PRIVACY POLICY
In May 2018, new Europe-wide guidelines come into place regarding how your Data is acquired, stored, retrieved and accessed. These new guidelines give the Data Owner (you) more control over what information is kept.
This document sets out what and how Rising Lotus Therapies /Sara-mae, a sole trader registered as self employed handles the Data it collects from all sessions, whether it is a private sessions, group classes workshops and training course participants, and to reassure you of GDPR compliance.
The General Data Protection Regulation (GDPR) is concerned with the personal information that we collect about you and/or your child. This document is our GDPR policy. This policy is about our clients who are children as well as our clients who are adults. Where we say “you” and your child is receiving a service from us, we are referring to your child.
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This policy will be available for you to read online and a paper copy will be available to read whenever you are asked to provide your personal information ie when joining a yoga class, joining a mailing list, attending a workshop or accessing any of our other services which may change from time to time. This policy is currently only available in written English format. If you require any other type of format please let us know and we will do our best to help you to access this information.
Although it is not compulsory to provide the information requested, if you choose not to, we may not be able to provide you with the services that we offer for your own safety and the safety of others.
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How we collect your personal information
You provide your personal information during interactions with us. These are the occasions we have to collect your personal information:
1. joining a class / individual therapy service / mentoring services / course / workshop / retreat and filling in a registration form or providing verbal information about your health status and any changes,
2. registration form / intake form/ health form / email enquiry / web enquiry/ phone call about one to one services
3. signing up to the mailing list either via the form at www.peacewithinyoga.co.uk or by requesting to join via email, in person or on a written sign-up sheet where you have written your details
4. when you provide a review in writing either on paper or electronically via email, facebook, what's app, instagram, twitter, youtube, survey monkey
5. if you are a yoga teacher who is covering a class on behalf of Rising Lotus Therapies
1. The type of information we collect
We only collect the information we consider relevant to carry out our business, keep you informed or services you may be interested in and provide the services you have requested in a safe, appropriate and professional manner. There are occasions where you may choose not to provide us with certain information which may mean we are unable to provide you with a service. For example we cannot teach you in a yoga class if you do not tell us about your health. We cannot accept you as a therapy client if you do not provide details of your GP as this is a safeguarding issue and is there for your protection and the safety of others.
The type of information we collect depends on the reason and context for our interaction.
Information You Have Shared:
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Information about your life as part of an initial informal enquiry/registration and or assessment process for therapeutic services.
Medical History, confidentiality & consent processes
If you have scheduled to have a chat about my services, completed an enquiry form, subscribed to Rising Lotus Therapies newsletter or applied to participate in an educational program you will have shared your contact details & in some cases your profession & your areas of interest.
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i) Paper/electronic
When you first attend a session, be it a group setting, a private session, a corporate session or a workshop, you will fill in a Intake form/registration form, health and well being form/ email or web enquiry form, which details any important medical details, your contact details and the expectations you have from the classes.
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ii) Electronic Data
Your email address and name is collected from the enquiry forms form for email marketing purposes by Sara-mae. You have an option to opt out of marketing at any time.
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Information Rising Lotus Therapies may generate:
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A record of therapeutic sessions with dates, brief information on what was covered, concerns about risk & any tools offered
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Working audio notes to facilitate my thinking (anonymised)
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Communications to other health professionals
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A shared (with you & anyone else you choose) Google Drive folder of any notes/images used during therapeutic sessions
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Supervision & Peer Reflection Notes (anonymised)
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Invoices & payment plans
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Information generated in a clinical setting:
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Personal information such as your name, gender, date of birth, relationships, parents, siblings, children, occupation, address, telephone numbers, email addresses, therapeutic history, medical conditions, medication history, employment, education and social life details
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We also collect sensitive information such as physical and mental health details, sexual life, racial or ethnic origin, religious or other beliefs, convicted offences, and alleged offences.
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Ongoing contact with you is also recorded. For example, we make a short record of the content of each appointment we have with you; and we also record all email exchanges and telephone calls we have with you. If another professional contacts us we will also record what they tell us.
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Sometimes for the purpose of assessment, clinical supervision, and for ongoing professional development, video recordings may be taken of sessions. Your therapist will always discuss this with you first and request your consent to do so. You will be asked to complete a video consent form prior to recordings being made. Videos will be stored on a secure server.
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Referrals: sometimes a referral organisation may share previous medical/mental health assessments/care plans (such as an EHCP), consent to provide this information to Rising Lotus Therapies, will be obtained by the referrer prior to being shared.
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We only share this information in the case of a serious concern relating to your welfare or someone else's welfare or if required to by law. We will always attempt to inform you of this first and only to share the information with those people or organisations deemed essential eg your doctor.
2. Details shared with third parties
We do not share your details with any other parties than those directly involved in providing and supporting our services.
Third parties who we currently share your data with are:
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Mailchimp which is an online service which holds our mailing list and provides templates to send emails.
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HMRC receives statistical information about payments and other financial interactions we have.
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Clinical supervisors or peer supervision groups may discuss you anonymously in order to provide the best possible care for you and others who may learn from your case.
