Skip to Customer Data Privacy Notice
1. Important information and who we are
This website is not intended for children and we do not knowingly collect data relating to children.
Full name of legal entity: Liminal Health Ltd,
Email address: firstname.lastname@example.org
Postal address: 12 Fairway, Princes Risborough, Bucks HP27 9DH
Telephone number: 07796 924 959
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
July, 2020. Historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you that we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, your photograph (if you choose to upload it) and gender.
- Contact Data includes billing address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of services that you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your username and password, your photograph (if you choose to upload it), purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Special Categories of Personal Data (sensitive personal data) about you includes details about your information about your health, and genetic and biometric data, race or ethnicity, religious or philosophical beliefs. This may be in the form of a audio or video recording of your counselling/coaching as this may be useful for you to refer back to after your session.
We also collect, use and share Aggregated Data
such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not
We do not collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the services). In this case, we may have to cancel a Service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
Automated technologies or interactions.
- apply for our services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a promotion or survey; or
- give us feedback or contact us.
from the following parties:
- analytics providers such as Google based outside the EU;
- advertising networks based inside or outside the EU; and
- search information providers based inside or outside the EU.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
We also rely on consent as a legal basis for processing your personal data through the services that we provide to you that relate to your Special Category Data – these enable us to provide the advice or counselling services that you have come to us for. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
||Type of data
||Lawful basis for processing including basis of legitimate interest
|To register you as a new customer
||Performance of a contract with you
|To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
||(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
||(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a complete a survey
(e) Marketing and Communications
||(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
|To make suggestions and recommendations to you about goods or services that may be of interest to you
(f) Marketing and Communications
||Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above. All such sharing of your personal data will be governed by a written agreement between us and the third party.
- External Third Parties who are consultants to us, providing the services to you, or that may be your insurer or private healthcare provider, that may enter into a contract with us, requiring us to provide services to you. You will already have your own relationship with that External Third Party.
- The doctors and other healthcare professionals involved in your treatment, if you wish Liminal to disclose your personal data to them.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
We share your personal data within Liminal. This may involve transferring your data outside the United Kingdom and the European Economic Area (EEA) through the use of our secure IT systems. Any such transfer of personal data will be covered by written agreements protecting your personal data.
Some of our external third parties are based outside the United Kingdom so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the United Kingdom, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries (this still applies in the UK post-31st December, 2020).
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries (this still applies in the UK post-31st December, 2020).
- Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the United Kingdom.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
- No fee usually required – You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
- What we may need from you – We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
External Third Parties
- Service providers acting as processors offering IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Customer Data Privacy Notice
This Patient Data Privacy Notice sets out how Liminal collects, stores, analyses, uses, modifies, deletes or does anything else with Personal Data of patients that Liminal receives, as it is acting as the Data Controller (controlling the purposes and the means of data processing). Liminal does this in the provision of its Services to you.
Liminal will adhere to this Privacy Notice at all times in compliance with the provisions of the General Data Protection Regulation (GDPR) and its obligations of Confidentiality.
Liminal receives and collects Personal Data about patients in order to provide patients with advice and counselling. Such records of Personal Data enable Liminal to provide its Services to you. Liminal will use your Personal Data in order to check and review the quality of care that it provides. This helps to improve the quality of Service to you.
“Personal Data” covers any data that can be used to identify a living individual (data subject). Individuals can be identified by various means including their name and address, telephone number or email address.
The Personal Data that Liminal IT systems will handle from patients includes name, address, email address, date of birth and data concerning health (also known as special category data). This Personal Data of patients must be dealt with by Liminal to ensure Liminal’s compliance with GDPR.
Liminal performs processing activities on such patient Personal Data that it receives from patients, that patients provide to their Liminal Professionals in the course of receiving Services from Liminal and also administrative data that Liminal requires of the patient in order to arrange appointments and secure payment. The handling and communication of all such Personal Data by Liminal constitutes processing of such Personal Data.
