Data protection and disclosure of information
As part of our day-to-day business of providing
dietetic services (nutritional assessment, intervention
and monitoring of the client), we need to collect
personal information from our clients and potential
clients to ensure that we can meet their needs for the
provision of or information about the Services.
Your privacy is important to us and it is our policy to
respect the confidentiality of information and the
privacy of individuals. This notice outlines how we
manage your personal information and details your
rights in respect of our processing of your personal
information.We process your information in terms of our
Protection of Information Policy and Retention of
Data Policy. To review same, kindly send a request
to the Information Officer: Roslyn Schenk using the
following email address: larosedietitians@gmail.com
Defined terms herein, were not herein defined, are
defined within the Protection of Personal
Information Act, 2013 (as may be amended or
substituted from time to time) (“POPIA”).
Who are we?
This Privacy Notice applies to the processing
activities of Roslyn Schenk TA LaRose Dietitians
(“LaRose Dietitians”) (the “Practice”; an association
of registered Dietitians (Roslyn Schenk). LaRose
Dietitians (Roslyn Schenk) is the Responsible Party
(and Operator in certain instances) for the processing
of your Personal Information.
Any reference to ‘us’, ‘our’, ‘we’ in this Privacy Notice
is a reference to both Roslyn Schenk and the
Therapists respectively. Similarly, any reference to
‘you’, ‘your’, ‘yours’ or ‘yourself’ in this Privacy Notice
is a reference to any of our clients and potential
clients as a Data Subject, or a Competent Person in
respect of such client and potential client that is
incompetent, such as a minor child.
Our Privacy Notice will be reviewed from time to time
to take account of new obligations and technology,
changes to our operations and practices, and to
make sure it remains appropriate to the changing
environment.
What kind of Personal Information do we collect?
We collect information necessary to fulfil our
obligations to our clients in the course of providing
the Services.
We may collect the following types of information
about you:
Name, address and contact details, date of birth and
gender, bank details, education and qualifications,
employment details, family details, medical aid
details, lifestyle and social circumstances, location
data, any other similar information.
On occasion the following sensitive Personal
Information may be obtained: physical or mental
health details, racial or ethnic origin, religious or
philosophical beliefs, sexual orientation, genetic data,
biometric data. We will only obtain and process this
information with your express consent as set out in
terms of the relevant contractual terms.
Much of this information is collected in order to
establish and assess the reasons for a referral to us
as well as whether we can and should provide the
Services (and products, where relevant) to you. If
you chose not to provide the information required, we
may not be able to provide you with the requested
product or service.
If you provide us with any Personal Information
relating to a third party (e.g. information of your
spouse, children, parents, and/or employees), by
submitting such information to us, you represent to
us that you have obtained their consent and/or
are a Competent Person in respect to the
provision of such Personal Information.
The main activities of the Practice are the
provision of dietetic services. In this respect, by
submitting Personal Information (including
sensitive personal information) to the Practice,
you expressly provide your informed consent for
the collection, processing and storage of such
Personal Information and confirm that you are
duly authorised to do so as a Competent Person.
How is the Personal Information obtained?
We obtain this information in a number of ways, for
example through the submission of a Google Online
form, through the provision of intake assessments,
interviews with you, relevant and related educators,
relevant and related health care professionals, family
members, questionnaires etc. as well as from
information provided in the course of ongoing
services and communication. Additionally, we may
obtain Personal Information about you through your
use of our websites, apps, or using cookies on our
websites, in particular by recording your activity and
which pages you look at on our websites (please see
below on Cookies).
We may record any communications with you
including electronic (including video conference), by
telephone, in person or otherwise, which will
constitute evidence of the communications between
us. This information is collected in compliance with
our regulatory duties in relation to our record-keeping
obligations. It may or may not be retrievable.
Such conversations may be recorded without the use
of a warning tone or any other further notice. Further,
if you visit any of our offices or premises, we may
have CCTV which may record your image and
conversations which you acknowledge, understand
and accept.
What Lawful Basis do we rely on?
We may be required to collect and use certain types
of Personal Information to comply with the
requirements of the law and/or regulations, however
we are committed to processing all personal
information in accordance with POPIA and any other
relevant data protection laws and codes of conduct
(herein collectively referred to as “the data protection
laws”) which are applicable to Roslyn Schenk TA
LaRose Dietitians and its business.
The data protection laws allow us to only process
your data for certain reasons:
to perform a contract that we are party to;
to carry out legally required duties;
for us to carry out our legitimate interests;
where we obtain your consent;
to protect your interests; and
where something is done in the public
interest.
