Data Protection & Privacy Policy

ICO Ref no ZB081666

Kristina Triebow is committed to ensuring that your privacy is protected. Should I ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement. By providing me with your data, you warrant to me that you are over 13 years of age.

Kristina Triebow is the data controller and I am responsible for your personal data (referred to as “I”, “me” or “my” in this privacy notice).

Kristina Triebow holds some information about you. This document outlines how that information is used, who I may share that information with and how I keep it secure. This notice does not provide exhaustive detail. However, I am happy to provide any additional information or explanation needed. Any requests for this should be sent to contact@kristinatriebow.com. I keep my Privacy Notice under regular review. This Privacy Notice was last reviewed in May 2023.

Kristina Triebow provides Nutritional Therapy, Naturopathy and Aromatherapy services to clients to improve their health through diet and lifestyle interventions.  I 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, I aim to understand the underlying causes of your health issues which I will seek to address through personalised dietary therapy, nutraceutical prescription (supplements) and lifestyle advice.

Information provided by you

You provide me 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 

This may include the following information:

• basic details such as name, address, contact details and next of kin
• details of contact I 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

I use this information in order to provide you with direct healthcare.  This means that the legal basis of my holding your personal data is for legitimate interest. 

Following completion of your healthcare I retain your personal data for the period defined by my professional association BANT and registrant body, the Complementary and Natural Healthcare Council (CNHC). This enables me to process any complaint you may make.  In this case the legal basis of my holding your personal data is for contract administration.

Information I get from other sources

I may obtain sensitive medical information in the form of test results from biochemical testing companies.  I use this information in order to provide you with direct healthcare.  This means that the legal basis of my holding your personal data is for legitimate interest.  

I may obtain sensitive information from other healthcare providers.  The provision of this information is subject to you giving me your express consent. If I do not receive this consent from you, I will not be able to coordinate your healthcare with that provided by other providers which means the healthcare provided by me may be less effective.

I act as a data controller for use of your personal data to provide direct healthcare.  I 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.  I act as a data controller and processor in regard to the processing of credit card and online payments.

I undertake at all times to protect your personal data, including any health and contact details, in a manner which is consistent with my duty of professional confidence and the requirements of the General Data Protection Regulation (GDPR) concerning data protection.  I will also take reasonable security measures to protect your personal data storage.

I 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. I may use your data for marketing purposes such as newsletters but this would be subject to you giving me your express consent.

I will keep information about you confidential.  I will only disclose your information with other third parties with your express consent with the exception of the following categories of third parties:

• My registrant body, CNHC, and my professional association, BANT, for the processing of a complaint made by you
• Any contractors and advisors that provide a service to me or act as my agents on the understanding that they keep the information confidential
• Anyone to whom I may transfer my rights and duties under any agreement I have with you
• Any legal or crime prevention agencies and/or to satisfy any regulatory request (e.g. CNHC) if I have a duty to do so or if the law allows me to do so

I may share your information with supplement companies and biochemical testing companies as part of providing you with direct healthcare.  I will not include any sensitive information.

I will seek your express consent before sharing your information with your GP or other healthcare providers. However, if I believe that your life is in danger then I 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.

I may share your case history in an anonymised form with my 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.  I will seek your explicit consent before processing your data in this way.

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

Under Article 17 of the GDPR individuals have the right to have personal data erased. If you no longer wish for me to hold a record of your details, please get in touch on 07864 553 241 or email contact@kristinatriebow.com.

You can see more about these rights at:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email me at contact@kristinatriebow.com. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.

I may need to request specific information from you to help me confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. I may also contact you to ask you for further information in relation to your request to speed up my response.

I try to respond to all legitimate requests within one month. Occasionally it may take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you.

If you are not happy with any aspect of how I collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). I would be grateful if you would contact me first if you do have a complaint so that I can try to resolve it for you.

I only use information that may identify you in accordance with GDPR. This requires me 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, I 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. I 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.

I also ensure the information I 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). I ensure external data processors that support me 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.

Kristina Triebow 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 (Ref no ZB081666).

All records held by Kristina Triebow will be kept for the duration specified by guidance from my professional association BANT.

1. Forms

I do use electronic forms on my website making use of an available ‘forms module’ which has a number of built-in features to help ensure privacy. I 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:

Cookie name	Purpose
AcceptCookies	This is used to store whether you have agreed to receive cookies. Persistent for one year.

Cookies are small. I 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.

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.

My website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave my site, you should note that I do not have any control over that other website. Therefore, I cannot be responsible for the protection and privacy of any information, which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

If you have a complaint regarding the use of your personal data then please contact me by writing to the Data Controller at Kristina Triebow, 23 Ash Way, Didcot, OX11 6AN or email contact@kristinatriebow.com and I will do my 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.