained in secure locations with restricted administrative access.

4. Subject Access & Data Portability Requests

Any individual is entitled to request a complete copy of their personal records held by Conscious Nutrition:

  • Subject access requests are fulfilled free of charge within one calendar month of identity verification.
  • Records are provided in a structured, commonly used electronic format (such as encrypted PDF).
  • Clients can request rectification of inaccurate records or restriction of processing in accordance with law.

Requests should be directed in writing to Alex Georgiou at alex@conscious-nutrition.co.uk.

5. Third Parties & Data Processors

We only engage third-party processors (such as biochemical laboratories Genova Diagnostics, supplement dispensaries, or payment processors like PayPal) who provide written guarantees that their technical security satisfies UK GDPR standards. Written data processing agreements govern all processor relationships.

Personal data is never sold, leased, or transferred to third parties for commercial or marketing purposes.

6. Data Breach Notification Procedure

Conscious Nutrition maintains a strict protocol to detect, investigate, and report data security breaches. In the unlikely event of a security incident that poses a risk to the rights and freedoms of individuals, notification will be submitted to the UK Information Commissioner’s Office (ICO) within 72 hours, and affected individuals will be notified without undue delay.

Data Protection Officer / Controller Contact

Alex Georgiou · Registered Nutritional Therapist

Conscious Nutrition · 111 Piccadilly, Suite 240, Manchester M1 2HY

Email: alex@conscious-nutrition.co.uk · Tel: 0161 706 0389