Reflective Nutrition Privacy Notice
Last updated: 15 October 2026
1. About this privacy notice
When you contact or work with Reflective Nutrition, you may need to share personal and health information. This notice explains what happens to that information and how I look after it.
It explains what personal information I collect, why I use it, how it is stored and protected, when it may be shared, how long it is kept, and the rights you have in relation to your information.
Reflective Nutrition is the data controller for the personal information used in providing its services. This means that I am responsible for deciding how and why your information is used and for making sure it is handled appropriately.
I, Rachel Jennings, am an HCPC-registered dietitian and am professionally bound by standards of confidentiality and record keeping.
For questions about this privacy notice or the way your information is handled, please contact:
Rachel Jennings
Reflective Nutrition
Email: hello@reflectivenutrition.co.uk
Website: www.reflectivenutrition.co.uk
Reflective Nutrition is registered with the Information Commissioner's Office (ICO).
ICO registration reference: ZC191029
2. Information I may collect
Here is the information I might collect, depending on your contact with Reflective Nutrition and the service you receive:
your name and contact details;
information you provide when making an enquiry;
appointment and administrative information;
relevant health and medical information;
information about eating, nutrition, weight history and your relationship with food;
information about your emotional wellbeing and other circumstances relevant to dietetic care;
details of medication and other health or care professionals involved in your care, where relevant;
assessment, formulation, care planning and consultation records;
correspondence between you and Reflective Nutrition;
information shared by another professional or service, where appropriate;
information about payments and invoices; and
records of consent, information sharing and other decisions relevant to your care.
I only ask for information that I actually need to provide or manage your care safely and appropriately.
If you make an enquiry but do not become a client
At enquiry stage, I aim to collect only the information needed to respond to you and consider whether Reflective Nutrition may be an appropriate service.
If clinically significant or risk-related information is disclosed during an enquiry or Discovery Call, this may need to be recorded more formally. Further information about how long enquiry information is kept is provided below.
Providing information to Reflective Nutrition
You are not required by law to provide personal information to Reflective Nutrition. However, some information is necessary to consider whether the service is suitable for you and to provide safe and appropriate dietetic care.
If relevant information is not provided, I may not be able to offer or continue the service.
3. Where your information comes from
Most information is provided directly by you.
With your knowledge and, where required, your consent, relevant information may sometimes also be received from another health or care professional, a family member or another person involved in your care.
There may be exceptional circumstances in which information is received or shared without your consent, for example where this is necessary to respond to a serious and immediate risk, a safeguarding concern or a legal requirement. This will only happen where the law allows it.
4. Why I use your information
Your information may be used to:
respond to your enquiry and arrange appointments;
consider whether Reflective Nutrition is a suitable service for you;
provide safe and appropriate dietetic assessment, formulation and intervention;
maintain an accurate clinical record;
communicate with you about your care;
prepare relevant correspondence or clinical summaries;
liaise with other professionals where this is clinically appropriate;
manage appointments, payments and administration;
meet professional, legal, regulatory and safeguarding responsibilities;
respond appropriately to concerns about safety or wellbeing; and
manage and improve the safe operation of Reflective Nutrition.
I will not use your information for purposes unrelated to the reason it was collected.
Client health and clinical information is not used for marketing purposes.
Reflective Nutrition does not use solely automated decision-making or profiling to make decisions about your care.
5. The legal basis for using your information
In short, data protection law allows me to collect, use and keep health information that is relevant to your care where this is necessary to provide safe dietetic care. This may include information you provide yourself, information appropriately shared by another person or professional, and information recorded as part of your assessment and care.
The more detailed legal position is set out below.
Data protection law requires Reflective Nutrition to have a lawful basis, or legal reason, for using personal information.
Depending on the circumstances, I may collect, use or keep personal information because:
it is necessary to take steps at your request before entering into an agreement with Reflective Nutrition, or to provide the service you have agreed to receive;
it is necessary to meet a legal or professional obligation; or
Reflective Nutrition has a legitimate interest, meaning a genuine need to operate a safe and effective healthcare service, provided that this does not override your rights and interests.
Health information has additional legal protection and is known under data protection law as special category data.
Reflective Nutrition may collect, use and keep health information where this is necessary for providing and managing health care or treatment by a regulated health professional who is professionally bound by confidentiality requirements.
In some specific circumstances, another legal basis may apply, for example where information needs to be used to protect someone's life or immediate safety, meet a safeguarding or legal requirement, or establish, exercise or defend a legal claim.
Consent may still be requested for particular aspects of your care, such as sharing information with another professional. This is separate from the legal basis that allows Reflective Nutrition to hold and use information needed to provide safe dietetic care.
6. How your information is stored and protected
Reflective Nutrition uses secure electronic systems to manage clinical and administrative information.
The main clinical record is held using WriteUpp, a specialist cloud-based practice-management and clinical-record system. WriteUpp acts as a data processor, meaning it securely handles information on behalf of Reflective Nutrition.
WriteUpp stores client information on secure servers within the European Union and uses security measures including encryption and two-factor authentication.
Google Workspace may be used for email, business administration and the temporary preparation of client reports, letters or other documents.
