Privacy Policy

Introduction

Welcome to the privacy policy of Lifespan Therapy.

We at Lifespan Therapy respect your privacy and are committed to protecting your personal data in accordance with our obligations under the General Data Protection Regulation ((EU) 2016/679) and the Data Protection Act 2018 (referred to in this privacy policy as “Data Protection Law”).

This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how Data Protection Law protects you.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Lifespan Therapy collects and processes your personal data when carrying out its services and functions.

Controller

Dr David Gogan, Chartered Clinical Psychologist (trading as Lifespan Therapy) is the controller responsible for your personal data (referred to as “Lifespan Therapy”, “we”, “us” or “our” in this privacy policy).

Contact details

If you have any questions about this privacy policy, including any request to exercise your legal rights, please contact Lifespan Therapy’s Data Protection Officer (“DPO”), Dr David Gogan, in the following ways:

Email address: david@lifespantherapy.ie

Postal address: Dr David Gogan, Chartered Clinical Psychologist, Lifespan Therapy, Dodder Park Medical, Dodder Park House, Dodder Park Drive, Rathfarnham, Dublin 14

You have the right to make a complaint at any time to the Data Protection Commission, the Irish supervisory authority for data protection issues (www.dataprotection.ie).  We would, however, appreciate the chance to deal with your concerns before you approach the DPC so we would ask that you please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

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 which we have grouped together as follows:

• Identity Data includes first name, last name, title, date of birth and gender.
• Contact Data includes postal address, email address, telephone numbers and next-of-kin contact details.
• Financial Data such as payment card details when you pay for our services.

Special Categories of Personal Data is personal data of a particularly sensitive nature, and includes information concerning a person’s health, their sex life or sexual orientation, or their religious and philosophical beliefs.  Due to the nature of our work, we may handle your health information and other special categories of personal data when carrying out our services and functions.  For the purpose of this privacy policy, the types of personal data detailed in this paragraph are referred to as “Sensitive Data”.

We may also handle information about criminal convictions and offences that you or third parties provide to us.

Like all other types of personal data, we handle Sensitive Data and information about criminal convictions and offences only when we have a lawful basis for doing so (as described in more detail in section 4 below) and strictly in compliance with all of our obligations under Data Protection Law.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your personal data by engaging with us face-to-face or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• make an appointment with us;
• attend a consultation with us;
• give us feedback or contact us.

• Third parties. We may receive personal data about you from certain third parties in circumstances including:
  • From your General Practitioner or other medical adviser when they have referred you to us, or when we need information regarding any other health care, treatment or advice that has been provided to you so that we can carry out our services and functions.
  • From The Child and Family Agency (Tusla) or the Health Service Executive when we have been asked us to carry out a clinical assessment and to prepare a report.
  • From a referring solicitor when we have been asked to carry out a clinical assessment and to prepare a report in the context of prosecuting or defending a legal claim.
  • From other third party sources such as family members.

4. How we use your personal data

We will only use your personal data when we have a lawful basis for doing so, which means when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform a contract to deliver services to you.
• Where we need to protect your vital interests or the vital interests of another person.
• Where you have consented to us using your personal data for specified purposes.
• Where we need to comply with a legal obligation.
• 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.

Most commonly, we will use your Sensitive Data in the following circumstances:

• Where it is necessary for the purpose of delivering the health care service that we have agreed to provide to you or to another person.
• Where you have consented to us using your Sensitive Data for specified purposes.
• Where we need to protect your vital interests or the vital interests of another person where you are physically or legally incapable of giving consent.

Where consent is the lawful basis we rely upon to handle your personal data, you may withdraw such consent at any time free of charge.

Please 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.

Purposes for which we will use your personal data

We may use your personal data for purposes including:

• To verify your identity.
• To create your psychological healthcare file.
• To arrange appointments with you and to contact you regarding appointments.
• To provide the services that have been requested.
• To attend consultations and carry out clinical assessments.
• To provide appropriate care, treatment and advice.
• To make referrals to other medical professionals if we consider it to be necessary and appropriate.
• To respond to queries and provide support.

5. Your personal data and third parties

Third Party Service Providers

We may share your personal data with third party service providers who perform services and functions at our direction and on our behalf.  Such third party services providers may include administrative service providers, accountants, legal advisers, IT service providers, payment service providers and security services providers engaged by us.

We require all third parties to respect the confidentiality and 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 we only permit them to process your personal data for specified purposes and in accordance with our instructions.

Other medical professionals

It may be necessary or appropriate to refer our clients to other medical professionals for further care, treatment or advice and we may share your personal data with such other medical professionals for such purposes.  We will seek your consent before we do so, unless there is a serious concern regarding your vital interests or the vital interests of others.

An Garda Síochána, government or quasi-government bodies, courts and tribunals

We may share your personal data with these organisations and bodies where we are required to do so by law.

Clinical supervision

The code of professional ethics and professional practice guidelines that apply to psychologists require us to engage in “clinical supervision”.  This process involves us discussing and reviewing consultations and assessments we have carried out with other psychologist colleagues, for the purpose of ensuring that we are providing the best possible clinical service to our clients.  Any personal data that we share in the course of clinical supervision is disclosed on a strict “need to know” basis.  The colleague in question is subject to the same duties as us to ensure that all personal data is protected and treated strictly in accordance with their professional, ethical and legal obligations, including the requirements of Data Protection Law.

6. International transfers

We may transfer, store or process your personal data in countries outside the European Economic Area (“EEA”).  Where the laws of such countries do not afford an equivalent level of protection of personal data as the laws of Ireland, we take specific steps in accordance with data protection law to protect your personal data.

We’ll use one of these safeguards:

• Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA.
• Put in place a contract with the recipient of the personal data that means they must protect it to the same standards as the EEA.
• Transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries.  It makes sure those standards are similar to what is used within the EEA.

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 only those who have a strict 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

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 if we have a legitimate interest in retaining such information that is not outweighed by your fundamental rights and freedoms, where we have statutory or regulatory obligations to retain personal data for a longer period, or where we may need to retain the information in the event of a legal claim.

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.

9. Your rights

You have a number of rights under data protection law in relation to how we use your personal data.  These include the right, free of charge, to:

1. Be informed about the personal data we hold about you and how we use that information.
2. Obtain access to your personal data we hold.
3. Have any personal data that we hold about you that you believe is incorrect, incomplete or inaccurate updated or corrected.
4. Have your personal data erased.
5. Have our processing of your personal data restricted.
6. Object to our processing of your personal data.
7. Not be subject to wholly automated decisions, including profiling, which produce legal effects or which could have a similarly significant effect on you.
8. Lodge a complaint with the Data Protection Commission.

These rights are in some circumstances limited by Data Protection Law.  If you wish to exercise any of these rights, you can contact us using the details set out in section 1.

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.

10. Updates

We may update this privacy policy from time to time.  Any updates will be made available and, where appropriate, notified to you.