CNELM and NS3UK Ltd understand 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 Stakeholders 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.
Please note that the information in this policy is also available on our website
- Information About Us
- CNELM (Centre for Nutrition Education & Lifestyle Management)
- Company Limited by Guarantee (not for profit wholly controlled subsidiary of NS3UK Ltd) registered in England and Wales under company number 08635327
- Registered address for NS3UK Ltd and CNELM: 14 Rectory Road, WOKINGHAM, RG40 1DH registered in England and Wales under company number 4239159
- Main trading address for both companies: 14 Rectory Road, WOKINGHAM, RG40 1DH
- VAT number for NS3UK Ltd: 785643682
- Data Protection Officer: David Lee
- Email address: email@example.com
- Telephone number: 0118 9798686
- Postal Address: 14 Rectory Road, WOKINGHAM, RG40 1DH
- Lead Authority for UK GDPR
The lead authority is the supervisory authority. Therefore, the lead authority for CNELM and NS3UK Ltd is
the UK’s Information Commission Office (ICO) and governed under the laws of England including UK GDPR
and the Data Protection Act 2018. The UK is no longer an EU member state and the EU has added the UK
to their Data Protection Adequacy List. This means the UK’s Data Protection Laws and regime is considered
of equivalence to EU GDPR and thus allows the transfer of Data between the UK and the EU and EEA in
compliance with GDPR.
- The Purpose of this Notice
This Notice is designed to help you understand what kind of information we collect in connection with our products and services and how we will process and use this information. In the course of providing you with products and services we will collect and process information that is commonly known as personal data.
- 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.
- 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’. GDPR is incorporated into UK Law in the Data Protection Act 2018 as UK GDPR.
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.
The personal data that we use is set out in Part 7, below.
Personal data may contain information which is known as special categories of personal data. This may be
information relating to and not limited to, an individual’s health, racial or ethnic origin, political opinions,
religious or philosophical beliefs, trade union membership, genetic and biometric data, or data relating to
For the purposes of safeguarding and processing criminal conviction and offence data responsibly, this data
is treated in the same manner as special categories of personal data, where we are legally required to
comply with specific data processing requirements.
- What Are Your Rights?
Under UK GDPR, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 13.
- The right to access the personal data we hold about you. Part 12 will tell you how to do this.
- 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 13 to find out more.
- 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 13 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to data portability. This means that you can ask us for a copy of your personal data held by us to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
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 13.
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.
- Personal Data We Collect
We may collect some or all of the following personal data (this may vary according to your relationship with
- Date of birth;
- Criminal convictions;
- Marital Status;
- Place of birth;
- Emergency contact;
- Email address;
- Telephone number;
- Mobile number;
- Business name;
- Job title;
- Payment information;
- Information about your preferences and interests;
- Health and Illness;
- Biometric and genetic data
Your personal data is obtained from the following third parties:
- Testing Laboratories;
- Healthcare Professionals;
- Disclosure and Barring Agency (DBS) – UK Only;
- Authorised third party acting on behalf of a student, client or staff member
- How Do You Use My Personal Data?
Under UK 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, because it is in our legitimate business interests to use it or because we have a Legal
Obligation to retain your Data.. Your personal data may be used for one of the following purposes:
- Providing and managing your account.
- Supplying our programmes and services to you. Your personal details are required in order for us to enter into a contract with you.
- Personalising and tailoring our programmes and services for you.
- Communicating with you. This may include responding to emails or calls from you. If you become a student or member of staff you will be issued a Company email account and all future correspondence will be sent to this email address except for a) when you have not responded within a reasonable timeframe b) to send end of service documentation.
- Supplying you with information by email that you have opted-in to, you may unsubscribe or opt-out at any time by email or sending by post your request to the Data Manager firstname.lastname@example.org
- If you object to the collection, sharing and use of your personal data we may be unable to provide you with our services and access to our programmes and employment opportunities.
We do not use your data to market our products or services to you nor do we sell your data to third parties.
