We are company number 662576 registered in Ireland.
Our registered office is Unit 3, First Floor, Ryan House, Emmet Street, Trim, Co. Meath. Our phone number is 087 3830875 and email address which is email@example.com Introduction: This is a notice to inform you of our policy about all information that we record about you. It sets out conditions under which we may process any information that we collect from you, or that you provide to use. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice “process” means collect, store, transfer, use or otherwise act on information.
We regret that if there are one or more points below with which you are not happy, we will not be in a position to provide services to you at this time.
We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party. We undertake to preserve the confidentiality of all information you provide to use, and hope that you reciprocate.
Our policy complies with the Data Protection Act 2018 (Act) accordingly incorporating the EU General Data Protection Regulation (GDPR). The law requires us to tell you about your rights and obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org
Who are we? Who is the Data Controller? “Dr. Emma O’Brien, Clinical Psychologist” is a private provider or children’s, adolescent’s , and young adult’s psychology services in Ireland. The Data Controller is Emma O’Brien. This statement relates to our privacy practices.
Where is the location of processing? “Dr. Emma O’Brien, Clinical Psychologist” offers clinic-based appointments and telehealth appointments using videoconferencing software. Personal data is processed at our clinic location and the home office of our Administrator which is in Co. Westmeath.
What personal data do we process? How do we process data? We process the following data: Names (of parents/guardians and children), addresses, telephone numbers, email addresses and dates of birth. We process information relating to the health (physical and mental) and education of the young people attending our service. We also process text submitted via forms on our website or third party appointment scheduling software (WriteUpp) which may or may not include names, e-mail addresses and telephone numbers. We also process IP addresses. We collect information in manual/paper and electronic formats. We do not record telephone calls or online Telehealth sessions.
Credit/debit card details and associated cardholders names and addresses submitted via “Dr. Emma O’Brien, Clinical Psychologist” website are processed directly by WriteUpp (online appointment scheduling software), PayPal (card payment processor), and SumUp (card payment processor). You may be sent links to complete payment via e-mail and/or SMS. You can read about WriteUpp, PayPal and SumUp GDPR compliance here: https://help.writeupp.com/en/article/is-writeupp-gdpr-compliant-1ih2158/ https://www.paypal.com/uk/webapps/mpp/gdpr-readiness-requirements https://help.sumup.com/hc/en-ie/articles/360004703114-GDPR-SumUp-and-my-data
“Dr. Emma O’Brien, Clinical Psychologist” does not store credit/debit card information. At the point of payment, you are transferred to a secure page on the website of PayPal/Stripe/SumUp or some other reputable payment service provider. That page may be branded to look like a page on our website, but It is not controlled by us.
Our email (firstname.lastname@example.org) is hosted by Gmail via GSuite; you can read about Gmail and GDPR compliance here: https://privacy.google.com/businesses/compliance/#?modal_active=none
We employ Virtru, a service which encrypts emails from us; you can read about Virtru and GDPR compliance here: https://www.virtru.com/gdpr-compliance/
We do not send confidential information by email and we actively encourage families not to email unencrypted confidential information to us.
Our online session take place via Zoom (video-conferencing software) or WriteUpp. You can read about Zoom and GDPR here: https://zoom.us/gdpr
When you contact us, whether by telephone, through our website or by e-mail, we collect the data that you have given us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our business.
We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.
Why do we process personal data? It is necessary to process data as part of the process of provide psychology services to the young person. This includes, but is not limited to booking appointments, conducting phone consultations and telehealth sessions, carrying out assessments and interventions, making onward referrals, discussing a client’s case with parents/legal guardians and other professionals (as appropriate). Additionally data may be processed for administrative purposes, including but not limited to invoicing and day-to-day administration and financial activities (e.g. accounting, end-of-year tax returns) that are within our legitimate interests.
Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply, or when you leave a voicemail and you would reasonably expect a return phone call.
Who do we share data with and why? Data processed by “Dr. Emma O’Brien, Clinical Psychologist” remains confidential and is not shared with individuals, companies or organisations except under the following circumstances:
1. Legal reasons - We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation. For example, we may be required to give information to legal authorities if they request or if they have the proper authorisation such as a search warrant or court order. This may include your personal information.
2. Information sharing – with your consent, we may share personal information pertaining to the younger person when we have the written consent of their parents or legal guardians to do so. Information sharing in this way will only take place in the case that it is in the best interest of the young person and the psychology services provided to them. For example, we may request or disclose information with the young person’s educational placement or other professionals involved in their care.
3. For processing by third parties – including WriteUpp (online appointment scheduling software), Gmail (e-mail platform), Zoom (video-conferencing platform), PayPal/SumUp (card payment processor) and our Accountants. Where we process your information on this basis, we do so after having given careful consideration to: • Whether the same objective could be achieved through some other means • Whether process (or not processing) might cause you harm • Whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
How do we store and protect data? Physical/paper-based data and electronic data is stored at our registered address and the home office of our Administrator, Emma O’Brien. Physical/paper-based data is stored in lockable filing cabinets. Electronic data and the devices storing this information are encrypted and have Firewalls enabled. We have BitDefender Security installed and enabled on all devices which may be used to process data. All data is accessible only by our Administrator, Emma O’Brien. We do not store client information on cloud servers.
How long do we retain data for? We retain data in line with data retention guidelines provided by the HSE. We retain all electronic and/or paper/physical data relating to the young person until their 25th birthday or until their 26th birthday if the young person was 17 at the conclusion of treatment, or 8 years after death. Financial data for the current year and previous six financial years is retained. All data is destroyed under confidential conditions upon expiration of the retention period.
Consent: When making a referral to “Dr. Emma O’Brien, Clinical Psychologist”, consent must be provided by both parents or legal guardians to process the referral. Prior to the initial appointment, parents/legal guardians of young people under 18 years of age are provided with a Consent Form to proceed with assessment/intervention which must be signed before services commence. Young people aged 18+ are required to sign their own Consent Form. They may be required to provide additional consent for the involvement of their parents/legal guardians if appropriate (e.g. in the case of collecting early developmental history). Individual consent forms are also provided with regard to obtaining and sharing information as described in “Who do we share data with and why” above. Furthermore, additional consent forms must be completed in advance of telehealth sessions and clinic sessions carried out under strict operating procedures put in place during the COVID-19 pandemic.
Data may be processed outside the European Union: Our website is hosted in Ireland. We may also use outsourced services in countries outside the European Union from time to time in other aspects of business (e.g. WriteUpp, Gmail, GSuite, SumUpp, PayPal etc). Accordingly, data obtained within Ireland or any other country could be processed outside the European Union. It is our understanding that these companies are GDPR compliant and have subscribed to the EU-US and Swiss-US Privacy Shield and/or EU Model Contract Clauses (MCCs, also known as Standard Contractual Clauses or SCCs) which ensures that EU citizens are protected under EU data protection laws. You can read more about Privacy Shield here: https://www.privacyshield.gov/welcome.
Access to your personal information: At any time you may review or update personally identifiable information that we hold about you, by contacting us by e-mail at email@example.com. After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
Complaints about how your data is processed: When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint. If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is. We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person. If you are concerned about how your personal information is processed by “Dr. Emma O’Brien, Clinical Psychologist”, please contact us by emailing firstname.lastname@example.org