PRIVACY NOTICE FOR NUTRITIONAL THERAPISTS OF IRELAND (NTOI Ltd)
NTOI Ltd holds some information about its members. 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 [email protected]. We keep our Privacy Notice under regular review. This Privacy Notice was last reviewed in May 2018.
- What We Do
NTOI Ltd. is a non-profit organisation and the professional body representing Nutritional Therapists in Ireland. Our members comprise of Practising, Non-Practicing and Student members who meet the criteria set out in our Code of Practice document.
NTOI Ltd also runs educational events for its members and for the public from time to time.
- How We Obtain Your Personal Data
Information provided by you
You provide us with personal data in the following ways:
- By becoming a member
- By signing a terms of engagement form
- By taking credit card and online payment
This may include the following information:
- basic details such as name, address, contact details
- Bank details
We use this information in order to provide you with the service of membership. This means that the legal basis of our holding your personal data is for legitimate interest.
- How we use your personal data
We act as a data controller for use of your personal data to provide your membership service. We act as a data controller and processor in regard to the processing of credit card and online payments.
We undertake at all times to protect your personal data, including any health and contact details, in a manner which is consistent with our 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.
We 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. We may use your data for marketing purposes such as newsletters but this would be subject to you giving us your express consent.
- Do you share my information with other organisations?
We will keep information about you confidential. We will only disclose your information with other third parties with your express consent with the exception of the following categories of third parties:
- Our professional body NTOI, for the processing of a complaint made by you
- Any contractors and advisors that provide a service to us or act as our agents on the understanding that they keep the information confidential
- 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, if we have a duty to do so or if the law allows us to do so.
- What are your rights?
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 [email protected] Under special circumstances, some information may be withheld. We shall respond within 20 working days from the point of receiving the request and all necessary information from you. Our response will include the details of the personal data we hold on you including:
- Sources from which we acquired the information
- The purposes of processing the information
- Persons or entities with whom we are 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 us to stop processing information about you where we are not required to do so by law or in accordance with the NTOI guidelines.
- Receive a copy of your personal data, which you have provided to us, in a structured, commonly used and machine readable format and have the right to transmit that data to another controller, without hindrance from us.
- Object at any time to the processing of personal data concerning you
We 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 write to the Data Controller email [email protected]
- What safeguards are in place to ensure data that identifies me is secure?
We only use information that may identify you in accordance with GDPR. This requires us 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, we 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. We 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.
We also ensure the information we 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). We 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.
- How long do you hold confidential information for?
All records held by NTOI Ltd will be kept for no longer than what is necessary.
- Website technical details
We do use electronic forms on our website making use of an available ‘forms module’ which has a number of built-in features to help ensure privacy. We also aim to use secure forms where appropriate.
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If you have a complaint regarding the use of your personal data then please contact us by writing to the Data Controller at [email protected] and we will do our best to help you.
If your complaint is not resolved to your satisfaction and you wish to make a formal complaint to the Data Protection Commissioner at www.dataprotection.ie