Privacy Policy

Client Data Privacy Agreement

If you are a client of Thrive Nutritional Therapy & Functional Medicine. We hold personal information about you in order to provide nutrition and wellbeing services.

Thrive Nutritional Therapy & Functional Medicine is a trading name of Therme RPC Limited, a company registered in England & Wales (Company No. 13051620).

This notice outlines how the information we hold is used, who we may share that information with, and how we keep it secure. This notice does not provide exhaustive detail. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to thrive-clinic@thermerpc.com. We keep our Client Data Privacy Notice under regular review. This Client Data Privacy Notice was last reviewed in January 2026.

What We Do

Thrive Nutritional Therapy & Functional Medicine provides nutrition-led wellbeing services to the public, including:

  • One-to-one nutritional therapy consultations with Registered Nutritionists and Registered Nutritional Therapists

  • Functional and advanced health testing with professional interpretation

  • Body composition analysis and wellbeing assessments

  • Personalised nutrition and lifestyle support

We do not provide medical diagnosis or medical treatment.

How We Obtain Your Personal Data

Information Provided by You

You provide us with personal data in the following ways:

  • Complete an intake or nutritional therapy questionnaire

  • Sign a Terms of Engagement or consent form

  • Attend a consultation (in person or online)

  • Communicate with us by email, telephone, or post

  • Make payments for services

This may include the following information:

  • Personal details (name, address, contact details and next of kin)

  • Appointment history and communications

  • Health and wellbeing information, including medical history, dietary and lifestyle information, supplement and medication use, test results, clinical notes, and wellbeing plans

  • GP or primary care contact details (where provided)

  • Payment and billing information

We use this information to provide you with direct nutritional therapy and wellbeing support.

The lawful basis for processing this data includes:

  • Legitimate interests (to provide care)

  • Contractual necessity (to deliver services you have requested)

  • Explicit consent (for special category health data)

 Information We Get from Other Sources

With your consent, we may receive information from:

  • Functional testing and laboratory providers

  • Other healthcare practitioners involved in your care

We may obtain sensitive medical information in the form of test results from biochemical testing companies. We use this information to provide you with direct healthcare. This means that the legal basis of our holding your personal data is for legitimate interest.

We may obtain sensitive information from other healthcare providers. The provision of this information is subject to you giving us your express consent. If we do not receive this consent from you, we will not be able to coordinate your healthcare with that provided by other providers which means the healthcare provided by us may be less effective.

How We Use Your Personal Data

We act as a data controller for use of your personal data to provide direct healthcare. We also act as a controller and processor with regards to the processing of your data from third parties such as testing companies and other healthcare providers. We act as a data controller and processor regarding the processing of credit card and online payments.

We undertake at all times to protect your personal data, including any health and contact details, in a manner which is consistent with our duty of professional confidence and the requirements of the UK General Data Protection Regulation (UK GDPR) concerning data protection. We will also take reasonable security measures to protect your personal data storage.

We may use your personal data where there is an overriding public interest in using the information e.g., to safeguard an individual, or to prevent a serious crime. Also, where there is a legal requirement such as a formal court order. We may use your data for marketing purposes such as newsletters, but this would be subject to you giving us your explicit consent.

Do You Share My Information with Other Organisations?

We will keep information about you confidential. We will only disclose your information with other third parties with your express consent with the exception of the following categories of third parties:

  • The Association for Nutrition (AfN), BANT, and the Complementary and Natural Healthcare Council (CNHC) for professional registration, regulation, or complaint handling

  • Service providers acting on our behalf (e.g. Practice Better), who are contractually bound to confidentiality and data protection

  • Functional testing laboratories and supplement providers, where relevant to your care (no unnecessary data shared)

  • Legal or regulatory authorities where required by law

We may share your information with supplement companies and biochemical testing companies as part of providing you with direct healthcare. We will not include any sensitive information. 

We will seek your express consent before sharing your information with your GP or other healthcare providers. However, if we believe that your life is in danger then we may pass your information onto an appropriate authority (such as the police, social services in the case of a child or vulnerable adult, or GP in case of self-harm) using the legal basis of vital interests.

