Centre for Nutrition Education & Lifestyle Management (CNELM) on behalf of NS3UK Ltd (CNELM is a wholly controlled not-for-profit subsidiary of NS3UK Ltd) 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 everyone who visits this website, www.cnelm.co.uk (“Our Site”) and will only collect and 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.
Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
||means an account required to access and/or use certain areas and features of Our Site or other CNELM platforms including OAS and Moodle;
||means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and
|means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data, as defined by EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).
Information About Us
Our Site is owned and operated by CNELM, a Company Limited by Guarantee registered in England under company number 08635327.
Registered address: 14 Rectory Road, Wokingham, RG40 1DH, UK.
Main trading address: As above
Data Manager (DM): Dave Lee
Email address: firstname.lastname@example.org.
Telephone number: 0118 979 8686.
Postal Address: As above.
We are regulated by Information Commissioner’s Office England (ICO)
We are registered with the ICO
What Does This Policy Cover?
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, and other online identifiers.
What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
b. The right to access the personal data we hold about you. Part 13 will tell you how to do this
c. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
d. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 15 to find out more.
e. The right to restrict (i.e. prevent) the processing of your personal data.
f. The right to object to us using your personal data for a particular purpose or purposes.
g. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
h. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
g. For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
What Data Do We Collect?
Depending upon your use of Our Site, we may collect some or all of the following personal and non-personal data (please also see Parts 14-16 below)
- Date of birth;
- Email address;
- Telephone number;
- Business name;
- Job title;
- Payment information;
- Information about your preferences and interests;
- IP address;
- Web browser type and version;
- Operating system;
- A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
- Documentation related to course applications.
NB: Simply by visiting Our Site no personal data is collected. We do not use automated means to process your requests. Your personal data will only be shared by You with Us when using the call to action facilities on Our Site, including the use of the email@example.com email address to send us queries/requests.
How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one or more of the following purposes:
- Providing and managing your Account;
- Providing and managing your access to Our Site/s (CNELM Moodle or OAS);
- Personalising and tailoring your experience on Our Site;
- Supplying our products OR services to you. Your personal details are required in order for us to enter into a contract with you.
- Personalising and tailoring our products OR services for you.
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information by email AND/OR post that you have opted-in to (you may unsubscribe or opt-out at any time. For example, if you subscribe to our new letter, this is posted to you via Mail Chimp which comes with an unsubscribe link. For all non-automated opt outs please contact the DM.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news, and offers on our products AND/OR services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
We do not use any automated systems for carrying out decision-making or profiling.
How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept in accordance with our Data Retention Policy (DRP). A copy of our DRP can be provided by contacting the DM. The following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
- Course enquiries that do not lead to either application or registration will be retained for 14 months following date of offer letter or last activity. Data related to students and staff will be retained in accordance with the DRP and some Data will be retained indefinitely due to legal obligations and public task related to professional accreditations and Higher Education requirements.
How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.
EXCEPT Where we transfer your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield (Google, Microsoft, Zoom, Dropbox). This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.
Please contact us using the details below in Part 15 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
- All CNELM online platform use https encryption.
- Industry standard encryption of passwords and personal data stored online
- Use of encryption and access restrictions on cloud storage services
- End to end encryption available for online conferencing software
- Industry standard encryption of any sensitive ‘special category’ data
Do You Share My Personal Data?
We may share your personal data with other companies in our group or third party companies for contractual and legitimate business interest purposes. For example registration data shared with Middlesex University (MU) for students enrolled on degree programmes validated by MU.
We may sometimes contract with the following third parties to supply certain products AND/OR services. These may include payment processing and delivery. In some cases, those third parties may require access to some of your personal data that we hold.
- Third party student learning resources e.g. Science Direct, Royal Society of Medicine etc. All EEA based.
- Third party student learning resources e.g. Institute of Functional Medicine. US based.
- Amazon for sending textbooks
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 9.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
How Can I Control My Personal Data?
11.1 In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data.
11.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11.3 CNELM does not engage in unsolicited and bulk direct marketing via email, text or phone. CNELM will only contact you in response to your queries and requests. Students, graduates, staff and other stake holders will receive emails from Us related to CPD, Job opportunities, Conferences etc that are relevant.
11.4 All students, graduates and alumni that have CNELM accounts then you can access your core profile information and correct or update this.
Can I Withhold Information?
You may access certain areas of Our Site/s without providing any personal data at all. However, to use all features and functions available on Our Site/s you will be required to submit or allow for the collection of certain data.
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 in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month 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 our progress.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown an alert on the first visit for each unique device or if you clear you internet cache. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
The following first-party Cookies may be placed on your computer or device:
|Name of Cookie
||WordPress cookie for a logged in user
||yes – but for administrators only
||This is used to customize your view of admin interface, and possibly also the main site interface.
||yes – but for administrators only
||Unique Site identifier
Our Site uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the products AND/OR services offered through it.
The analytics service(s) used by Our Site use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.
The analytics service(s) used by Our Site use(s) the following Cookies:
|Name of Cookie
||First / Third Party
||Google Analytics (GA)
||Used to distinguish users
||Used to distinguish users
||Used to throttle request rate
||Stores the traffic source or campaign that explains how the user reached your site.
||Used to throttle request rate.
||Not used in ga.js. Set for interoperability with urchin.js. Historically, this cookie operated in conjunction with the __utmb cookie to determine whether the user was in a new session/visit
||Used to determine new sessions/visits
||Used to distinguish users and sessions
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
Types of Cookies
All Cookies used by and on Our Site are used in accordance with current Cookie Law. We may use some or all of the following types of Cookie:
15.1 Strictly Necessary Cookies
A Cookie falls into this category if it is essential to the operation of Our Site, supporting functions such as logging in, your shopping basket, and payment transactions.
15.2 Analytics Cookies
It is important for Us to understand how you use Our Site, for example, how efficiently you are able to navigate around it, and what features you use. Analytics Cookies enable us to gather this information, helping Us to improve Our Site and your experience of it.
15.3 Functionality Cookies
Functionality Cookies enable Us to provide additional functions to you on Our Site such as personalisation and remembering your saved preferences. Some functionality Cookies may also be strictly necessary Cookies, but not all necessarily fall into that category.
Consent and Control
16.1 In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
16.2 The links below provide instructions on how to control Cookies in all mainstream browsers:
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 use the following details (for the attention of Dave Lee):
Email address: firstname.lastname@example.org
Telephone number: 0118 979 8686.
Postal Address: 14 Rectory Road, Wokingham, RG40 1DH, UK.
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.