Your Privacy Policy should set out the information you will be collecting from visitors to your website as well as people who purchase your online courses or books in relation to nutrition.
Personal Information
As part of your service it is expected that you will require participants in your courses to disclose detailed personal information including their contact details, weight, height, goals and achievements. You may also be collecting information from your website visitor’s activities including data from cookies, google analytics and other information which you may use to assess how people use your website.
Your website’s Privacy Policy should set out a list of all of the types of information you will be collecting. You should also address how you will be using the information. Common examples of when your business will use this information is for website development, improving services or tailoring advertising. You will also be using their information when you have collected their contact details for the purpose of direct marketing.
You may also be required to store certain information and materials for a period of time after the customer has terminated the services. This should also be set out in the Privacy Policy. Your visitors may also want to edit or remove personal information from your website. You should set out if and how this is possible and state that copies may be kept for back up purposes even after the content is deleted off the website.
If you send direct marketing emails to your clients, you should set out how they can unsubscribe or limit this communication via your website. This should generally alert the client to the fact that they can end their subscription by hitting an unsubscribe button or by emailing you.
Sensitive Information
You should set out the sensitive information that you will be collecting from your customers as this has a separate set of protections under the Privacy Act 1988 (Cth). You will likely be collecting health information which could be considered sensitive, including details in relation to injuries and ailments. You may also be collecting information about people’s philosophical or religious beliefs in relation to their eating and dietary requirements.
In relation to both personal and sensitive information there are some circumstances where you are required to disclose the information by law. This should be covered in your Privacy Policy so that your visitors and customers understand that their personal information may be disclosed for this purpose.
Third Party Disclosure
You should set out when and how any personal information will be shared with third parties and how personal data is stored. For example you should set out whether your data is stored in Australia or overseas. You should also set out the third party products or applications you use and disclose personal information to. This could include marketing tools, advertising tools, payment portals and other third party sites. You should set out the security measures you have in place to protect personal and sensitive information but should state that beyond the standard security measures you cannot guarantee the safety of the data. Customers and visitors should ensure that they also back up their own personal information as required.
Conclusion
If you’re unsure how to go about drafting your Privacy Policy as a nutritionist you should speak with a qualified, experienced business lawyer, preferably one with experience drafting Privacy Policies. At LegalVision, we draft these Privacy Policies on a regular basis, so if you’re in need of legal advice, contact us on 1300 544 755 and speak with one of our business solicitors.
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