 We may share your case history in an anonymised form with our peers for the purpose of professional development. This may be at clinical supervision meetings, conferences, online forums, and through publishing in medical journals, trade magazines or online professional sites. We will seek your explicit consent before processing your data in this way.

What Are Your Rights?

Every individual has the right to see, amend, delete or have a copy, of data held that can identify you, with some exceptions. You do not need to give a reason to see your data.

If you want to access your data you must make a subject access request in writing to thrive-clinic@thermerpc.com. Under special circumstances, some information may be withheld.

We shall respond within 30 working days from the point of receiving the request and all necessary information from you. Our response will include the details of the personal data we hold regarding you, including:

  • Sources from which we acquired the information

  • The purposes of processing the information

  • Persons or entities with whom we are sharing the information

 You have the right, subject to exemptions, to ask to:

  • Have your information deleted

  • Have your information corrected or updated where it is no longer accurate

  • Ask us to stop processing information about you where we are not required to do so by law or in accordance with the AfN, BANT and CNHC guidelines

  • Receive a copy of your personal data, which you have provided to us, in a structured, commonly used, and machine-readable format and have the right to transmit that data to another controller, without hindrance from us

  • Object at any time to the processing of personal data concerning you

We do not carry out any automated processing, which may lead to automated decision based on your personal data.

 If you would like to invoke any of the above rights then please write to the Data Controller at Tithe Barn, Church Road, Thame, Oxfordshire, OX9 3AJ or email thrive-clinic@thermerpc.com

What Safeguards Are in Place to Ensure Data that Identifies Me is Secure?

We only use information that may identify you in accordance with UK GDPR. This requires us to process personal data only if there is a legitimate basis for doing so and that any processing must be fair and lawful.

Within the health sector, we also have to follow the common law duty of confidence, which means that where identifiable information about you has been given in confidence, it should be treated as confidential and only shared for the purpose of providing direct healthcare. We will protect your information, inform you of how your information will be used, and allow you to decide if and how your information can be shared.

We also ensure the information we hold is kept in secure locations, restrict access to information to authorised personnel only, protect personal and confidential information held on equipment such as laptops with encryption (which masks data so that unauthorised users cannot see or make sense of it). We ensure external data processors that support us are legally and contractually bound to operate and prove security arrangements are in place where data that could or does identify a person are processed.

Therme RPC Limited, which Thrive Nutritional Therapy & Functional Medicine is operated by, is registered with the Information Commissioner’s Office (ICO) as a data controller and collects data for a variety of purposes. A copy of the registration is available through the ICO website (search by business name).

 How Long Do You Hold Confidential Information For?

All records held by Thrive Nutritional Therapy & Functional Medicine will be kept for the duration specified by guidance from our professional associations.

Website Technical Details

We do use electronic forms on our website making use of an available ‘forms module’ which has a number of built-in features to help ensure privacy. We also aim to use secure forms where appropriate.

Cookies are small. We do not make use of cookies to collect any private or personally identifiable information. The technical platform of this website uses cookies solely to aid the proper technical functioning of the website. The cookies used contain random strings of characters alongside minimal information about the state and session of the website – which in no way collects or discloses any personal information about you as a visitor.

Advanced areas of this site may use cookies to store your presentation preferences in a purely technical fashion with no individually identifiable information. Note also our statement on analytics software below – as analytics software also uses cookies to function.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout


Analytics

Like most websites, we make use of analytics software in order to help us understand the trends in popularity of our website and of different sections. We make no use of personally identifiable information in any of the statistical reports we use from this package. We use an analytics package called Google Analytics who provide details of their privacy policy on the Google website.

Complaints

If you have a complaint regarding the use of your personal data then please contact us by writing to the Data Controller at Tithe Barn, Church Road, Thame, Oxfordshire, OX9 3AJ or emailing thrive-clinic@thermerpc.com and we will do our best to help you.

 If your complaint is not resolved to your satisfaction and you wish to make a formal complaint to the Information Commissioner’s Office (ICO), you can contact them on 01625 545745 or 0303 1231113.