Privacy Policy

Privacy Policy

Last updated:  09.10.2024

At The Lazarus Practice we are committed to respecting and protecting your privacy at all times and take seriously our responsibilities under data protection legislation.

Your personal information is data which by itself or with other data available to The Lazarus Practice can be used to identify you as an individual.This privacy notice outlines how The Lazarus Practice Limited and its affiliates (collectively “The Lazarus Practice”, “we”, “us”,or “our”) collect and use your personal information, how we keep it secure and respect your privacy.  

Our role in your privacy

If you are a client of The Lazarus Practice, a prospective client, or just visiting our website, this policy applies to you.

Our services are currently limited to supporting adults (aged 18 years plus). If you are under the age of 18, please do not use our website or contact us.

Who we are and our responsibilities

The Lazarus Practice Limited is a private limited company with its registered office is 85 Great Portland Street, London, England, W1W 7LT.

The Lazarus Practice is the ‘data controller’ of your personal information that we collect and use, and you are the ‘data subject’.

We engage independent therapists and other wellbeing practitioners to provide care to you (the “Providers”).The Providers will maintain records in relation to the services that they provide to you within The Lazarus Practice system/platform. They are an independent ‘data controller’ in respect of the personal information that they hold within those records, meaning that they must comply with the data protection legislation and relevant guidance when handling your personal information.

Types of personal information that we collect and use 

In order for The Lazarus Practice and your Provider to provide your care we will collect certain types of personal information about you. 

The personal information we may collect includes:

• Contact details: Your full name and title, address and contact details, including email address and telephone numbers and other contact details that you share with us. Also emergency contact details and/or next of kin
• Identity details: including your date of birth, gender, marital status, other IDs such as NHS number or passport details.
• Data that identifies you: Information about how you use our website, IP address, login information, browser details (such as type and version), time zone settings, browser plug-ins, geolocation information, and operating system details
• Feedback data: Information received in response to any surveys, complaints or claims (or other feedback).
• Other Information: Any other information you choose to provide to us about yourself or others or that is generated during out contractual relationship with you.

We may also collect and hold personal information that is known as special categories of data, which includes:

• Details of your current and previous physical and mental health that you have provided to us. This may include details of care you have received elsewhere, and any medical records including past therapy
• Information about medical or health conditions of your family
• Your religion, nationality, race and/or ethnicity
• Sexual orientation
• Genetic or biometric data relating to you

If you are employed by The Lazarus Practice or engaged as Provider, we will also hold and process other information relating to your recruitment, employment, or services you provide. Please request our Privacy Policy for employees and Providers.

Where does this personal information come from?

We may collect this information in a variety of ways. We will collect most of this information directly during the registration process but we may also obtain data from your identity documents, website enquiry forms, from correspondence with you, through interviews and surveys, video calls, or by telephone.

The Lazarus Practice may request that you provide us with personal information about you from third parties, such as your GP, the NHS, mental health providers, or referral agencies. For instance, this may include your medical records  from your GP or by a referring therapist and any other health professionals that have been involved in your care.  If a third party provides any personal information about you directly to us, we will let you know.  

Do I have to provide my personal information?

You are not obliged to share any personal information with us, but limiting the information you do disclose may mean we are unable to offer a full range of therapy services and therefore it may affect the service we can offer. We will tell you if providing some personal information is optional, including if we need to ask for your consent to process it. In all other cases, we need you to provide your personal information so we can provide care to you and receive payment for our services.

How will The Lazarus Practice use my personal information?

We can only use your data for specific reasons and if we have a legal basis to do so. These reasons are:

• Managing our contractual relationship

Handling information requests about The Lazarus Practice and our services; executing, fulfilling, monitoring and enforcing compliance of our legal contract with you; issuing invoices and collecting payments.

Legal basis: Contract
Data categories: Contact details, Data that identifies you, Other information

• Providing our services

We use your personal information to fulfil our contract with you to support the provision of your support in the following ways:

• to decide how best to provide support to you
• to take steps at your request during the course of your support
• to keep your records up to date
• providing the Providers with all necessary information for them to provide the services to you

Legal basis: Contract
Data categories: Contact details, Identity Details, Special categories of data, Other information.

• Marketing communications

We will never use your personal information for marketing purposes without your consent. We will not sell your personal information to a third party. Subject to obtaining your consent and in accordance with your communications preferences we may use your contact details to send you newsletters and other information on new services and care pathways, which we think may be of interest to you.

If you don't want to receive such communications, you can object at any time by clicking the unsubscribe link on the message. You are free at any time to change your mind and withdraw consent for marketing activities. Please contact data-protection@thelazaruspractice.com.

Legal basis: Consent

Data categories: Contact details

• Improving The Lazarus Practice and our services

We also use your personal information to maintain the high standards of service that we provide:

• for good governance, accounting, and managing and auditing our therapy and business operations
• for surveys of client experience and quality of care
• to monitor emails, videos, calls, other communications, and activities on the Lazarus Practice networks and systems for quality assurance and for Provider training
• for market research, other surveys and analysis and developing statistics for improving therapy performance
• Managing landing pages and heat mapping our website, optimising traffic
• anonymising personal information for development, testing and analytics of the website and services.

Legal basis: Legitimate interests - (i) to ensure an appropriate standard of care, (ii) self-regulatory practices, (iii) and be in a position to defend from and minimise any claims from our clients, and (iv)analysing our business practices so that we can make informed decisions and define our strategies for developing and growing our business.
Data categories: Contact details, Identity details, Data that identifies you, Feedback data, Other information

• Maintaining security of The Lazarus Practice services and website

Ensuring that our services and website are not being used in an unauthorised or abusive way by detecting, investigating or preventing activities that go against our policies or laws, to protect the security of our communications networks and systems.

