Introduction and Purpose of Privacy Policy
Lancara Ltd. is registered in England and Wales, Company Number 10854077, registered office: 181 Graham Road, Hackney, London, E8 1PD.
This privacy policy explains how Lancara Ltd uses and protects any personal information collected by us when you use this website or during the course of our work.
To provide our services, Lancara Ltd needs to collect and utilize specific types of information about individuals. Data may be gathered through various means, including paper forms, email communications, and Google Drive.
Lancara Ltd (and BBW) is dedicated to safeguarding your privacy. Any information that can identify a client or customer will be handled in strict accordance with this policy.
Personal data will never be sold, distributed, or leased to third parties.
In the rare event that sharing information with a private third party becomes necessary, we will seek the express permission of the data subject, unless legal obligations dictate otherwise (see below).
This policy is effective from the date specified on this page and will be updated as necessary to comply with privacy and data protection legislation.
There are two components of privacy addressed in this policy:
Website Privacy
Confidentiality and Data Protection Policy for Clients
Each are detailed below.
Lancara Ltd serves as the Data Controller under GDPR. This means we are responsible for determining the purposes for which personal information is collected and used, and we are committed to complying with GDPR requirements.ConsentBy engaging with our services and providing personal information, you consent to the collection and processing of your data as described in this policy.
By providing personal data (e.g., through forms), clients are giving consent. You have the right to withdraw your consent at any time, as detailed in the section below on Consent.
Lancara Ltd adheres to the EU’s General Data protection Regulation (GDPR) 7 Principles of Data Protection:
Lawfulness, fairness and transparency
Purpose limitation
Data minimisation
Accuracy
Storage limitation
Integrity and confidentiality (security)
Accountability
Full details may be found here on the ICO’s website: A guide to the data protection principles | ICO.
The following policies below detail how Lancara Ltd will ensure these Rights can be exercised under GDPR.
1. Introduction
Lancara Ltd. is committed to data privacy for visitors to our site, www.gemmakeaney.com and www.gemmakeaney.co.uk, noting any non-personal data collected.
This Website Privacy Policy outlines how Lancara Ltd. ("we," "our," or "us") collects, uses, and protects any information provided by users ("you") while visiting our website, www.gemmakeaney.com and www.gemmakeaney.co.uk. By accessing or using our website, you agree to this Privacy Policy.
2. Data Collection and Usage
We may collect both non-personal and personal information from users visiting our website, including:
Contact Information:
If you voluntarily submit information through our contact form, we may collect your name, email address, and any other details you provide. This information is used to respond to your inquiries.
Analytics and Usage Data:
We may automatically collect certain non-personal information to understand how our website is used. This includes your IP address, browser type, pages visited, and other diagnostic data. This helps us improve our website and tailor the user experience.
Third-Party Links:
The Site also includes links to other websites and provides access to products and services offered by third parties, whose privacy policies we do not control. When you access another website or purchase third-party products or services through the Site, use of any information you provide is governed by the privacy policy of the operator of the site you are visiting or the provider of such products or services. We encourage you to review the privacy policies of any third-party websites you visit.
3. Legal Basis for Processing
We process your information on the following legal bases:
Consent:
By using our website or filling out a contact form, you consent to the collection and use of your information as outlined in this policy.
Legitimate Interest:
Analytics and usage data are collected to help us analyse website performance and improve user experience.
4. Data Sharing and Security
We are committed to protecting your data. We may share data with third-party providers solely for the purposes of website hosting and analytics. This may include:
Analytics Providers:
We use Google Analytics to help us understand website usage patterns. For details on how this data is collected, please see How Google uses information from sites or apps that use our services – Privacy & Terms – Google.
Hosting Providers:
Our website is hosted on secure servers provided by Namecheap Inc. And their privacy policy can be found here Namecheap.com - Legal - Privacy Policy. Additionally online course material (for clients signed up for online training) (GrooveMember) is hosted on secure servers provided by Groove Digital LLC. Their Privacy Policy can be found here: https://groovedigital.com/privacy
We implement a range of security measures, including encryption, to protect your personal information against unauthorised access.
5. Cookies
Our website uses cookies to enhance user experience and collect anonymous usage data:
Necessary Cookies:
These are essential for website functionality.
Analytics Cookies:
These help us track user interactions to improve the website.
You can manage or disable cookies through your browser settings or through our cookie management tool, which is accessible on our website.
6. User Rights
As a user of our website, you have the following rights:
Right to Access: You can request information on any personal data we hold about you.
Right to Rectification: If any data is inaccurate, you may request that we correct it.
Right to Erasure: You may request the deletion of any personal data we hold, subject to certain legal obligations.
Right to Restrict Processing: In certain cases, you may request that we limit the use of your personal data.To exercise these rights, please contact us using the information provided below.
7. Contact Information
If you have questions about this Privacy Policy or wish to exercise any of your rights, please contact us at:
Email: [email protected] (at Lancara Ltd.)
8. Changes to This Policy
We reserve the right to review and update this policy as necessary to reflect changes to our practices or for legal reasons. Any changes will be posted on this page, and we encourage you to review our Privacy Policy periodically.
This policy was last updated on 31 October 2024.
