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Privacy Policy

Milk to Mealtime (Site) understands that protecting your personal data is important. This Privacy Notice sets out our commitment to protecting the privacy of personal data provided to us, or otherwise collected by us when providing our communications for our mailing list, for access to and communications about the online programmes, for arranging therapy services or when otherwise interacting with you. 

It is important that you read this Privacy Notice together with any other detailed privacy notices we may provide when we are collecting or processing personal data about you so that you understand our privacy practices in relation to your data.

The information we collect

Personal information: is information that relates to an identified or identifiable individual.

We may collect, use, store and disclose different kinds of personal data about you which we have listed below: 

  • Identity Data including first name, middle name, last name, maiden name, title, date of birth, title and images of you. 

  • Contact Data including billing address, delivery address, email address and telephone numbers.

  • Financial Data including bank account and payment card details through our third party payment processor, Pay Pal.

  • Transaction Data including details about payments to you from us and from you to us and other details of products and services you have purchased from us or we have purchased from you.

  • Technical and Usage Data including internet protocol (IP) address, your login data, your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour, information about your access and use of our website, including through the use of Internet cookies, your communications with our website, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider].

  • Profile Data including your username and password for [our Services OR insert name of your platform], profile picture, purchases or orders you have made with us, support requests you have made, content you post, send receive and share through our platform, information you have shared with our social media platforms, your interests, preferences, feedback and survey responses.  

  • Interaction Data including information you provide to us when you participate in any interactive features of our Services, including surveys, contests, promotions, activities or events.  

  • Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.

How we collect personal information

 

We collect personal data in a variety of ways, including:

  • Directly: We collect personal information which you directly provide to us, including e.g. when you register for an account, through the ‘contact us’ form on our website or when you request our assistance via email, or over the telephone.

  • Indirectly: We may collect personal information which you indirectly provide to us while interacting with us, such as e.g. when you use our website, in emails, over the telephone and in your online enquiries.

  • From third parties: We collect personal information from third parties, such as details of your use of our website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies.

 

 

Our lawful purpose for processing personal clinical information

 

Our lawful basis for processing and storing personal information is one of ‘legitimate interest’ under section 6 of the General Data Protection Regulations (GDPR). We cannot adequately deliver a service to you or your child without processing personal information. As it is both a necessity for our service delivery and of benefit to you or your child, we have a legitimate interest to process and store this data.

Data relating to an individual’s health is classified as ‘Special Category Data’ under section 9 of the GDPR. The regulations specify that health professionals who are ‘legally bound to professional secrecy’ may have a lawful basis for processing this data. eating and drinkingTherapists are legally bound to keep client information confidential and it is under this condition that we process and store personal information.

 

It is a legal requirement for all eating and drinkingTherapists to be registered with the Health and Care Professions Council (HCPC). The HCPC has clear standards of conduct, performance and ethics that all registrants must adhere to.

These standards affect the way in which we process and share information, specifically:

  • Standard 2: Communicate appropriately and effectively
    “You must share relevant information, where appropriate, with colleagues involved in the care, treatment or other services provided to a service user.”

  • Standard 10: Keep records of your work
    “You must keep full, clear, and accurate records for everyone you care for, treat, or provide other services to. You must complete all records promptly and as soon as possible after providing care, treatment or other services. You must keep records secure by protecting them from loss, damage or inappropriate access.”

How we collect personal information for clinical use

 

Information about you or your child may be collected in spoken or written form from parents/legal guardians. With parental consent, information may also be collected from other professionals working with you or your child (such as teaching staff, childminders, health professionals and NHS eating and drinkingTherapists). Where relevant to you or your child’s care we may also collect information about family members e.g. contact details for parents, next of kin and relevant medical history.

 

You may use the Milk to Mealtime website without providing any personal information. However, if you wish to make an enquiry via the website’s online submission form, you are requested to provide your name, e-mail address and contact telephone number to enable us to respond to your enquiry. You may add comments or queries which might also contain personal information.

 

If your enquiry does not result in you or your child being supported by Milk to Mealtime directly then this personal information will be deleted once your enquiry has been dealt with. If your child is subsequently supported by Milk to Mealtime these details will be added to their record.

 

How we use personal information

Personal information collected by us via the Milk to Mealtime website, email, telephone or fvirtually, is stored and used by us for the purpose of delivering you or your child’s intervention.

 

We use this information:

  • To prepare, plan and provide eating and drinkingtherapy services appropriate for you or your child’s needs

  • To communicate with you via email, telephone or text message in relation to:
     

    • arranging / confirming and planning for appointments

    • general communication in between appointments

    • sending you reports and programmes for you or your child

    • copying you in to communications with other professionals involved with you or your child

    • sending you resources necessary for you or your child’s eating and drinking intervention

  • For management and administration, for example names and addresses of clients are included in our secure accounting database

Any sensitive personal details are stored in a secure and confidential system and processed in confidence by Milk to Mealtime and shall only be used for the purposes of delivering appropriate eating and drinkingtherapy services to you or your child.