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Rising Lotus Therapies will never share, sell, rent or trade your personal information to any third parties for marketing purposes without your prior consent.
Information will only be shared when legally required or when your or someone else's life may be at risk or in the case of children or vulnerable adults being at risk of harm.
Information may be collected from you verbally, manually on a written form in person or by post, via a webform, through social media or via email.
Verbal information may be recorded on paper.
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3. How we handle your information
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All paper records are stored at the business premises of Sara-mae Higgs under the guidelines of the National Occupational Standards guidelines. This means your records are stored in a locked filing cabinet. If the records are needed outside of this property, they are transported in a case with a combination lock. Transportation of documents is kept to a minimum i.e., only when they are needed for an appointment or for a clinical supervision session. Records are required to be kept for 7 years after which point, they will be securely and confidentially disposed of.
Occasionally you may be asked for permission to record one of our sessions for my professional development. You have the right to refuse. If you agree, this will be stored on a a voice memo and stored within your electronic encrypted folder, any copies will be deleted from the recording device and the recording will be deleted as soon as it has served its purpose. Until then it will be stored in the locked box with your files.
Despite all our precautions no data transmission over the internet is 100% secure so we cannot guarantee the security of information you disclose to us and wish to draw your attention to the fact that you do this at your own risk when corresponding by email. There is always the alternative to provide this information via telephone or for registration forms and other longer pieces of information you can post these to us.
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4. Can you use my data for other purposes?
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We will only use your personal data for the purposes we have collected it for. If we did need to use your data for another reason, we will get in touch and explain the basis for us doing so and seek your consent. We never use your personal details for marketing purposes.
5. How may my data be shared?
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We share the necessary aspects of your data as follows:
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During in-house clinical discussions to support the quality of the work your therapist is offering.
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During clinical supervision between your therapist and their supervisor, which they are obliged to have in accordance with their professional standards.
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Outside agencies, such as NHS mental health teams, your child’s school, Children’s Services and your GP. You will be asked for explicit signed consent to share data with outside agencies, unless there are safeguarding concerns which override this. It is important for you to know that all of the above agencies and individuals are also bound by GDPR rules, and we have specifically asked for evidence of their privacy policy.
6. How is my data kept?
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Your data is kept on a secure server, accessible by all Rising Lotus Therapies staff. Individual devices (e.g. laptops, computers, ipads) are all password protected. If paper data needs to be stored, it is kept in a locked cabinet within Rising Lotus Therapies Clinic, which is in a secured building.
Rising Lotus Therapies makes use of Google Suite and iCloud services. These services are password protected & encrypted. You can read about how Google protects data stored on its cloud services here and how iCloud protects its stored data here.
Mobile phone numbers for clients are held locally on Sara-mae’s Business mobile phone. No other identifying information is held locally on any of her mobile devices or external hard drives.
Although the Rising Lotus Therapies website uses SSL protection. I cannot guarantee that the data will be 100% secure when it is transmitted. As a result I cannot guarantee the security of any information you transmit to me through enquiry forms, registration forms, or email enquiries, and you do so at your own risk. Once I receive your information, I make every effort to ensure its security on my own systems - see the section above.
7. How long will you keep my data for?
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For children (aged 15 and under); we will hold data until they are 26 years old.
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For individuals (aged 16 and above); we will hold data for seven years after the closure of our service to you.
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What if I make an enquiry or send a referral, but don’t end up working with your service?
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If you get in touch with us with an initial enquiry and share personal information; we will record this information and store it for 16 weeks. If we have not heard back from you after 16 weeks, your personal information will be destroyed. If you confirm that you do not want to pursue a service with us within those 16 weeks, we will destroy the information we hold about you immediately.
8. Your rights
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To be informed of what information we hold about you (this Privacy Notice).
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To see the information we hold about you (free of charge for the initial request).
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To correct any inaccurate information or incomplete personal information (we may ask for verification of this information)
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To request your personal information is erased/deleted/shredded. This request may be declined if the information is needed for us to practice lawfully and competently, or if there is an adverse reason (such as a complaint, safeguarding concerns or a legal reason).
9. Who should I contact if I have a question about my data?
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Our Data Protection Officer is Sara-mae Higgs (previously known as Martin), who is the owner and founder of Rising Lotus Therapies.
Sara-mae is available for questions by contacting her on:
07583709399
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Rising Lotus Therapies and Sara-mae may interact with you through USA organisations such as Facebook, Google, Twitter or Instagram. The USA has different, weaker data protection laws than that of the EU. You can view how they handle your data by visiting these pages below:
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Facebook privacy policy
https://www.facebook.com/full_data_use_policy
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Google privacy policy
https://policies.google.com/privacy/update
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Instagram privacy policy
https://help.instagram.com/519522125107875?helpref=page_content
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10. What should I do if I’m not happy with the data protection procedures?
In the first instance, we would encourage you to contact our Data Protection Officer as above. Alternatively, you have a right to make a complaint at any time to the Information Commissioner’s Office (ICO) (www.ico.org.uk).
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This privacy information was updated in November 2020 and again in May 2024. Further updates may follow.