HOLISTIC WELLNESS

Holistic Wellness – Insights to Your Health
Last updated: August 2026

Holistic Wellness is committed to protecting the privacy, confidentiality and security of the personal information entrusted to the practice.

This Privacy Policy explains how Holistic Wellness collects, uses, stores, shares and protects personal information in accordance with applicable United Kingdom data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Because Holistic Wellness provides nutritional, complementary health and wellbeing services, some of the information provided by clients may include information concerning their health. Health information is classified as special category personal data and is therefore subject to additional protections.

This Privacy Policy should be read alongside the Holistic Wellness Practice Disclaimer and any applicable consent, booking or assessment documentation.

1. WHO IS RESPONSIBLE FOR YOUR INFORMATION?
For the purposes of UK data protection legislation, Holistic Wellness acts as the data controller for personal information collected and processed in connection with the practice, except where another organisation is independently responsible for particular information.

The data controller determines why and how personal information is processed.

Practice: Holistic Wellness
Practice slogan: Insights to Your Health
Data Controller: Gavin Oppert
Contact email: gavin@insightstoyourhealth.com
Telephone: 07719197471

Questions regarding this Privacy Policy, your personal information or the exercise of your data protection rights should be directed to the contact details above.

2. PERSONAL INFORMATION WE MAY COLLECT
The information collected will depend upon your interaction with Holistic Wellness and the services you receive.

This may include:

Identity and Contact Information
Full name
Date of birth
Age
Sex, where relevant to an assessment
Address
Telephone number
Email address
Emergency contact details where appropriate

Appointment and Administrative Information
This may include:
Appointment dates and times
Booking history
Cancellation information
Correspondence concerning appointments
Communication preferences
Payment and transaction records
Invoices and receipts

Holistic Wellness does not intentionally retain complete payment-card details where payments are processed through an independent payment provider.

Health and Wellbeing Information
To provide an appropriate nutritional or complementary health assessment, you may be asked to provide information concerning your health and wellbeing.

This may include:
Current and previous health concerns
Symptoms
Relevant medical history
Diagnosed medical conditions
Previous investigations
Allergies and intolerances
Prescription medication
Over-the-counter medication
Nutritional supplements
Herbal products
Previous operations or procedures
Family health history where relevant
Dietary information
Lifestyle information
Sleep patterns
Exercise
Smoking
Alcohol consumption
Stress and wellbeing information
Relevant hormonal, digestive, metabolic or other health information
Relevant information provided by your GP, consultant, pharmacist or other healthcare professional where you have supplied or authorised this information

Health information is treated as special category personal data under UK GDPR.

3. ASSESSMENT AND SCREENING INFORMATION
Depending upon the services you choose, Holistic Wellness may create or retain records relating to complementary assessments and screening.

These may include information arising from:
Nutritional assessment
Lifestyle assessment
Live Blood Analysis
Dry Blood Analysis
Iridology
Sclera observation
Nailfold Capillaroscopy
Point-of-care biomarker screening
Follow-up assessments

Information may include written observations, numerical screening results, practitioner notes, recommendations and relevant images.

These assessments are subject to the limitations explained within the Holistic Wellness Practice Disclaimer.

4. PHOTOGRAPHS AND CLINICAL OR ASSESSMENT IMAGES
Some assessments may involve capturing images for the purpose of recording or explaining observations.

These may include, where applicable:
Microscopy images
Iris images
Sclera images
Nailfold capillary images
Images associated with assessment findings
Other images relevant to an agreed assessment

Where images are identifiable or can reasonably be connected with an identifiable client, they will be treated as personal information and, where they reveal information concerning health, may constitute special category personal data.

Assessment images will be used for the purposes explained to the client.

Images will not be used for marketing, advertising, social media, website content, teaching, presentations or promotional materials without an appropriate separate permission or other valid legal basis.

Where specific consent is relied upon for such additional use, you may withdraw that consent for future use.

5. BIOMARKER INFORMATION
Where you request or agree to point-of-care biomarker screening, Holistic Wellness may record:
The biomarker tested
Date of testing
Numerical result
Applicable units
Relevant reference information
Practitioner comments
Recommendations arising from the result
Recommendations to seek GP or other medical assessment where appropriate

Biomarker results constitute health information and will therefore be handled as special category personal data.

