GENERAL DATA PROTECTION
REGULATION (GDPR) PRIVACY NOTICE
INTRA Performance Group understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients and will only use personal data in ways that are described here and in a way that is consistent with our obligations and your rights under the law.
1. Information About Us
INTRA Performance Group registered in England under company number 06934277, whose registered address is 86-90 Paul St, Shoreditch, London, EC2A 4NE.
Main trading address: 86-90 Paul St, Shoreditch, London, EC2A 4NE
Data Protection Officer: Mr James Collins
Email address: firstname.lastname@example.org
We are regulated by General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”)
2. What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
We will tell you if providing some personal data is optional, including if we ask for your consent to process it. In all other cases, we need you to provide your personal data so we can provide care and treatment and receive payment for these services.
3. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, medical records including digital and radiology data and reports, correspondence from and to other doctors/healthcare workers/hospitals and other online identifiers.
The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
• The right to be informed about processing of your personal data
• The right to have your personal data corrected if it is inaccurate and to have incomplete personal data completed
• The right to object to processing of your personal data*
• The right to restrict processing of your personal data*
• The right to have your personal data erased (the ‘right to be forgotten’)*
• The right to request access to your personal data and information about how we process it
• The right to move, copy or transfer your personal data (‘data portability’)
*these rights do not apply in all circumstances
You have the right to complain to the Information Commissioner’s Office (ICO) which can be found at https://ico.org.uk/. It has enforcement powers and can investigate compliance with data protection law. Your Personal Data is data which by itself or with other data available to INTRA Performance Group can be used to identify you as an individual. INTRA Performance Group is the data controller. This privacy notice sets out how INTRA Performance Group will use your personal data. You can contact our Data Protection Officer (DPO) via email email@example.com if you have any questions.
5. What Personal Data Do We Collect?
• Your name, address and contact details, including email address and home and mobile telephone numbers, date of birth and gender
• Information regarding relevant medical history, and nutrition related information, such as food diaries, exercise and lifestyle habits
• Health monitoring information, such as body composition data. Access to blood tests from medical practitioners
• Your financial information if you are a ‘self-pay’ patient or the financial information of the company or individual who is responsible for the payment of invoices/bills relating to your care (e.g. insurer or sponsor)
• Information received in response to any surveys or, complaints claims
• In an elite sport setting: training data (e.g. GPS), subjective wellbeing data, individual goals and objectives, responses to foods or commercial nutrition products
INTRA Performance Group may collect this information in a variety of ways. For example, data might be collected through online registration forms completed by you at the start of your programme, from correspondence with you; through the Registration process or through interviews, consultations meetings or other assessments.
In some cases, the organisation may collect personal data about you from third parties, such as other team members (e.g. referrers).
6. How Do You Use My Personal Data?
• To support the provision of your nutrition programme and its bespoke requirement
• To decide how best to provide programme / strategy for you
• As necessary to support the healthcare contract with you and to allow us to receive full payment for those services
• To keep your records up-to-date as necessary for our own legitimate interests or those of other persons and organisations
• For good governance, accounting, and managing and auditing our performance and business operations
• To monitor emails, calls, other communications, and activities on INTRA Performance Group networks and systems
• For market research, analysis and developing statistics for improving performance; and
As necessary to comply with a legal obligation:
• When you exercise your rights under Data Protection Laws and make requests
• For compliance with legal and regulatory requirements and related disclosures
• For establishment and defence of legal rights
Based on your consent:
• If you ask us to disclose your personal data to other people or organisations such as a company handling a claim on your behalf; or otherwise agree to disclosures;
• When we process any special categories of personal data about you at your request (e.g. data concerning your health)
You are free at any time to change your mind and withdraw your consent. The consequence might be that we cannot continue to provide full healthcare services to you
7. How Long Will You Keep My Personal Data?
Information will be kept in accordance with the retention periods outlined in the Information Governance Alliance (IGA) Records Management Code of Practice for Health and Social Care (2016). Information may be held for longer periods where the following apply: Retention in case of queries. We will retain your personal data as long as necessary
to deal with any queries you may have
• Retention in case of claims. We will retain your personal data for as long as you might legally bring claims against us
• Retention in accordance with legal and regulatory requirements. We will retain your personal data after you have received healthcare services at our facilities based on our legal and regulatory requirements.
8. How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer your personal data in the UK. This means that it will be fully protected under the GDPR.
9. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes except under the following limited circumstances.
• Consultants, nutritionists, sports science / sports medicine professionals who provide treatment to you
• Other healthcare providers where we feel this will enhance the quality of your care
• Sub-contractors and other persons who help us to provide healthcare products and services to you
• Companies and other persons providing services to you as part of your extended care
• Our legal and other professional advisors, including our auditors
• Fraud prevention agencies, credit reference agencies, and debt collection agencies
• Government bodies and agencies in the UK and overseas (e.g. HMRC who may in turn share it with relevant overseas tax authorities and with regulators)
• The Information Commissioner’s Office (ICO)
• Courts, to comply with legal requirements, and for the administration of justice
• In an emergency or to otherwise protect your vital interests
• To protect the security or integrity of our business operations and other patients
• Payment systems and providers
• Anyone else where we have your consent or as required by law
10. How Can I Access My Personal Data?
• If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
• All subject access requests should be made in writing and sent to the email or postal addresses shown.
• We will respond to your subject access request within 14 working days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request.
You will be kept fully informed of progress.
11. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please email firstname.lastname@example.org
12. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Information relating to any changes will be made available via email.
INTRA Performance Group