Privacy Policy
This Privacy Policy provides you with the details of how I, Lois Dabrowski, collect and process your personal data.
By providing your data, you warrant that you are over 13 years of age, Lois Dabrowski is the Data Controller and responsible for your personal data. I am registered with the Information Commissioner’s Office (ICO) (Reference ZA337572).
Contact details
Full name of legal entity: Lois Dabrowski trading as Limen Therapy
Email address: lois@limen-therapy.co.uk
Postal address: Suite 420, Martinique House, Hampshire Road, Bordon, GU35 0HJ
It is very important that the information I hold about you is accurate and up to date. Please let me know if at any time your personal information changes by emailing me at lois@limen-therapy.co.uk.
What data do I collect about you, for what purpose and on what grounds do I process it?
The lawful bases on which I keep client data is that of:
Your consent. You are able to remove your consent at any time. You can do this by contacting: lois@limen-therapy.co.uk
I have a contractual obligation.
I have a legal obligation.
I have a legitimate interest. This means the data that is necessary for me to fulfil the contract that we have together (i.e. to provide therapy) and is data that you would reasonably expect me to hold and use.
For those enquiring about therapy, the data I hold includes any information you have sent to me by email/text/message or from completing the web form on my website (www.limen-therapy.co.uk).
For those who book and attend at least one session, the data I hold includes:
Personal information data such as your first and last names, email address, telephone number, address.
Information that you give me as part of the work we do together.
Records of the interventions that I use (or considered and not used) in our sessions.
Emails, texts and/or messages that are sent between us.
Information sent from any third party, e.g. GP, occupational health provider.
Some of the information that you give me may fall under the definition of special category of data as defined by the General Data Protection Regulation (GDPR). The condition for processing this special data is “processing is necessary for medical diagnosis, the provision of health care or treatment pursuant to contract with a health professional”.
Data is not shared with anyone, except possibly your GP, and for any reasons covered by the Requirements for Disclosure which are detailed and discussed when we first meet.
The data is primarily used to enable me to provide therapy to you. It may also be used for scientific research purposes and statistical purposes.
Details of where data is held:
Any emails sent between us are held on my biometrically-secured computer, mobile devices and managed by Microsoft Outlook.
Any other messages sent between us (See Social Media Policy) are managed by the provider’s storage policies and can only be accessed by me due to biometric security on my mobile devices and computer.
Any digital documents are held on a biometrically-secured and encrypted local drive.
Session notes are handwritten and kept in a locked filing cabinet. I use a confidential coding system to identify which notes belong to which client, meaning that anyone accessing the notes without authorisation would be unable to determine the client's identity.
Payment is via BACs. My bank statements will show the details of your payment.
Your data as a client is retained for 7 years. The length of time is based on the stipulation of my insurer (Balens Insurance). After this time any paper records are shredded and computer records permanently deleted.
Limen Therapy takes the security of data seriously and as such:
All data is held securely (see details of where data is held above).
However:
I am not in control of data (including emails and texts) which you send me.
Apps such as Instagram routinely access any information held and this is beyond my control.
What happens in the event of a data breach?
If there is any breach of data security, Limen Therapy will give full details to the Information Commissioner’s Office (ICO) and any person affected within 72 hours of the breach and do all that is possible to minimise any potential impact.
Your rights
You have rights under data protection laws in relation to your personal data held:
The right of access. I will provide you with all data I hold on you as soon as I can following a Subject Access Request (and definitely within 30 days, unless this is impossible due to holidays or illness).
The right to rectification. If any data I hold is incorrect, let me know and I will correct it as soon as I can (and definitely within 30 days, unless this is impossible due to holidays or illness).
The right to object.
The right to erasure. If you wish me to erase your data just let me know and I will delete any computer records and shred any paper records as soon as I can after this request (and within 30 days, unless this is impossible due to holidays or illness). NB: data may be retained for scientific research, historical research or statistical purposes where erasure is likely to render impossible or seriously impair the achievement of that processing but this would never include case notes or data such as address/email/phone.
The right to restrict processing. This would usually be a stop-gap measure before correction of any errors or before erasure.
The right to data portability. This might apply if you want your notes sent to another therapist for example, but it is likely that the easiest solution would come under the right to access, i.e. I would send the data to you.
The right not to be subject to automated processing. I do not engage in this.
Cookie policy
Like many websites, this website uses cookies. A cookie is a small amount of data that is sent to your computer or mobile phone browser from a website’s computer and is stored on your device’s hard drive.
You can disable cookies in your browser.
I will ask for your permission to place cookies on your device, except where they are essential for me to provide you with the service that you have requested.
You can withdraw your consent at any time. See your browser settings to change what types of cookies you accept.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. I do not control these third-party websites and therefore am not responsible for their privacy statements.
I may use the following cookies:
Strictly necessary cookies. These cookies are essential to allow you to use the website effectively and cannot be turned off. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the Internet.
Performance/analytical cookies. These cookies allow me to recognise and count the number of visitors and to see how visitors move around my site; this helps me to improve how my site works, for example, by ensuring that users can find what they are looking for easily.
Functionality cookies. These cookies recognise you when you return to my site; this allows me to personalise my content for you, greet you by name, and remember your preferences, for example, your region or choice of language.
Targeting cookies. These cookies record your visit to my site, the pages you have visited, and the links you have followed. I use this information to make my site and its advertising more relevant to your interests.
I use Google Analytics to understand how visitors engage with my websites. It collects information anonymously and reports website trends without identifying individual visitors. For more information, visit Google Analytics’ privacy and security information.
Contact
If you have questions about this Policy, please email me (lois@limen-therapy.co.uk).