6. WHY WE PROCESS YOUR INFORMATION
Holistic Wellness may process personal information for purposes including:
Arranging and managing appointments
Communicating with clients
Providing requested services
Conducting nutritional and lifestyle assessments
Recording complementary observations
Conducting agreed point-of-care screening
Preparing personalised reports
Providing nutritional, supplement and lifestyle recommendations
Monitoring progress at follow-up consultations
Maintaining appropriate client records
Supporting continuity of service
Maintaining financial and accounting records
Processing payments
Responding to enquiries
Managing complaints
Maintaining appropriate professional and practice records
Meeting legal, regulatory, insurance or professional obligations
Establishing, exercising or defending legal claims where necessary
Protecting the safety, security and legitimate interests of clients and the practice

Personal information will not be used for purposes incompatible with those for which it was collected unless permitted by law.

7. OUR LAWFUL BASIS FOR PROCESSING
UK GDPR requires a lawful basis for processing personal information.

Depending upon the circumstances, Holistic Wellness may rely upon one or more lawful bases under Article 6 UK GDPR, including:

Contract
Processing may be necessary to provide services you have requested or to take steps at your request before entering into an agreement for services.

For example, this may include processing information to:
Arrange your appointment
Communicate about your consultation
Provide your assessment
Prepare an agreed report
Process payment

Legal Obligation
Certain information may need to be processed or retained to comply with legal obligations, including financial, accounting or taxation requirements.

Legitimate Interests
In appropriate circumstances, Holistic Wellness may process information where this is necessary for legitimate interests and where those interests are not overridden by your rights and freedoms.

Examples may include appropriate practice administration, security, maintaining records, managing enquiries, establishing or defending legal claims and improving the operation of the practice.

Consent
Where appropriate, consent may be relied upon for particular processing activities.

Where processing is based upon consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing undertaken before consent was withdrawn.

8. SPECIAL CATEGORY HEALTH INFORMATION
Information concerning health receives additional protection under UK GDPR.

Holistic Wellness will only process special category personal data where both an appropriate Article 6 lawful basis and an applicable condition under Article 9 UK GDPR and the Data Protection Act 2018 are available.

The particular legal basis will depend upon the nature of the service, the information involved and the circumstances in which it is processed.

Where explicit consent is relied upon for a particular activity, that consent will be requested appropriately.

Holistic Wellness does not assume that consent is automatically the correct legal basis for every aspect of health-information processing.

9. INFORMATION PROVIDED VOLUNTARILY
Clients are encouraged to provide accurate and relevant information where it is necessary to conduct an appropriate assessment.

You should inform Holistic Wellness if important information changes, particularly:
Medication
Diagnosed medical conditions
Allergies
Pregnancy or breastfeeding status
Relevant investigation results
Significant changes in symptoms
Relevant medical treatment

Failure to provide certain information may limit the ability of Holistic Wellness to provide an appropriate or safe service.

10. INFORMATION RECEIVED FROM THIRD PARTIES
In some circumstances, information may be received from another person or organisation.

This could include information supplied by:
Your GP
Consultant
Pharmacist
Other healthcare professional
Another practitioner
A clinic or venue through which you have arranged an appointment
A family member or representative acting with appropriate authority

Where appropriate, Holistic Wellness will take reasonable steps to ensure that such information is handled lawfully and confidentially.

11. SHARING YOUR INFORMATION
Holistic Wellness does not sell your personal or health information.

Personal information will only be shared where there is an appropriate reason and lawful basis for doing so.

Depending upon the circumstances, information may be shared with:
Service providers supporting the operation of the practice
IT, website, booking or secure data-storage providers
Payment processors
Accountants or professional advisers
Insurers
Legal advisers
Healthcare professionals where appropriate and lawful
Regulatory or public authorities where disclosure is legally required

Where third-party processors handle personal information on behalf of Holistic Wellness, appropriate data-protection arrangements will be used where required.

Only information reasonably necessary for the relevant purpose will be disclosed.