We will send you information about Continuing Professional Development and job opportunities that we
believe will be of interest to you.
We do not use automated systems absent of human involvement to make decisions in respect of enquiries,
applications, access to services or any other process.
- 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. You can request a copy of our Data Retention policy from the Data Manager
email@example.com. Below are some examples:
- We will retain your enquiry data for a period of fourteen months following the last contact for statistical purposes and to respond to any reactivation of your enquiry.
- Applicants that do not proceed with a course or job offer their data is retained for a period of fourteen months following the last contact for statistical purposes and to respond to any reactivation of your application.
- We will indefinitely retain electronic copies of student and graduate data related to overall module and course results, certificates, and transcripts (Diploma Supplements) issued to you.
- When you make a complaint we will retain your data for ten years.
- Where legal, or statutory regulation requires us to retain your data for longer periods.
- Client data is retained, in an anonymous and encrypted format, for the purpose of student training and assessment and for quality assurance accreditation oversight for a period of three years following the graduation or exit of the student. Where a client consents for the recording of their consultation to be made available for wider educational purposes the recording is retained for five years. In addition, the Clinic Supervisor will retain client data in accordance with the regulatory requirements. You can contact the Clinic Supervisor for a copy of their Data Protection and Retention Policies.
- How and Where Do You Store or Transfer My Personal Data?
We will only store 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 equivalent standards by law.
We may also share your data with third parties located in the USA which are compliant with UK GDPR and UK Adequacy decisions. UK GDPR and the wider Data Protection Act 2018 includes reference to Codes for use of Cloud Services including services that may Transit Data via the USA. 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:
- We take reasonable physical, administrative, technical and electronic measures to protect your data including the use of https (secure) connection to our servers, encryption of stored data and secure storage of special category data hard copies.
- We implement a password protocol for access to web services including Moodle, our Online Administrative System. Panopto, Company Zoom accounts and Company Gmail and Google Apps.
- Policies and procedures are in place for the management of special category data such as client details related to clinic and coaching assessments or student or staff data related to health, criminal disclosure and application monitoring information, e.g. the use of encryption technologies (7-Zip and encrypted email).
- Use of end-to-end encryption protocols when using conferencing software including Zoom when used for virtual supervision of client consultations.
- Do You Share My Personal Data?
We may sometimes contract with the following third parties to supply products and services to you on our behalf. These may include payment processing, delivery, oversight and quality assurance of courses. In addition, as an Alternative Higher Education Provider and provider of professional courses we are also under a legal obligation to provide information for the purpose of public tasks and vital interests.
In some cases, those third parties may require access to some or all of your personal data that we hold.
- Middlesex University, England for legal and contractual purposes of registering students on the degree programmes we teach that are validated by them as the Awarding Institution; and to enable their quality management of these programmes.
- Office of the Independent Adjudicator (OIA), ENGLAND for legal obligation purposes to enable compliance with annual data returns, and to respond to the OIA should a student or graduate present a complaint to the OIA.
- Qualifi, England for legal and contractual purposes of registering students on the Personalised Nutrition Practice Diploma (PNPD) course Endorsed by them; and to enable their quality management of this programme and for the production of Certificates to graduate of the PNPD Programme.
- UK-ENIC for legal obligation and consent purposes to prevent fraud and to confirm qualifications that meet entry requirements.
- Enrolment Letters produced by CNELM, England for contractual purposes. Letters are provided to students and students may use their letter at their discretion as proof of student status with us.
- Nutritional Therapy Education Commission, England for legal and contractual purposes of enabling courses accredited by them for nutritional therapy practice to be monitored and reviewed.
- British Association for Nutrition and Lifestyle Medicine (BANT – Professional Body), ENGLAND for contractual and consent purposes of facilitating student membership for students completing nutrition degree courses and courses leading to nutritional therapy practice; for vital interests and public task purposes in situations of public safety.
