This privacy policy is to give you as my clients or prospective clients, their family members, carers or guardians as well as service providers and others concerned with data use who reside in the UK and EU about my privacy policies in relation to them.

Emma Davies and Pom Nutrition hold 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 business via my email info@pomnutrition.co.uk

I keep the Privacy Notice under regular review. This Privacy Notice was last reviewed in August 2024

As part of my business I provide nutritional therapy services to clients to improve their health through diet and lifestyle interventions.  I focus on natural and preventative healthcare and work commonly within the functional medicine model. I focus on 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 (supplementation) and lifestyle advice. In addition I also provide other business services such as educational talks, blogs and recipe advice.

Information provided by you. You may be providing us with personal data in the following ways:

• By completing a nutritional therapy questionnaire either written or submitted online

• By accepting  my terms and privacy policy statement via the online questionnaire

• During a nutritional therapy consultation

• Through email, video consults, over the telephone or by post

• By taking debit/credit card and online payment when purchasing my services or products

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

Any other information or personal data that you may provide to me during the application process, such as views or interests expressed during consultations, in the questionnaire or first contact form. I 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 I retain your personal data for the period defined by our registrant body, ICO. This enables me/myself to process any complaint you may make. In this case the legal basis of our holding your personal data is for contract administration.

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.

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 and third party fulfilment. 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 that is consistent with my 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.

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. This is achieved through you signing up to my mailing list  via the website.

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:

• Our registrant body, CNHC and our professional association, BANT, for the processing of a complaint made by you

• 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, CMA) if we have a duty to do so or if the law allows us to do so

• I may share your information with supplement companies, pharmacies and biochemical testing companies as part of providing you with direct healthcare and fulfilment of products. 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 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.  I will first seek your explicit consent before processing your data in this way.

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 me at emmadavies@pomnutrition.co.uk. I shall respond within 20 working days from the point of receiving the request and all necessary information from you. 

My response will include the details of the personal data I hold on you including:

• Sources from which I acquired the information

• The purposes of processing the information

• Persons or entities with whom I am 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 me to stop processing information about you where I am not required to do so by law or in accordance with the CMA guidelines.

• Receive a copy of your personal data, which you have provided to me, in a structured, commonly used and machine readable format and have the right to transmit that data to another controller, without hindrance from me.

• Object at any time to the processing of personal data concerning you

I 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 the Data Controller at info@pomnutrition.co.uk

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. I 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.

Pom Nutrition 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).

All records held by Pom Nutrition will be kept for the duration specified by guidance from our professional association.

I do use electronic forms on our website  or electronic diary system 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 website:

Cookie name:  Accept Cookies

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

Cookie name: Google Analytics

Purpose: These cookies are used to collect information about how visitors use our site. I use the information to compile reports and to help improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.

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. 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 https://tools.google.com/dlpage/gaoptout

Like most websites, I make use of analytics software in order to help myself understand the trends in popularity of our website and of different sections.  I make no use of personally identifiable information in any of the statistical reports I use from this package. I use an analytics package called Google Analytics who provide details of their privacy policy on the Google website.

If you have a complaint regarding the use of your personal data then please contact me by email to info@pomnutrition.co.uk 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.

This policy will be reviewed on an annual basis and as and when necessary following any legislative changes or relevant best practice recommendations.  The last reviewed data is specified above within this policy.

I do not guarantee that the information I provided will help all everyone and following them are at your own risk. You recognise that any advice I share on my website or in a blog is solely from personal experience and education and may not suit or work for everyone. You therefore release me from any blame or claim arising from such a situation.