12. COMMUNICATION WITH YOUR GP OR OTHER HEALTHCARE PROFESSIONALS
Holistic Wellness recognises the importance of appropriate collaboration with conventional healthcare professionals.

Where appropriate, you may be advised to discuss findings or concerns with your GP, pharmacist, consultant or another healthcare professional.

Information will ordinarily be shared with another healthcare professional with your knowledge and where an appropriate legal basis exists.

There may be exceptional circumstances in which information can or must be disclosed without consent, for example where disclosure is required by law or where another recognised legal basis applies.

13. CONFIDENTIALITY
Information discussed during consultations is treated confidentially.

Access to personal and health information is restricted to individuals who reasonably require access for an appropriate purpose.

Confidentiality may be subject to limited exceptions where disclosure is required or permitted by law.

14. HOW INFORMATION IS STORED
Holistic Wellness takes reasonable technical and organisational measures designed to protect personal information against:
Unauthorised access
Unlawful disclosure
Accidental loss
Destruction
Alteration
Misuse

Depending upon the type of record, information may be stored electronically or in secure physical records.

Electronic information should be protected through measures appropriate to the level of risk, which may include password protection, access controls, secure devices, encryption or appropriately secured cloud services.

Physical records, where maintained, will be stored securely with access appropriately restricted.

15. WEBSITE AND ONLINE SERVICES
When you visit the Holistic Wellness website, certain technical information may be collected automatically by the website platform or associated service providers.

This may include:
IP address
Browser type
Device information
Pages visited
Date and time of access
Website interaction information
Cookie information

Such information may be used for website security, functionality, performance and, where appropriately permitted, analytics.

Where non-essential cookies or similar technologies require consent under applicable UK law, they should not be activated until the appropriate choice has been made.

Further information should be provided through the website's Cookie Policy or cookie-management system.

16. WEBSITE ENQUIRIES AND CONTACT FORMS
If you contact Holistic Wellness through a website enquiry form, email, telephone or another communication method, the information you provide may be processed to respond to your enquiry and, where appropriate, arrange services.

Please avoid sending unnecessary sensitive medical information through general website contact forms or unsecured communication channels.

Where detailed health information is required, you may be asked to provide it through a more appropriate method.

17. EMAIL AND ELECTRONIC COMMUNICATION
Email and other electronic communication methods may be used for:
Appointment administration
Responding to enquiries
Providing agreed reports
Follow-up communication
Other legitimate practice communications

While reasonable precautions are taken, ordinary email and electronic communication cannot always be guaranteed to be completely secure.

Clients should therefore consider the nature and sensitivity of information they choose to send electronically.

18. MARKETING COMMUNICATIONS
Holistic Wellness will distinguish between communications necessary to provide a requested service and optional direct marketing.

Where consent is required for electronic marketing, marketing messages will only be sent where the appropriate permission has been obtained or another lawful basis applies.

You may unsubscribe or withdraw marketing consent at any time using the method provided in the communication or by contacting Holistic Wellness.

Withdrawing marketing consent will not prevent necessary communications concerning appointments, existing services, payments or other administrative matters.

19. COOKIES
The Holistic Wellness website may use cookies and similar technologies.

Cookies may be required for:
Essential website functionality
Security
Remembering preferences
Website performance
Analytics
Other optional functions

Where consent is legally required, non-essential cookies should only be placed after the user has made the relevant choice.

Website visitors should be provided with appropriate controls to accept, reject or manage non-essential cookies.

A separate Cookie Policy may provide further details.

20. INTERNATIONAL TRANSFERS
Some technology, website, cloud-storage, communications or other service providers may process information outside the United Kingdom.

Where personal information is transferred internationally, Holistic Wellness will take reasonable steps to ensure that an appropriate transfer mechanism and safeguards required by UK data protection legislation are in place.

These may include UK adequacy regulations or appropriate contractual safeguards where applicable.

21. HOW LONG WE KEEP INFORMATION
Holistic Wellness will not retain personal information for longer than reasonably necessary for the purpose for which it was collected, subject to applicable legal, professional, insurance, financial and clinical record-keeping considerations.

Different categories of information may therefore be retained for different periods.