Liminal will only share your Personal Data with a healthcare professional if you provide your written consent to Liminal for it to do this.
The lawful and proper treatment of patient Personal Data by Liminal is extremely important to Liminal and assists to maintain the confidence of Liminal’s clients. Liminal ensures that it treats personal data lawfully and correctly.
Liminal fully supports and complies with the principles of GDPR that relate to data processing:
- Personal data shall be processed lawfully and fairly.
- Personal data shall be obtained/processed for specific lawful purposes.
- Personal data held must be adequate, relevant and not excessive.
- Personal data must be accurate and kept up to date.
- Personal data shall not be kept for longer than necessary.
- Personal data must be kept secure
- identify every relationship where Liminal acts as a Data Controller;
- make sure that measures and controls are in place to Process the Personal Data only in accordance with the obligations placed upon a Data Controller by applicable law;
- document and test those measures and controls to satisfy themselves that these work, and continue to work, in practice;
- commit all Liminal Workers who have access to the Personal Data supplied by the patients, to keep that Personal Data confidential.
Data Protection Officer
This person will be the person with overall responsibility for data protection and they will:
- provide training for all working at Liminal who handle Personal Data and ensure access to further guidance and support;
- provide clear lines of report and supervision for compliance with data protection;
- carry out regular checks to monitor and assess new processing of Personal Data; and
- develop and maintain Data Protection procedures to include: roles and responsibilities, notification, subject access, training and compliance review.
Responsibilities of People Working at Liminal
All people working at Liminal will, through appropriate training and responsible management:
- Observe guidance, practice and procedures about the collection and use of patient Personal Data;
- Understand fully the purposes for which Liminal uses patient Personal Data;
- Collect and process appropriate patient Personal Data, and only in accordance with the purposes for which it is to be used by Liminal in the ordinary course of business or fulfilment of its legal requirements;
- Ensure the patient Personal Data is destroyed when it is no longer required;
- On receipt of a request by or on behalf of a patient about the patient Personal Data held about them, respond to provide a response in line with obligations set out by law; and
- Understand that breaches of this Patient Data Privacy Notice may result in disciplinary action, up to and including termination of contract.
Liminal is required by law to provide you with the following information about how Liminal handles your information.
|Data Controller contact details
||Liminal Health Ltd Registered Office: 39 Lilestone St, London, NW8 8SS
|Data Protection Officer contact details
|Purpose of the processing
- To give direct complementary care to individual patients, through Liminal’s Professionals, including counsellors, dieticians, nutritionists, coaches, physiotherapists, psychotherapists, or other coaches.
- To check and review the quality of care and adhere to professional standards (this is called audit and clinical governance).
|Lawful basis for processing
||These purposes are supported under the following sections of the GDPR:
Article 6(1)(e) ‘…necessary for the performance of a task carried out in the public interest’; and
Article 9(2)(h) ‘necessary for the purposes of preventative or occupational medicine for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services…”
Liminal Professionals will also respect and comply with their obligations under the common law duty of confidence.
|Rights to object
- You have the right to object to Personal Data being shared between those Liminal Professionals who are providing you with direct care or Liminal Workers processing your Personal Data as part of the administrative operations of Liminal.
- However this may affect the care you receive – please speak to Liminal.
- You are not able to object to your name, address and other information being used by Liminal in order to arrange for payment for the Services, unless you no longer wish to receive the Services.
|Right to access and correct
- You have the right to access your record and have any errors or mistakes corrected. Please speak to a Liminal Professional or Candice Hampson or look at our ‘subject access request’ policy on the Liminal website.
- Liminal as a provider of complementary health care will be under an obligation to retain your Personal Data as part of the professional standards to which it and Liminal Professionals must adhere.
||Your records will be kept in line with the law and national guidance.
|Right to complain
||You have the right to complain to the Information Commissioner’s Office. If you wish to complain follow this link https://ico.org.uk/global/contact-us/ or call the helpline 0303 123 1113