Privacy notice

1. Who is responsible for your information

Lifespan Nutrition Ltd is the data controller for the information described in this notice. The company is registered in England and Wales, number 12698638, at Springbank Clinic, 13 Pembroke Road, Sevenoaks, Kent TN13 1XR.

The practice is led by Dr Melissa Bujtor, a dietitian registered with the Health and Care Professions Council, registration number DT036246. You can verify that registration on the HCPC register.

The same company also operates SUSTAIN, a multidisciplinary lifestyle service delivered with independent practitioners. Where those practitioners keep their own clinical records, they are separate controllers for those records.

If you have a question about how your information is handled, or you want to exercise any of the rights in section 8, please write to enquiries@drbujtor.com or telephone 01732 453956.

The practice has not appointed a Data Protection Officer. One is required where an organisation processes special category data on a large scale, and a single practitioner seeing patients individually does not meet that threshold. Dr Bujtor is responsible for data protection in the practice.

2. What we collect

If you contact us through this website. The enquiry form asks for your name and email address, and optionally your telephone number. It also asks who the enquiry is about, which service you are interested in, how you heard about the practice, and whatever you choose to write in the message box. You are asked to confirm that you are happy to be contacted, and that confirmation is recorded with your enquiry. Your contact details and your answers to the form's questions (who the enquiry is about, the service, how you heard about the practice, and your confirmation) are kept as a record of the enquiry. Your message is not part of that record; see section 7.

Please share only what you need to at this stage. Many people describe a child's eating or health in an enquiry, and that is entirely reasonable, but anything you write is health information and is treated as such under section 3.

If you download a guide. We ask for your email address so we can send you a copy. We keep a record of the request: your email address, which guide you asked for, when, and whether you ticked the box to receive occasional updates. If you did tick it, we also record the exact wording you agreed to.

If you become a patient. We record what is needed to provide care:

• name, date of birth, contact details, and an emergency contact;
• your GP and any other clinicians involved;
• medical history, medications, diagnoses and allergies;
• dietary and feeding history, and assessment questionnaire responses;
• growth measurements, for children;
• notes of each session, reports, and correspondence;
• recordings of sessions and transcripts made from them, only where you have agreed to that separately;
• appointment, consent, payment and invoicing records.

Automatically. Our hosting provider keeps short-term server logs, including IP addresses, to deliver the site and protect it from abuse. If you accept analytics cookies, the tools in section 9 also record your visit.

3. Why we hold it, and our lawful basis

We must have a lawful basis for everything we do with your information. These are the ones we rely on:

• Providing care, including assessments, sessions and reports: Article 6(1)(b), necessary to perform our agreement with you.
• Answering an enquiry and arranging appointments: Article 6(1)(b), steps taken at your request before that agreement exists. Keeping a record of enquiries, including how you heard about the practice: Article 6(1)(f), our legitimate interest in following up every enquiry and understanding how people find us.
• Sending a guide you asked for: Article 6(1)(b), steps taken at your request. Keeping a record of guide requests: Article 6(1)(f), our legitimate interest in knowing what we have sent and to whom.
• Sending occasional updates: Article 6(1)(a), your consent, given by ticking the box when you download a guide. You can withdraw it at any time, and every update tells you how.
• Recording a session: Article 6(1)(a), your explicit consent, which you can withdraw at any time.
• Writing to your GP or another clinician: Article 6(1)(a), your consent, unless the law requires disclosure.
• Safeguarding and serious risk: Article 6(1)(d), vital interests, where there is a serious concern about someone's safety.
• Payment, invoicing and record keeping required by our regulator or by tax law: Articles 6(1)(b) and 6(1)(c).

Special category data

Information about health is special category data and needs a second condition as well as a lawful basis. For providing care we rely on Article 9(2)(h), processing necessary for the provision of health care and treatment, together with the condition at paragraph 2 of Part 1 of Schedule 1 to the Data Protection Act 2018.

