Privacy Policy
Luna Path Therapy Privacy Policy
This privacy notice tells you what to expect Luna Path to do with your personal information.
· Contact details
· What information Luna Path collects, uses, and why
· Lawful bases and data protection rights
· Where Luna Path gets personal information from
· How long Luna Path keeps information
· Who Luna Path shares information with
· How to complain
Contact details
Email info@lunapaththerapy.com
What information Luna Path collects, uses, and why
Luna Path collects or usse the following information for safeguarding or public protection reasons:
· Name, address and contact details
· Emergency contact details
· Health information (including medical conditions, allergies and medical requirements)
· Information about care needs (including disabilities, home conditions, dietary requirements and general care provisions)
· Records of meetings and decisions
Luna Path also collects the following special category information for safeguarding or public protection reasons. This information is subject to additional protection due to its sensitive nature:
· Health information
Luna Path collects or uses the following personal information to comply with legal requirements:
· Name
· Contact information
· Health and safety information
· Any other personal information required to comply with legal obligations
· Safeguarding information
Luna Path also collects the following special category information to comply with legal requirements. This information is subject to additional protection due to its sensitive nature:
· Health information
Luna Path collects or uses the following personal information for dealing with queries, complaints or claims:
· Names and contact details
· Addresses
· Information relating to health and safety (including incident investigation details and reports and accident book records)
· Correspondence
Lawful bases and data protection rights
Under UK data protection law, Luna Path must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis Luna Path relies on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
· Your right of access: You have the right to ask Luna Path for copies of your personal information. You can request other information such as details about where Luna Path gets personal information from and who Luna Path shares personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
· Your right to rectification: You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
· Your right to erasure: You have the right to ask Luna Path to delete your personal information. Read more about the right to erasure.
· Your right to restriction of processing: You have the right to ask Luna Path to limit how Luna Path can use your personal information. Read more about the right to restriction of processing.
· Your right to object to processing: You have the right to object to the processing of your personal data. Read more about the right to object to processing.
· Your right to data portability: You have the right to ask that Luna Path transfers the personal information you gave Luna Path to another organisation, or to you. Read more about the right to data portability.
· Your right to withdraw consent: When Luna Path uses consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.
If you make a request, Luna Path must respond to you without undue delay and in any event within 25 working days.
To make a data protection rights request, please contact Luna Path using the contact details at the top of this privacy notice.
Luna Path's lawful bases for the collection and use of your data
Luna Path's lawful bases for collecting or using personal information for safeguarding or public protection reasons are:
· Consent: Luna Path has permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Legal obligation: Luna Path have to collect or use your information so Luna Path can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
· Legitimate interests: Luna Path collects or uses your information because it benefits you, the organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Luna Path may collect or use personal information where it is necessary for safeguarding or public protection purposes. This includes situations where there is a concern about serious risk of harm to you or to others, or where sharing relevant information is necessary to protect life, prevent serious harm, or support safeguarding processes. In these circumstances, information will only be used or shared where it is proportionate, relevant, and in line with professional ethical standards and legal requirements, and where it does not override your rights and interests.
For more information on Luna Path's use of legitimate interests as a lawful basis you can contact Luna Path using the contact details set out above.
· Vital interests: collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter.
All of your data protection rights may apply, except the right to object and the right to portability.
Luna Path's lawful bases for collecting or using personal information to comply with legal requirements are:
· Consent: Luna Path has permission from you after giving you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Legal obligation: Luna Path has to collect or use your information to comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
· Legitimate interests: Luna Path collects or uses your information because it benefits you, the organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Luna Path may collect or use personal information where it is necessary to comply with legal obligations. This includes maintaining accurate records for tax purposes, fulfilling reporting requirements under safeguarding legislation, or meeting any other legal or regulatory duties that apply to my counselling practice. Information will only be used for these purposes, handled securely, and kept only for as long as required by law or professional guidelines.
For more information on Luna Path's use of legitimate interests as a lawful basis you can contact Luna Path using the contact details set out above.
· Vital interests: collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.
Luna Path's lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
· Consent: Luna Path have permission from you after giving you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Legal obligation: Luna Path have to collect or use your information to comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
· Legitimate interests: Luna Path collects or uses your information because it benefits you, the organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Luna Path may collect or use personal information where it is necessary to respond to enquiries, resolve complaints, and / or manage claims relating to Luna Path's counselling services. This helps ensure concerns are addressed fairly and efficiently, allows Luna Path to investigate and improve services, and ensures that any issues are resolved appropriately. Information used for these purposes will be kept secure, handled confidentially, and only retained for as long as necessary to resolve the matter.
For more information on Luna Path's use of legitimate interests as a lawful basis you can contact Luna Path using the contact details set out above.
· Vital interests: collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter.
All of your data protection rights may apply, except the right to object and the right to portability.
Where Luna Path gets personal information from
· Directly from you
· Regulatory authorities
· Family members or carers
· Other health and care providers
· Social services
· Charities or voluntary sector organisations
· Schools, colleges, universities or other education organisations
· Relevant regulatory authorities
· Third parties:
Luna Path may collect personal information directly from you when you contact Luna Path, book a session, complete forms, or during counselling sessions. In some cases, Luna Path may also receive personal information from other healthcare professionals involved in your care, with your consent, to ensure coordinated and effective support. Any personal information obtained from third parties will only be used in line with this privacy policy and handled securely.
In some circumstances, Luna Path may receive personal information from other sources relevant to your care or the administration of my counselling practice. This could include, for example, referrals from other professionals, information provided by family members with your consent, or publicly available sources. Any information obtained from these sources will be used only for legitimate purposes, handled securely, and in line with this privacy policy.
How long Luna Path keeps information
· Adults: 7 years after the last session
· Children / young people (under 18 at time of service): Kept until client turns 25 years old (or 7 years after the last contact, whichever is longer)
For more information on how long Luna Path stores your personal information or the criteria we use to determine this please contact Luna Path using the details provided above.
Who Luna Path shares information with
Others Luna Path shares personal information with:
· Other health providers (eg GPs and consultants)
· Care providers
· Organisations Luna Path needs to share information with for safeguarding reasons
· Emergency services
· Local authorities or councils
· External auditors or inspectors
· Organisations Luna Path is legally obliged to share personal information with
Duty of confidentiality
Luna Path is subject to a common law duty of confidentiality. However, there are circumstances where we will share relevant health and care information.
These are where:
· you’ve provided Luna Path with your consent (Luna Path have taken it as implied to provide you with care, or you have given it explicitly for other uses);
· Luna Path have a legal requirement (including court orders) to collect, share or use the data;
· on a case-by-case basis, the public interest to collect, share and use the data overrides the public interest served by protecting the duty of confidentiality (for example sharing information with the police to support the detection or prevention of serious crime);
· if in England or Wales: the requirements of The Health Service (Control of Patient Information) Regulations 2002 are satisfied; or
· if in Scotland – Luna Path have the authority to share provided by the Chief Medical Officer for Scotland, the Chief Executive of NHS Scotland, the Public Benefit and Privacy Panel for Health and Social Care or other similar governance and scrutiny process.
National data opt-out
Luna Path complies with England’s national data opt-out because Luna Path is using confidential patient information for purposes beyond individual care. To find out more or to register your choice to opt out, please visit www.nhs.uk/your-nhs-data-matters.
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to Luna Path using the contact details at the top of this privacy notice.
If you remain unhappy with how Luna Path has used your data after raising a complaint with Luna Path, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113