Retention decisions may take into account:
The nature of the information
The purpose for which it was collected
Professional record-keeping requirements
Insurance requirements
Taxation and accounting obligations
The possibility of complaints or legal claims
Safeguarding requirements where relevant

When information is no longer required, it will be securely deleted, destroyed or anonymised as appropriate.

A more detailed internal retention schedule may be maintained by Holistic Wellness.

22. YOUR DATA PROTECTION RIGHTS
Depending upon the circumstances and applicable exemptions, UK data protection legislation provides individuals with a number of rights concerning their personal information.

These may include:

Right to Be Informed
You have the right to receive clear information about how your personal information is collected and used.

Right of Access
You may request access to personal information held about you.

This is commonly known as a Subject Access Request (SAR).

Right to Rectification
You may ask for inaccurate personal information to be corrected or incomplete information to be completed.

Right to Erasure
In certain circumstances, you may request deletion of personal information.

This right is not absolute. Holistic Wellness may be required or entitled to retain particular records despite a request for deletion.

Right to Restrict Processing
In certain circumstances, you may ask for processing of your information to be restricted.

Right to Data Portability
Where the relevant legal requirements apply, you may have the right to receive certain information in a structured, commonly used and machine-readable format or request that it be transferred to another organisation.

Right to Object
You may have the right to object to certain processing, including processing based upon particular legitimate interests and direct marketing.

Rights Relating to Automated Decision-Making
UK GDPR provides protections in relation to certain decisions made solely by automated processing that produce legal or similarly significant effects.

Holistic Wellness does not intend to make significant decisions concerning clients solely through automated processing without appropriate safeguards.

Right to Withdraw Consent
Where processing is based upon your consent, you may withdraw that consent at any time.

Withdrawal does not affect the lawfulness of processing undertaken before consent was withdrawn.

23. SUBJECT ACCESS REQUESTS
If you wish to request access to your personal information, please contact Holistic Wellness using the contact details contained within this Privacy Policy.

You will not ordinarily be charged for exercising your data-protection rights.

Holistic Wellness may request reasonable information to confirm your identity before releasing personal information.

Requests will be handled within the timeframes required by applicable data protection legislation.

24. CHILDREN'S INFORMATION
Holistic Wellness recognises that information concerning children requires particular care.

Where services are provided to a child or young person, appropriate consideration will be given to:
Age
Capacity and understanding
Parental responsibility
Consent
Confidentiality
The child's best interests
Applicable safeguarding responsibilities

Personal information concerning children will be handled with appropriate additional care.

25. DATA BREACHES
Holistic Wellness maintains procedures for responding to suspected personal-data breaches.

Where a breach is likely to result in a risk to the rights and freedoms of individuals, it will be assessed and, where required by law, reported to the Information Commissioner's Office (ICO).

Where a breach is likely to result in a high risk to an affected individual, that individual will also be informed where required by law.

26. YOUR RIGHT TO COMPLAIN
If you have concerns about how Holistic Wellness handles your personal information, please contact the practice in the first instance so that the matter can be investigated.

You also have the right to raise concerns with the Information Commissioner's Office (ICO), the UK's independent regulator for data protection.

Further information about data-protection rights and how to make a complaint is available directly from the Information Commissioner's Office.

27. CHANGES TO THIS PRIVACY POLICY
This Privacy Policy may be updated periodically to reflect:
Changes to the services provided
Changes in technology
Changes in how information is processed
Changes in legal or regulatory requirements
Changes to third-party service providers

The latest version will be made available through the Holistic Wellness website.

The date of the most recent revision will be displayed at the beginning of this policy.

28. CONTACT HOLISTIC WELLNESS
For questions concerning this Privacy Policy, requests concerning your personal information or the exercise of your UK GDPR rights, please contact:

Holistic Wellness
Data Controller: Gavin Oppert
Email: gavin@insightstoyourhealth.com
Telephone: 07719197471

Privacy Commitment
Holistic Wellness recognises that clients may disclose sensitive and personal information when seeking nutritional and complementary health support.

The practice is committed to treating that information with confidentiality, respect and appropriate security, using it only where there is a legitimate and lawful reason to do so.

Holistic Wellness – Insights to Your Health