That condition applies because the information is handled by, or under the responsibility of, a registered health professional who owes a duty of confidentiality. Where we rely on your consent instead, for example to record a session, the condition is Article 9(2)(a). Where there is a serious risk to someone's life or safety, it is Article 9(2)(c).

We do not rely on your consent as the basis for providing care, so you do not lose the right to care by declining or withdrawing consent to something else.

4. Clinical records, digital tools, and children

If you become a patient, a clinical record is created and added to at each contact. Record keeping is a professional requirement: the HCPC standards require registrants to keep full, clear and accurate records for everyone they care for. Those records also protect you, because they are the account of your care and you are entitled to see them.

We use digital and AI-assisted tools in normal clinical work, including transcribing sessions you have agreed to record, drafting notes and reports, and preparing session materials. Two things are always true of that:

• we limit what is sent to an AI provider to what the task requires;
• a qualified practitioner always reviews anything a tool produces before it is used in your care or shared with you. No decision about your care is made by a tool alone.

On training. We use these services on the standard terms their providers publish, rather than under a contract we have negotiated, and we turn on the privacy settings each one offers, including any setting that limits using information to improve their models. We rely on those published terms. We cannot look inside a provider's systems to confirm what happens there, so we do not claim more than that.

You can ask at any time how your information is handled by any technology used in your care.

Children. Much of this practice is with children and young people. Where the patient is a child, we take consent from a parent, guardian or carer, and we also consider the child's own understanding and capacity to decide for themselves. Young people aged sixteen and seventeen are presumed able to consent to their own information being processed. Children's records are kept for longer, as set out in section 6.

5. Who we share information with

With your agreement. We write to your GP, and to a referring or treating clinician, where doing so supports your care. We will tell you what we intend to send. Where care involves other professionals, we share what is relevant to their part in it.

Without your agreement, in limited circumstances. We may share information without consent where there is a serious concern about safety, including a child's safety, where a court order or the law requires it, or in response to a formal investigation by a professional regulator. We would normally tell you if we had to do this, unless doing so would increase the risk.

Service providers. These organisations process information on our behalf, under contract and in line with UK data protection law. Individual providers are not named here, because our suppliers change from time to time. A current list of the providers we use, and the safeguard in place for each, is available on request from enquiries@drbujtor.com.

Kind of provider	What for	What they receive	Where
Practice management system	Scheduling, patient records and invoicing	Your details, appointments and clinical notes	EEA
Cloud hosting and infrastructure	Running and storing our clinical platform	Patient and clinical information, encrypted where it is stored	EEA
Speech-to-text transcription	Turning session recordings into text, where you have agreed to a recording	Session audio, not kept by the provider after transcription	US
AI providers	Drafting clinical notes and reports from clinical text	Clinical text	EEA / US
Growth reference calculation service	Working out growth centiles for children	Age, sex and measurements only, with no names or identifiers	UK
Website form and email delivery	Passing on enquiries you send through our website	Your name, email address and message	US
Website hosting	Running this website and passing on enquiries and guide requests	What you send through the website, and short-term server logs	EEA / UK
Email, documents and spreadsheets	Practice email, correspondence and reports, and the record of enquiries and guide requests	Messages, documents and the details you give us	EEA / US

We do not sell your information, and we do not share it for marketing.

6. How long we keep it

We follow the retention periods in the NHS Records Management Code of Practice and our professional body's guidance.

What	How long
Enquiries that do not lead to an appointment	12 months from our last contact with you
Guide download requests	2 years from the request
Your agreement to receive updates	Until you ask us to stop, and then only as long as we need to show we have stopped
Adult clinical records	At least 8 years from the last contact
Children's clinical records	Until their 25th birthday, or 26th if they were 17 when treatment ended, or 8 years from the last contact, whichever is longer
Session recordings	As above, and often deleted sooner once the notes are finalised. You can ask us to delete a recording earlier
Payment and invoicing records	7 years, as HMRC requires
Consent records and correspondence	Alongside the clinical record they belong to

We do not keep information for longer than we need it. When a retention period ends, records are securely destroyed.

