Last updated: 23 May 2018
At Company Daisy Luiten we value the people we support, the customers who buy our products and the professionals we train. We take your privacy very seriously, treating any information you give to us with great care. We will ensure any personal information you provide to us is protected using secure systems and processes.
Our aim is to comply at all times with the EU General Data Protection Regulation (GDPR) and other relevant legislation.
This policy explains how we collect and use the personal information you provide to us. By using our website, any of our services, or providing us with any personal information we will assume you are agreeing to your information being used and disclosed in the ways described in this policy.
About Company Daisy Luiten
Company Daisy Luiten (referred to as Company DL from this point) is the practice and company owned by Daisy Luiten. Daisy Luiten is an art therapist specialising in bereavement counseling. She supports children, teenagers and adults, and educates professionals in the area of bereavement. Company DL also develops therapeutic products for therapists and for private persons.
Daisy Luiten is registered in the Netherlands at the Register Professional Practitioners Complementary Care (Register Beroepsbeoefenaren Complementaire Zorg, RBCZ), and she is a member of the Dutch Association for Specialized Pychosocial Therapists (de beroepsvereniging voor gespecialiseerde psychosociaal therapeuten, NVPA). She is also registered as a certified grief and bereavement counselor in the referral archife of the Dutch National Bereavement Support Organization (Landelijk Steunpunt Verlies, LSV).
What personal information does Company DL collect?
There is a variety of ways in which we may collect your personal information; for example, when you make an enquiry about our activities, access our support, sign-up for a newsletter, request training information, take part in our events, make a purchase from our shop or when you make a donation.
Information we routinely collect may include details such as your name, address, phone number and email address. We also collect and hold information about the activities that you take part in. This may include:
- Financial details when you make a donation
- Details of purchases though our webshop, via email or phone or at an event
- Event or training registration and attendance
- Details of correspondence sent to you or received from you
- Responses to surveys sent to you
Additional data will be collected in relation to families who access direct support from Company DL, in accordance with our record keeping policy, to ensure safe and consistent support can be delivered. The details of information storage, consent, confidentiality and safeguarding will be discussed at the outset of any direct work.
Due to the nature of our activities, we hold personal information relating to children and young people when they access direct support. These details are only held with the explicit consent of the child’s parents/guardian or a young person themselves if they are Fraser competent. They are kept securely with restricted access and handled with the greatest respect for privacy.
In some circumstances, we may collect data which is classified as ‘special categories of personal data’ under the GDPR. An example would be data about ethnic origin. We only hold this information for specific purposes and with your explicit consent. This information is only accessible to the therapist you work with in Daisy Luiten’s practice and not to other staff.
We may receive your information from a third party, for instance when an organisation gives you one of our products. These organisations will have their own data protection and privacy policies which you should be aware of before signing up.
How do we use your personal information?
We use the personal information you give us, where relevant, to:
- provide safe and consistent support to families
- to process your orders or donations, and to ensure they are recorded correctly
- to keep records of your relationship with us. For example; what events you have attended, what enquiries or complaints you
have made or what resources you have ordered.
- to provide you with information about our work and services including news, events, volunteering opportunities, fundraising
appeals, services, training and resources, and to tailor this kind of information according to your location and interests.
- conducting market research and reporting purposes
- to check on your preferences from time to time to ensure they are up to date
Using your information for marketing purposes
Families receiving direct support from Company DL will not receive marketing information but may consent to receive this information by email, post or phone (marketing information may include news about the work that we do, events and services). This will be discussed with them at closure of family support sessions.
Being able to communicate with you is important, as it keeps us up to date and helps us to continue our work for instance to develop new products to serve children and families in therapeutic sessions.
We may send your postal communications and occasionally call you (unless you have already told us you do not wish to receive post or phone calls). We rely on our legitimate interests to do this and have balanced our interests with yours. It is always your choice and you will always have a clear and easy way to opt-out.
We will only send you marketing emails when you have given us your consent to do so. You can stop receiving these at any time by clicking on an ‘unsubscribe’ link at the bottom of any marketing email you receive from us.
From time to time we conduct research and analysis using publicly available sources. We might use external data sources to increase or enhance the information we hold about you. This may include obtaining details of changes of address, telephone numbers and other contact details. This information may be taken from publicly available sources, such as public registers, company websites, newspapers, magazines and social media posts.
We will never sell your information or share it with other organisations for their marketing purposes.
How to stop receiving marketing communications
How do we protect your personal information?
Company DL is committed to the security of your personal information. We take appropriate technical and organisational security measures to safeguard personal information. Company DL uses commercially reasonable physical, administrative and technological safeguards to preserve the integrity and security of all information collected through our website and related sites. Company DL uses industry standard high encryption security measures to protect the loss, misuse and alteration of the information under our control. All information processed on our website is transmitted using Secure Socket Layer (“SSL”) technology. SSL encrypts your information to avoid the decoding of that information by anyone other than Company DL.
Information in relation to families who receive direct support is securely locked down so it is only available to Daisy Luiten and/or therapists who work in Daisy’s practice, not to other staff.
Who do we share your personal information with?
We engage service providers to work on our behalf, who will be employed under strict contractual arrangements and only have access to the specific information they need to undertake the service required. For example, our bookkeeper company and the companies processing website payments (for instance credit card). We will only provide those companies with the information they need to deliver the specific service and we ensure that your data is treated with the same level of care as if we were handling it directly.
Otherwise, we will only disclose your personal information to another party if required to by law.
Sharing of information under safeguarding policies will be discussed with the families we support at initial contact.
Where we store your personal information?
Personal information you provide to us is securely stored in a safe storage and/or filing cabinet.
How long will you keep my information?
We will retain your information for as long is necessary for the relevant activity, and meet any legal or regulatory requirement. If you cease to have an active relationship with us or request to receive no further contact, we will retain some basic information in order to avoid sending you unwanted materials in the future, and to ensure that we don’t accidentally duplicate information.
To comply with professional standards all information in relation to family support work will be securely stored for the period of 15 years following the Law on the therapeutic treatment policy (in Dutch: WGBO, Wet op de geneeskundige behandelingsovereenkomst).
How can you access your personal information?
We may request proof of your identity, this is to ensure we do not pass personal information to anyone else, other than the person making the request. The statutory time for our response is 4 weeks, but we will endeavour to respond sooner.
How can you amend or remove your personal information?
Any request to have your information deleted will be assessed on a case-by-case basis, as we may be under a requirement to retain it.
From time to time we may make changes to this policy. If any significant changes are made regarding how we collect and use your personal information we will update this policy.
This policy was last updated: 23 May 2018