Where information that could identify you is temporarily held in Google Workspace, only the information needed for the task will be used. Once the final version has been sent where appropriate and uploaded to the clinical record in WriteUpp, temporary working copies will be deleted unless there is a clear reason for them to be kept.
Where a document needs to be downloaded temporarily to a computer for sending or other practical purposes, the local copy will also be deleted once it is no longer needed.
WriteUpp remains the main location for the permanent clinical record.
The Reflective Nutrition website is hosted by Squarespace. When you submit an enquiry through the website contact form, the information you provide is processed by Squarespace and forwarded to Reflective Nutrition's business email account. Form submissions may also be retained within Squarespace's website administration system.
Information received through the website enquiry form is used to respond to your enquiry and consider whether Reflective Nutrition may be an appropriate service. Enquiry information is reviewed and retained only for as long as necessary, in accordance with Reflective Nutrition's record-retention arrangements.
Some service providers used by Reflective Nutrition may handle personal information outside the UK. Where this happens, legal safeguards approved under UK data protection law will be used.
Access to client information is restricted to what is necessary for the safe operation of the service.
Appropriate security measures are used to reduce the risk of unauthorised access, loss, alteration or sharing of personal information.
7. Who your information may be shared with
Your information is treated as confidential and is not routinely shared outside Reflective Nutrition.
Where it is clinically appropriate, information may sometimes be shared with another health or care professional involved in your care. This will normally happen with your knowledge and, where required, your consent.
Only information that is relevant and necessary for the purpose will be shared.
There may be exceptional circumstances where information needs to be shared without your consent, for example where:
there is a serious and immediate risk of harm;
there is a safeguarding concern;
sharing is required by law or a court; or
another overriding legal or professional duty applies.
Where this happens, information will be shared only to the extent necessary, and you will normally be informed unless there is a good reason why this would not be appropriate or safe.
Personal information may also be handled by organisations that provide services to Reflective Nutrition, such as secure clinical-record, email, payment, accounting or IT services. Where these organisations handle personal information on behalf of Reflective Nutrition, appropriate data protection arrangements are used.
Personal information is not sold to third parties.
8. Professional supervision and consultation
As part of maintaining safe and effective professional practice, I may discuss aspects of my clinical work in professional supervision or consultation.
Where possible, information will be anonymised or minimised so that you cannot be identified unnecessarily.
If information that could identify you needs to be discussed for a particular clinical or safety reason, this will only be done where there is an appropriate professional and legal reason and in keeping with confidentiality requirements.
Those providing professional supervision or consultation are expected to maintain appropriate professional confidentiality.
9. Communication and online appointments
Reflective Nutrition is currently an online service.
Appointments will therefore take place using an appropriate secure video platform.
Email may be used for administrative communication and, where appropriate, for limited clinical correspondence.
Although reasonable steps are taken to protect electronic communication, no method of communication over the internet can be guaranteed to be completely secure.
I will avoid including unnecessary sensitive information in email and encourage clients to do the same.
Where another method of communication is clinically or practically more suitable, this will be discussed with you.
10. How long your information is kept
Reflective Nutrition does not keep personal information for longer than is necessary.
Clinical records are kept in line with applicable professional guidance, legal requirements and recognised health-record retention guidance.
Different types of information may be kept for different periods depending on:
the nature and purpose of the record;
relevant professional or legal requirements;
the age of the client;
whether the information forms part of the clinical record; and
whether the information may be needed in relation to a complaint, legal matter or professional obligation.
Information relating only to an enquiry that does not progress to assessment will normally be kept for a shorter period than a clinical record, unless there is a clear clinical, legal or safeguarding reason to keep it for longer.
Reflective Nutrition maintains a record-retention schedule setting out how long different types of information are kept. This is reviewed periodically and is available on request.
When information is no longer required, it will be securely deleted, destroyed or anonymised as appropriate. This includes information submitted through the website enquiry form and any copies retained within Squarespace or the business email system.
11. Your data protection rights
You have a number of rights over your personal information. Depending on the circumstances and the way your information is being used, these may include the right to:
be informed about how your information is used;
ask for access to the personal information held about you;
ask for inaccurate information to be corrected;
ask me to limit how your information is used in certain circumstances;
object to certain types of use;
ask for some information to be deleted where the law allows this; and
ask for certain information in a format that can be transferred to another service where this right applies.
These rights are not absolute and some may not apply to particular information, especially where Reflective Nutrition has a professional or legal reason to keep or use it.
Where information is used specifically on the basis of your consent, you may withdraw that consent at any time. This does not affect anything that lawfully took place before consent was withdrawn.
If you wish to exercise a data protection right, please contact Reflective Nutrition using the contact details at the beginning of this notice.
12. If you have concerns about how your information is used
If you have any questions or concerns about how Reflective Nutrition handles your personal information, please contact me in the first instance so that I can try to resolve the issue.
If you remain dissatisfied, you have the right to complain to the Information Commissioner's Office.
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113
Website: ico.org.uk
13. Changes to this privacy notice
This privacy notice will be reviewed periodically and updated if there are significant changes to the way Reflective Nutrition uses personal information or to relevant legal or regulatory requirements.
The current version will be available through the Reflective Nutrition website.