- Clinic Supervisors, UK, for legal, consent, contractual and vital interests purposes to provide supervision of client and student consultations. The client is the client of the Clinic Supervisor and acts as a third party for our students. The client via the Terms of Agreement consents to the Company in processing their data for the purpose of student training and assessment.
- Clinic Supervisors, UK may permit in consultation and agreement with us for a student to work with a client under sixteen years of age. In such situations a legal guardian/parent must accompany the child and provide all consents. Our legal purpose for holding data on a person with incapacity is consent and legitimate interests for our students training and assessment. The Clinic Supervisor has a legal responsibility and purpose for the collection and retention of their client data.
- Clinic Supervisors, UK may permit in consultation and agreement with us for a student to work with a client whose incapacity leads to a request and/or a requirement for a designated third party or parties to participate in, and/or assume responsibility for a client for legal or supportive purposes. Our legal purpose for holding data on a person under the age of sixteen years is consent and legitimate interests for our student’s training and assessment. The Clinic Supervisor has a legal responsibility and purpose for the collection and retention of their client data.
- Royal Society of Medicine, England for contractual and consent purposes to enable students registered on degree programmes and a selection of CNELM courses to become student members of the RSM, and access to their e-learning resources.
- ScienceDirect, England for contractual and consent purposes of enabling students registered on degree programmes and a selection of CNELM courses access to their e-learning resources.
- Zoom, USA for consent, contractual and legitimate interest purposes of enabling access to meetings, tutorials, webinars and similar activities. As many Zoom sessions are recorded this may include your voice and or visual image and consent for this is obtained as part of the student Confirmation Agreement, staff Contract, and client Terms of Agreement. In general Zoom servers used are predominately based in the UK, Ireland or other European States.
- UK CPD, England for contractual and consent purposes of enabling students completing the NLP Practitioner course to participate in an external verification process for NLP Practitioner Certification, and to receive a Certificate upon successful completion.
- ILM, ENGLAND for consent purposes of enabling students that have met NLP Practitioner Certification to progress to further training and certification and ILM membership.
- Turnitin, ENGLAND for contractual and legitimate interest purposes of marking and assessment of student work.
- ACS Accounting, ENGLAND for contractual, legitimate interests and legal purposes for financial accounting and processing.
- Eazipay, ENGLAND for consent, contractual and legitimate interest purposes for collecting Direct Debit payments.
- Various third parties in various locations for consent and contractual purposes to enable payment of fees by other individuals or companies on behalf of a student.
- Balens Ltd. Insurance, ENGLAND for vital interests, legitimate interest and contractual purposes to provide insurance cover for Business, Education, Training School and Public Liability. The data of staff involved in the delivery of programmes are included on the Training School application to enable appropriate insurance cover. No other details are shared with Balens Ltd unless in response to a claim made by any Stakeholder.
- Telenova, ENGLAND for legitimate interest purposes of IT support.
- Trayton Mitchell, ENGLAND for legitimate interest purposes for software development.
- Annette Dickens, ENGLAND for consent purposes to access specific learning assessments.
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.
We may sometimes contract with third parties (as described above) that are located outside the UK or the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). If any personal data is transferred to a third party outside of the UK or 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 UK GDPR, as explained above in Part 8.
In some limited circumstances, we may be legally required to share certain personal data, which might include your data, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority. If Data is transferred outside of the UK or the EEA and not covered by UK Adequacy Listing then CNELM will hold a specific Data Protection Agreement (DPA) inclusive of the Standard Clauses.
- 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 13. 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 fifteen 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 our progress.
- 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 Mr Dave Lee:
Email address: firstname.lastname@example.org
Telephone number: 0118 9798686
Postal Address: CNELM, 14 Rectory Road, WOKINGHAM, RG40 1DH
- 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.
Any changes will be made available on our public website and for staff and students will be made available
on our intranet.
Named Contact Person/s responsible for this Policy
Kate Neil Managing Director and Head of Quality Assurance email@example.com
Dave Lee Centre Administrator, Data Manager and Practice Supervisor firstname.lastname@example.org