7. Where it is stored, and how it is protected

This website and its enquiry endpoint are hosted in the London region of our website hosting provider. Enquiries are delivered into the practice mailbox. The details you give in the enquiry form, other than your message, are also recorded in a spreadsheet in the practice's email and document system, as are guide download requests. Only named members of the practice can open it. Your message itself is kept only in the practice mailbox, and is never copied into that spreadsheet. There is no website database holding what you wrote.

Clinical records are held in our practice management system and in the practice's own clinical platform, with correspondence and reports in the practice's email and document system.

Outside the UK. Some of our service providers process information outside the United Kingdom, principally in the European Economic Area and the United States. The United Kingdom recognises the EEA as providing an equivalent standard of protection, so information moves there freely and no extra safeguard is needed. Transfers to the United States are made under Standard Contractual Clauses or an equivalent safeguard approved under UK data protection law.

How it is protected. Everything sent over the internet is encrypted in transit. Clinical data is encrypted where it is stored. Access is limited to authorised practitioners through role-based controls, transcription tools use short-lived keys that expire within minutes, and significant actions on your record are logged.

8. Your rights

Under the UK GDPR you have the right to:

• ask for a copy of the information we hold about you;
• have inaccurate or incomplete information corrected;
• ask us to delete information, subject to the retention rules in section 6;
• ask us to restrict how we use it;
• object to our using it;
• receive certain information in a portable form; and
• withdraw consent at any time where we relied on it, without affecting anything done before you withdrew it.

To exercise any of these, write to enquiries@drbujtor.com. We will respond within 30 calendar days. There is normally no charge.

Some rights work differently for clinical records. We cannot usually delete a clinical record on request, because we are required to keep it for the periods in section 6, and a record altered after the fact is no longer a reliable account of your care. If something in your record is wrong, we can correct a factual error, and where a professional judgement is disputed we can record your view alongside it.

Where a child is too young to decide for themselves, a person with parental responsibility can exercise these rights for them. As a child grows older, and where they understand what is involved, those rights become theirs.

9. Cookies and website analytics

Nothing is stored on your device unless you agree to it. The first time you visit, we ask whether we may measure how the site is used. If you decline, or simply ignore the question, no analytics cookie is ever set. You can change your mind by clearing this site's data in your browser, which brings the question back.

If you accept, we use two services to understand which pages people find useful and where they arrive from. Neither is used for advertising, and neither is used to identify you:

• Google Analytics records pages viewed, roughly where in the world you are, and how you reached the site. Your IP address is shortened before it is stored.
• Metricool records visits so we can see how well the practice's social media posts bring people here.

If you decline, Metricool is not loaded at all, and Google Analytics runs in a mode that stores nothing on your device. We still see that a page was viewed, with no cookie and nothing that identifies you or your device.

Two things happen regardless, and it is fair to say so. The site loads its typefaces from Google Fonts, so your browser requests those files from Google and Google receives your IP address in the process; no cookie is set by that request. And our hosting provider keeps short-term server logs in order to deliver the site and protect it from attack.

Where a page shows a map, it is provided by Google Maps. When the map loads, your browser connects to Google, which receives your IP address and may set cookies of its own under Google's privacy policy.

We set no advertising cookies, and we do not track you across other websites. The clinical platform used by practitioners sets no marketing cookies at all.

10. Complaints

If you are unhappy with how your information has been handled, please tell us first, at enquiries@drbujtor.com. We would rather hear about it and put it right.

You also have the right to complain to the Information Commissioner's Office, the UK's data protection regulator, and you can do that without contacting us first. The ICO can be reached at ico.org.uk/make-a-complaint, by telephone on 0303 123 1113, or at Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

If your concern is about Dr Bujtor's professional conduct rather than about data protection, the Health and Care Professions Council is the relevant regulator.