All the processing carried out by us falls into the
permitted reasons, for example; our use of your
personal information in order to comply with our
obligations under contract. This includes where a
contract is not yet signed but you have requested us
to take action as a first step (e.g. to provide dietary
intervention and counselling to a minor).
Consent
Where our use of your personal information requires
consent, such consent will be provided explicitly by
you as set out herein, in the Terms & Conditions
entered into by you with Roslyn Schenk TA LaRose
Dietitians or as otherwise provided or procured.
If we rely on your consent as our legal basis for
processing your personal information, you then have
the right to withdraw that consent at any time by
contacting us using the contact details set out in this
Privacy Notice; however, the withdrawal of consent
may be limited by law or contract or subject to the
completing of a relevant service or other similar and
related activity. Withdrawal of consent will likely
necessitate the termination of services.
We use WhatsApp for communication, which has
embedded end-to-end encryption that ensures only
the persons you’re communicating with can read or
listen to what is sent, and nobody in between, not
even WhatsApp. We also use WhatsApp groups for
convenient communication and support. By agreeing
to join the group you acknowledge and give consent
for your personal contact details being made public
to all those who are on the group. We use Google
Workspace (formerly “GSuite”) which is designed to
meet stringent privacy and security standards based
on industry best practices. We also utilise Microsoft
Teams and Zoom. Further information can be
provided on request or researched via their
respective websites. You consent to us processing
personal information via these channels as well as
telephonic communication.
What we do with the personal information we
obtain?
We may use information held about you in the
following ways:
To provide you with any services and/or
information you request from us (which
includes carrying out any obligations arising
from any contracts entered into between you
and us);
to notify you about changes to our services;
to provide you with information by post,
email, telephone or otherwise about products
and services of a similar nature to those you
have previously purchased or expressed an
interest in which are offered by Roslyn
Schenk TA LaRose Dietitians and which we
think may be of interest to you. You have the
right to ask us not to process your personal
information for marketing purposes. You can
exercise your right to prevent such
processing by contacting us by phone or
email using the details in the ‘Contact us’
section below. You can unsubscribe from
emails by following the unsubscribe
instructions included in every email;
alternatively, on request to the Information
Officer.
to administer our sites and for internal
operations, including troubleshooting, data
analysis, load management, testing,
research, statistical and survey purposes;
to improve our sites to ensure that content is
presented in the most effective manner for
you and for your device;
to measure or understand the effectiveness
of content we serve to you and others, and to
deliver relevant content to you;
for the purposes of providing services such
as ‘most popular’ information on our site;
to deliver targeted advertisements to you and
others as you browse the internet;
to obtain your feedback on a product, service
or our sites via a third party appointed by us;
to allow you to participate in interactive
features of our sites, when you choose to do
so; and
as part of our efforts to keep our sites safe
and secure.
Disclosure of your personal information
We may share the Personal Information we hold
about you across Roslyn Schenk TA LaRose
Dietitians and its Therapists to enable us to better
understand your needs and run your accounts in the
efficient way that you expect. Your Personal
Information may also be used for customer
modelling, statistical and trend analysis, with the aim
of developing and improving our products and
services.
We will never sell, trade, or rent your Personal
Information to others; however, we may share your
information with selected third parties including:
our service providers, suppliers and subcontractors for the performance of any
contract we have entered into with them.
They may then process this data on our
behalf to help run some of our internal
business operations for example IT services.
governmental or judicial bodies or agencies
to comply with our legal and regulatory
obligations;
non-affiliated companies may sometimes be
used to provide certain services such as
preparing and mailing reports, account
statements and other information, conducting
research on client satisfaction;
advertisers and advertising networks that
require the data to select and serve adverts
about our services to you and others. It will
only be passed to third party advertisers in
order to provide services on behalf of Roslyn
Schenk TA LaRose Dietitians.
data, service and software providers that
assist us in the improvement and
optimisation of our sites;
Where we share your data with third parties we
ensure that your data is held securely and in line with
applicable legislation.
How we store Personal Information
Safeguarding the privacy of your information is
important to us, whether you interact with us
personally, by phone, by mail, over the internet or
any other electronic medium.
We hold Personal Information in a combination of
secure computer storage facilities and paper-based
files and other records and take steps to protect the
Personal Information we hold from misuse, loss,
unauthorised access, modification or disclosure.
When we consider that Personal Information is no
longer needed, we will remove any details that will
identify you or we will securely destroy the records.
However, we may need to maintain records for a
significant period of time in line with our regulatory
obligations.
If we hold any Personal Information in the form of a
recorded communication, by telephone, electronic, in
person or otherwise in relation to our regulatory
obligations as detailed above, this information will be
held in line with local regulatory requirements which
can be obtained in the Documents Retention Policy.