 

With your consent, information about you or your child’s eating and drinkingneeds will be shared with other professionals involved in you or your child’s care, when it is in yours or your child’s best interests. A record of your consent is kept within your child’s record.

 

Unless we are required to do so by law, or for safeguarding purposes, we will not disclose any personal information collected to any person other than as set out above.

 

With your consent we may share information such as appointment dates and times and reports via email. Any email containing sensitive personal data, either in the body of the email will be password protected.

 

We do not employ agents to process personal data.

 

We do not give or sell client details to any third parties.

 

How we store personal information

 

All information about you, your child and their eating and drinkingtherapy is stored securely in our systems to ensure that we have a complete record of our service to them.

 

We use a secure electronic encrypted memory stick, which is only accessible via a password held by the eating and drinkingtherapist involved in the care of you or your child; or on an encrypted and password protected cloud based One drive.

Any paper based confidential information such as assessment record forms are stored securely in accordance with the Information Commissioner’s Office (ICO) data protection regulations before being scanned and uploaded to your or your child’s folders on One drive.

Videos may be sent by parents/legal guardians of clients with parental consent. These are temporarily stored on a password protected tablet or encrypted cloud based One drive.

These may then be viewed by the SLT in order to make notes in a client record within 48 hours of your or your child’s appointment. The video is then permanently deleted. With parental consent videos of clients’ eating and drinkingintervention may be used for training purposes. These videos are temporarily stored on a password protected tablet or encrypted cloud based One drive and deleted immediately after completion of the training for which they were used.

 

In accordance with law, all records will be kept securely until your child is 25 years old or if still receiving treatment at the age of 17, until they are 26 years old. After this time all records relating to your child will be destroyed.

 

Our responsibilities

 

We are committed to maintaining the security and confidentiality of you or your child’s personal information. We actively implement security measures to ensure their information is safe, and review these measures annually.

We are constantly working to ensure compliance with current data protection regulation.

 

We will not release your personal details to any third party without first seeking your consent, unless this is required by law.

 

Your rights

GDPR gives parents the following rights:

  • The right to a copy of the information we hold about you or your child

  • The right to ask for you or your child’s record to be amended if you believe that it is wrong.

How to access you or your child’s records

You can access the information we hold about you or your child by writing to us at the address below.

 

We will provide access to your child’s records within 30 days of receipt of all necessary information. Please make your request via email to info.milktomealtime@gmail.com

If you have any further questions about how we use your information, please contact Laura Bottiglieri (Data Protection Officer) at info.milktomealtime@gmail.com . Further information about data protection legislation is available through the Information Commissioner’s Office www.ico.org.uk.

 

 

 

Purposes and legal bases for processing

We collect and process personal data about you only where we have legal bases for doing so under applicable laws. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please reach out to us if you need further details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose of use / disclosure

Type of Data

Legal Basis for processing

To enable you to access and use our software, including to provide you with a login.

  • Identity Data

  • Contact Data

  • Performance of a contract with you

To provide our Services to you, including to [register your attendance at our events, manage your appointments.

  • Identity Data

  • Contact Data

  • Performance of a contract with you

To contact and communicate with you about our Services including in response to any support requests you lodge with us or other enquiries you make with us.

  • Identity Data

  • Contact Data

  • Profile Data

 

  • Performance of a contract with you

 

To contact and communicate with you about any enquiries you make with us via our website.

  • Identity Data

  • Contact Data

  • Legitimate interests: to ensure we provide the best client experience we can offer by answering all of your questions.

For internal record keeping, administrative, invoicing and billing purposes.

  • Identity Data

  • Contact Data

  • Financial Data

  • Transaction Data

  • Performance of a contract with you

  • To comply with a legal obligation

  • Legitimate interests: to recover debts due to us and ensure we can notify you about changes to our [terms of business] and any other administrative points.

For analytics market research and business development, including to operate and improve our Services, associated applications and associated social media platforms.

  • Profile Data

  • Technical and usage Data

  • Legitimate interests: to keep our website updated and relevant, to develop our business, improve our Services and to inform our marketing strategy

For advertising and marketing, including to send you promotional information about our events and experiences and information that we consider may be of interest to you.

  • Identity Data

  • Contact Data

  • Technical and usage Data

  • Profile Data

  • Marketing and communications Data

  • Legitimate interests: to develop our Services and grow our business

To run promotions, competitions and/or offer additional benefits to you.

  • Identity Data

  • Contact Data

  • Profile Data

  • Interaction Data

  • Marketing and communications Data

  • Legitimate interests: to facilitate engagement with our business and grow our business

To comply with our legal obligations or if otherwise required or authorised by law. 