Confidentiality and Data Protection Policy for Clients
Lancara Ltd. has a duty of confidentiality and compliance with GDPR, and insurance obligations and abides by the Complimentary Therapists Association (CThA) Code of Practice (www.ctha.com).
1. Introduction
This Confidentiality and Data Protection Policy for Clients explains how Lancara Ltd ("we," "our," or "us") collects, uses, stores, and protects personal information in the course of providing therapeutic services. We are committed to maintaining the confidentiality and security of our clients’ personal information in compliance with GDPR and other applicable data protection regulations.
2. Data Collection and Purpose
In order to provide safe and effective therapeutic services, we collect personal and sensitive information. By submitting your information, you agree to its use as specified in this policy.
If at any point you wish to withdraw consent, you may do so by contacting us, using the email below, and we will ensure your data is no longer processed for purposes that depend on consent.The types of information we collect may include, but are not limited to:
Personal Identification Information:
such as name, address, phone number, email, and date of birth.
Health and Medical Information: including doctor’s name, medications, diagnoses, and relevant medical history.
Personal History and Background: trauma history, relationships, family dynamics, and other sensitive personal details shared in the course of our work.
Assessment Data: data gathered through forms and questionnaires completed via Google Docs, PDF forms and in-person (or online).
Session Notes: hand-written notes taken during client sessions.
The purpose of collecting this information is to deliver high-quality therapy tailored to individual needs, assess therapeutic progress, and meet insurance and legal obligations.
Third-Party Links
Note also that in the course of our work I may send to you links or you may access them from the online training course (GrooveMember) to other websites which provide access to products and services offered by third parties, whose privacy policies we do not control. When you access another website or purchase third-party products or services through the Site, use of any information you provide is governed by the privacy policy of the operator of the site you are visiting or the provider of such products or services.
3. Legal Basis for Processing
We collect and process personal data on the following legal bases:
Performance of a Contract:
Personal data is required to provide services as agreed upon with each client, specifically to inform the Practitioner (Gemma Keaney, Lancara Ltd) of the most effective way to support the client(s).
Legitimate Interest:
Processing information to maintain accurate records for therapy and uphold our professional duty of care.
Legal Obligation:
We retain client records for 7 years to meet insurance and professional regulatory requirements.
4. Data Retention and Security
We are committed to ensuring that client data remains confidential and secure:
Retention:
We retain client records for a minimum of 7 years after the end of therapy, as required by insurance policies and professional regulations. After this period, data will be securely disposed of.
Security Measures:
Digital records, such as assessment data collected via Google Docs, are stored in a secure, password-protected account. Handwritten notes are stored in locked files with restricted access. We implement encryption and secure storage practices to prevent unauthorised access.
5. Data Sharing and Confidentiality
Client information is treated with the utmost confidentiality and is only shared under specific conditions:
Insurance or Legal Requirements:
Information may be shared if required by law or insurance policies:
1. Where information was shared that alerted me to a risk of serious harm to the client or someone else, especially a child, Lancara Ltd reserves the right to break confidentiality in order to prevent harm. I would do this only in extreme circumstances and would always try and discuss it with the client first before taking any action.
2. If required by a court of law to give evidence (e.g. in criminal proceedings).
3. If I received any information relating to an act of terrorism.
4. Professional Consultation: If necessary, non-identifiable information may be shared with colleagues for supervision or consultation purposes to enhance therapeutic care. To improve the quality of my work I (Gemma Keaney) have regular supervision where client sessions are discussed. This is standard practice and is done anonymously. Client identity will not be disclosed to my supervisor.
We will never share identifiable client information with third parties for marketing purposes.
6. Client Rights Under GDPR
As a client, you have the following rights regarding your personal data:
Right to be Informed: You have the right to know how your data is collected, used, and stored.
Right of Access: You can request a copy of any personal data we hold about you.
Right to Rectification: You may request corrections if any personal data is inaccurate or incomplete.
Right to Erasure: After the legally required retention period (5 years), you may request deletion of your data.
Right to Restrict Processing: You may request that we limit the use of your data in certain circumstances.
Right to Data Portability: You may request a transfer of your data to another provider in a structured format.
Right to Object: You may object to the processing of your data based on legitimate interests or other grounds.
Rights Related to Automated Decision-Making and Profiling: This applies if automated processing affects you, though we do not use this type of processing in our practice.
Right to Withdraw Consent - see details below.
You have the right to withdraw your consent for us to process your personal information at any time. If you decide to do this, please follow these simple steps:
Contact Us: Send us an email at [email protected] or use the contact form on our website.
Specify Your Request: In your message, let us know that you wish to withdraw your consent and mention which specific information you want us to stop processing.
Confirmation: We will acknowledge your request and confirm that your data will no longer be processed for purposes based on your consent, unless we are legally required to retain it.
Once consent is withdrawn, we will stop processing your data for purposes based on consent, except where legally required otherwise.
7. Contact Information
If you have any questions regarding this policy or your rights, please contact us at:
Email: [email protected] (at Lancara Ltd.)
8. Changes to This Policy
We may update this policy periodically to reflect changes in our practices or legal obligations. Any changes will be posted on our website, and we encourage you to review our Privacy Policy from time to time.
This policy was last updated o 31 October 2024.
© Gemma Keaney 2021
Lancara Ltd. Registered in England Number 10854077