Where you have opted out of receiving marketing
communication we will hold your details on our
suppression list so that we know you do not want to
receive these communications.
The Retention of Documents Policy contains further
information on this and is available on request.
Management and Safeguarding of Personal
Information
We always take appropriate technical and
organisational measures to ensure that your
information is secure. In particular, we train our
employees who handle Personal Information to
respect the confidentiality of customer information
and the privacy of individuals. We regard breaches of
your privacy very seriously and will impose
appropriate penalties, including dismissal where
necessary. We have appointed an Information Officer
to ensure that our management of Personal
Information is in accordance with this Privacy Notice,
applicable policies, and the applicable legislation.
The internet is an open medium and we cannot
guarantee that any information you send to us by
email or via our sites will not be intercepted or
tampered with; any transmission is at your own risk.
Once we have received your information, we will use
appropriate procedures and security features to
prevent unauthorised access.
Your rights as a data subject
The data protection laws give you certain rights in
relation to the data we hold on you. These are:
the right to be notified. This means that we
must tell you how we use your Personal
Information, and this is the purpose of this
Privacy Notice;
the right of access. You have the right to
access the Personal Information that we hold
on you. To do so, you should make a subject
access request;
the right for any inaccuracies to be
corrected. If any Personal Information that
we hold about you is incomplete or
inaccurate, you are able to require us to
correct it;
the right to have information deleted. If
you would like us to stop processing your
Personal Information, you have the right to
ask us to delete it from our systems where
you believe there is no reason for us to
continue processing it;
the right to restrict the processing of the
Personal Information. For example, if you
believe the Personal Information we hold is
incorrect, we will stop processing it (whilst
still holding it) until we have ensured that it is
correct;
the right to portability. You may transfer
the Personal Information that we hold on you
for your own purposes;
the right to object to the inclusion of any
information. You have the right to object to
the way we use your Personal Information
where we are using it for our legitimate
interests;
the right to regulate any automated
decision-making and profiling of Personal
Information. You have a right not to be
subject to automated decision making in way
that adversely affects your legal rights.
Where you have provided consent to our use of your
Personal Information, you also have the unrestricted
right to withdraw that consent at any time subject to
contractual obligations. Withdrawing your consent
means that we will stop processing the Personal
Information that you had previously given us consent
to use. There will be no consequences for
withdrawing your consent; however, in some cases,
we may continue to store and use the Personal
Information where so permitted by having a
legitimate reason for doing so or where required by
law, regulation or by any other competent authorities.
We may also not be able to continue our services to
you.
You can read more about these rights within section
5 of POPIA.
Transfers of Personal Information outside of
South Africa
Your data may be transferred to, stored at, and
processed at a destination outside of South Africa by
our service providers (eg. Google Workspace and
WhatsApp). By submitting your Personal Information,
you agree to this transfer, storing or processing.
We will take all steps reasonably necessary to
ensure that your data is treated securely and in
accordance with applicable legislation or other
relevant and appropriate laws.
Links to external websites
Our sites may, from time to time, contain links to and
from the websites of our partner networks,
advertisers and affiliates. If you follow a link to any of
these websites, please note that these websites have
their own privacy policies and that we do not accept
any responsibility or liability for these policies or how
such websites collect and use your data. Please
check these policies before you submit any Personal
Information to these websites.
Access to Personal Information about you
You have the right to request a copy of the Personal
Information we hold about you. If you would like a
copy of some or all of this information you may
contact us as follows:
Information officer contact details
Roslyn Schenk
larsoedietitians@gmail.com
083 408 8904
Roslyn Schenk TA LaRose’s head office
details
1 Flamingo Crescent, Bonza Bay, East London
larosedietitians@gmail.com
083 408 8904
If any of the information we hold is inaccurate, you
can ask us to make any necessary amendments.
Updates to the Privacy Notice
We reserve the right to update this Notice to reflect
any legal changes or changes to the way in which we
process your Personal Information. The updated
Notice will be delivered to you electronically to the
details we hold on file and/or published on our
website and it will come into effect at the time of
publication generally.
Contact Us
If you have any queries regarding privacy issues or
the content of this Privacy Notice, you can email us
on larosedietitians@gmail.com; alternatively, by
using the contact details provided above.
What if you have a complaint?
If you have a concern about any aspect of our
privacy practices, you can make a complaint. This
will be acted upon promptly. To make a complaint,
please contact us via one of the methods set above.
You undertake to first make a good faith attempt
to resolve same with the Practice. If you are not
first satisfied with our response to your complaint,
you have the right to then lodge a complaint with our
supervisory authority, the Information Regulator. You
can find details about how to do this on their website.