Legal basis: Legitimate interest - protecting our platforms, systems, and clients from cyberattacks, similar malicious actions.
Data categories: Contact details, Data that identifies you, Other information

• Complying with legal obligations

We use your personal information to ensure we can comply with our legal obligations:

• when you exercise your rights under data protection law and make requests
• for compliance with legal and regulatoryrequirements and related disclosures
• for establishment and defence of legalrights
• to verify your identity, credit fraudprevention, and anti-money laundering checks
• to investigate complaints, legal claimsand data protection or therapy incident
• for when we need to see a record of whathas been said.

Legal basis: Legal obligation
Data categories: Contact details, Identity Details, Data thatidentifies you, Feedback data, Other information

‍When does The Lazarus Practice share your personal information with others?

• Sharing information with those involved in your support. This would include:
  • The Providers
  • Your GP and/or other referring therapist(s)
  • If we feel you are vulnerable or “at risk” we have an obligation to share information about you with the local Safeguarding Team, the specialist members of which come from the local authority, NHS organisations and the police
  • Anyone you have asked us to communicate with or whose details you have provided as an emergency contact

• Sharing information with third parties not involved in your care
  • We share personal information with external organisations as required to ensure business functions are able to operate and to ensure the security and integrity of these functions.  In each case only information relevant to them is shared. The third parties can include:
    • Software providers of clinical and non-clinical systems
    • Legal and professional advisors, including auditors
    • Sharing information with regulatory bodies or due to a legal obligation 
    • Debt collection agencies if our fees are not paid in accordance with our terms. The information shared would only include contact details and copies of invoices. We would not share your medical records
  • We may disclose personal information where we have a statutory or legal obligation to do so, such as when instructed by court order or by the police and other crime agencies for the detection and prevention of crime

• Sharing of personal information for research
  • The Lazarus Practice is committed to furthering research and education in health and wellbeing care. We may therefore use your personal information for clinical research and education, for audits of therapeutic and clinical outcomes, and to support performance and process improvements.
  • We will seek your explicit consent to use your personal information for such purposes, inline with research ethics requirements and data protection laws.  

• Based on your consent we may also share your data:
  • with your next of kin or other nominated contact
  • if you ask us to disclose your personal information to a third party

You are free at any time to change your mind and withdraw your consent, where we have only relied on your consent, to share your personal information. We will advise you if the consequence of doing so is that we cannot continue to provide full care services to you.

• We are not responsible for third parties

Other than in respect of the Providers, this Privacy Policy does not address and we are not responsible for the practices or policies of any other parties that are provided with your personal information. These other parties may gather information from or about you. We have no control over the privacy practices of these other parties and make no representations about them.

For how long do we retain your personal information?

• We will only keep your personal information for as long as is necessary to comply with the purposes outlined in this privacy policy and to comply with legal and regulatory requirements. Longer retention periods for your personal information may apply in the case of:
  • queries: we will retain your personal information as long as necessary to handle any queries you may have
  • claims: we will retain your personal information for as long as you might legally bring claims against us in accordance with other legal and regulatory requirements. Once these periods have passed, we will either delete or anonymise your personal data.

Security of personal information

The Lazarus Practice is committed to keeping your personal information secure.

• Any personal information held by The Lazarus Practice is held on secure cloud servers and encrypted
• Strong passwords and two factor authentication are mandated on all systems holding and personal information
• Encryption controls have been implemented for data that is sent and received by us.  While we take measures to protect your information, please be aware that transmitting information over the Internet carries some inherent risks. We cannot guarantee absolute security, so please exercise discretion when sharing information online
• Video calls are end-to-end encrypted.

Use of cookies

Cookies are small data files that can identify you when you visit a website. Cookies remember your settings during and between visits to our site and also improve the speed and security of the website. 
We use cookies on our website to improve the visitor’s experience, ensuring our website is responsive, fast and shows the information that you need. It enables us to improve the website and our marketing. 

Please see our Cookies Policy here for more information on how we use cookies.

To block cookies, activate a setting on your browser that allows you to refuse their setting. You can also manage your preferences with our cookie banner, or delete cookies through your browser settings. However, if you use your browser settings to disable, reject, or block cookies (including essential cookies), certain parts of our website may not function fully. In some cases, our website may not be accessible at all. Please note that we have no control over how third parties use cookies when they are used.

What rights do I have as a data subject?

Your rights, under the data protection laws, are as follows (noting that these rights do not apply in all circumstances):

• the right to be informed about processing of your personal information
• the right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
• the right to object to processing of your personal information
• the right to restrict processing of your personal information
• the right to have your personal information erased (the "right to be forgotten”)
• the right to request access to your personal information and information about how we process it
• the right to move, copy or transfer your personal information ("data portability")
• rights in relation to automated decision-making including profiling.

Should you have any queries or wish to exercise any rights set out in this notice you can contact The Lazarus Practice Data Protection Officer at the address below.

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 we ask that you contact us in the first instance.

How to contact us

• Call 999 if you are having a mental health emergency.
• For contact related to this Privacy Policy or your personal information:
  • DataProtection Officer, The Lazarus Practice, 85 Great Portland Street, London, England, W1W 7LT
  • Email: data-protection@thelazaruspractice.com
• For all other enquiries: info@thelazaruspractice.com

Changes to the privacy policy

This version of the Privacy Policy was last updated on the date appearing at the start and any historic versions are available on request. We may make changes to this Privacy Policy from time to time and, if appropriate, will notify you by email regarding changes. In any event your continued use of our services after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.