 

  • To comply with a legal obligation

 

If you have consented to our use of data about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your data because we or a third party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using our services. Further information about your rights is available below.

Our disclosures of personal information to third parties

We may disclose personal information to:

  • payment systems operators such as PayPal;

  • courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;

  • courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;

  • third parties to collect and process data, such as [Google Analytics (To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time), Facebook Pixel or other relevant analytics businesses]; and

  • any other third parties as required or permitted by law, such as where we receive a subpoena.

Google Analytics: We have enabled Google Analytics Advertising Features including Remarketing Features, Advertising Reporting Features, Demographics and Interest Reports, Store Visits, Google Display Network Impression reporting etc.]. We and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together. 

You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the Google content network, please visit Google’s Ads Preferences Manager here or if you wish to opt-out permanently even when all cookies are deleted from your browser you can install their plugin here.  To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device: On android open the Google Settings app on your device and select “ads” to control the settings. On iOS devices with iOS 6 and above use Apple’s advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device.

Overseas transfers

Where we disclose personal data to the third parties listed above, these third parties may store, transfer or access personal data outside of the United Kingdom. The level of data protection in countries outside of the United Kingdom may be less comprehensive than what is offered in the United Kingdom. Where we transfer your personal data outside of the United Kingdom, we will perform those transfers using appropriate safeguards in accordance with the requirements of applicable data protection laws and we will protect the transferred personal data in accordance with this Privacy Notice. This includes:

  • only transferring your personal data to countries that have been deemed by applicable data protection laws to provide an adequate level of protection for personal data; or

  • including standard contractual clauses in our agreements with third parties that are overseas.

Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Your rights and controlling your personal data

Your choice: Please read this Privacy Notice carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Notice. You do not have to provide personal information to us, however, if you do not, it may affect our ability to provide our Services to you and your use of our Services.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Notice. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us. 

Access, correction, processing and portability: You may request details of the personal data that we hold about you and how we are process it (commonly known as a “data subject request”). You may also have a right in accordance with applicable data protection law to have your personal data rectified or deleted, to restrict our processing of that information, to object to decisions being made based on automated processing where the decision will produce a legal effect or a similarly significant effect on you, to stop unauthorised transfers of your personal information to a third party and, in some circumstances, to have personal information relating to you transferred to you or another organisation. 

Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Withdraw consent: Where we are relying on consent to process your personal data, you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. 

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.  

Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk. 

Cookies

We may use cookies on our website from time to time. Cookies are text files placed in your computer's browser to store your preferences. We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our online Services. They include, for example, cookies that enable you to log into secure areas of our online Services, use a shopping cart or make use of e-billing services.

  • Analytical/performance cookies. These are cookies that allow us to recognise and count the number of visitors to our online Services and to see how visitors move around our online Services when they are using them. This helps us to improve the way our online Services work, for example, by ensuring that users find what they are looking for easily.

  • Functionality cookies. These are used to recognise you when you return to our online Services. These cookies enable us to personalise our content for you and remember your preferences (for example, your choice of language or region).

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie

Purpose

Currency

This cookie stores the currency used for the online Services (AUD)

Language

This cookie stores the language used for the online Services (English)

PHPSESSIONID

This cookie contains a unique ID to support functions (for example last viewed products) to improve user experience

newsbcsub

This cookie is stored once the user has completed or closed the Register Pop Up, preventing it from re-appearing until after 7 days

TLSCookiesEU

This cookie tracks when a user has accepted that the online Services use cookies preventing the popup from being displayed again during that session

_ga / _gid / _gat

These cookies are used by our Google Analytics account to track customer traffic through the website to help us understand how our website is being used by our customers

 

Links to other websites

Our website may contain links to other party’s websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Notice.

Personal information from social network accounts

If you connect your account with us to a social network account, such as Facebook, Google,  we will collect your personal information from the social network. We will do this in accordance with the privacy settings you have chosen on that social network. 

The personal information that we may receive includes your name, ID, user name, handle, profile picture, gender, age, language, list of friends or followers and any other personal information you choose to share.

We use the personal information we receive from the social network to create a profile for you on our platform. 

If you agree, we may also use your personal information to give you updates on the social network which might interest you. We will not post to your social network without your permission.

Where we have accessed your personal information through your Facebook account, you have the right to request the deletion of personal information that we have been provided by Facebook. To submit a request for the deletion of personal information we acquired from Facebook, please send us an email at the address at the end of this Privacy Notice and specify in your request which personal information you would like deleted. If we deny your request for the deletion of personal information, we will explain why.

Amendments

We may change this Privacy Notice from time to time. We will notify you if we make a significant change to this Privacy Notice, by contacting you through the contact details you have provided to us and by publishing an updated version on our website.

For any questions or notices, please contact at:

Milk to Mealtime

info.milktomealtime@gmail.com

Last update: 16/04/2024

© LegalVision Law UK Ltd

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