GENERAL DATA PROTECTION REGULATION (GDPR) – PRIVACY NOTICE

SCOPE

This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.  The General Data Protection Regulation (GDPR) which is EU wide and far more extensive than its predecessor the Data Protection Act, along with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of EU data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU and its storage within the EEA.

 WHAT IS PERSONAL INFORMATION

 

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. This can include names, phone numbers, addresses, email addresses, images etc.

SPECIAL CATEGORY INFORMATION

 

Special Category information includes information about your physical or mental health, from notes and reports about your health and any treatment and care you have received or need, or it may be recorded in details of contact we have had with you.

HOW WE COLLECT PERSONAL INFORMATION

We collect personal information from you and from third parties (anyone acting on your behalf, for example, solicitor, government bodies, etc.) or indirectly from documents provided by them, including reports from expert witnesses

We collect personal information from you through your contact with us via phone email, our website or by post. We also collect information from other people and organisations. 

We may collect information from a family member or someone acting on your behalf; doctors, clinicians, health care professionals, hospitals, clinics and other health care providers; and any service providers who work with us in relation to your service.  

WHAT WE USE YOUR INFORMATION FOR

Confidentiality and consent to treatment are core values of our professional practice and we provide a professional psychological service. Any information disclosed will be treated with respect and will be confidential, unless we have serious professional or ethical reasons for not doing so, in which case we will discuss this matter with you.

We use your personal information only for “legitimate interest purposes” set out in this privacy notice. 

We process standard personal information about you if this is necessary to provide the services set out in a contract, if this is in our or a third party’s legitimate interest, or if this is required or allowed by law.  

We process special category information about you because it is necessary for the purposes of health prevention, assessment and treatment services;

 LEGITIMATE INTEREST PURPOSES

 

CS Aistear Ltd will only collect the information needed so that we can provide you with the services you require.  The business does not sell, broker, outsource of make any profit from your data.

For administrative purposes: For the purposes of booking an appointment, all patients will need to provide personal information, including their title, name, surname, date of birth, address, telephone number, mobile number and email address. Contact details provided by you such as telephone numbers, email addresses, postal addresses may be used to remind you of future appointments and provide reports or other information concerning your treatment.

For psychological purposes: During the consultation, psychologists elicit detailed personal, medical and other psychologically relevant information. We will only collect what is relevant and necessary for your treatment. This data is always held securely, is not shared with anyone not involved in your treatment, although for data storage purposes it may be handled by administrative staff who have all signed an integrity and confidentiality agreement. To be able to process your personal data it is a condition of any treatment that you give your explicit consent to allow psychologists to document and process your personal medical data.

CONSENT

 

Before you see a psychologist, you will be provided with relevant GDPR Terms and Conditions, which you will be requested to read, consent to and sign. 

YOUR RIGHTS AS A DATA SUBJECT

At any point whilst CS Aistear Ltd is in possession of, or processing your personal data, all data subjects have the following rights: 

Right of access: You have the right to request a copy of the information that we hold about you. 

Right of rectification: You have a right to correct data that we hold about you that is inaccurate or incomplete. 

Right to be forgotten: In certain circumstances you can ask for the data we hold about you to be erased from our records. 

Right to restriction of processing: Where certain conditions apply you have a right to restrict the processing.

Right of portability: You have the right to have the data we hold about you transferred to another organisation.

Right to object: You have the right to object to certain types of processing such as direct marketing, but this does not apply here because we do not engage in any direct marketing.

Right to object to automated processing, including profiling: You also have the right not to be subject to the legal effects of automated processing or profiling. 

Limitation:  In the event that CS Aistear Ltd refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge. At your request CS Aistear Ltd can confirm what information it holds about you and how it is processed. 

YOU CAN REQUEST THE FOLLOWING INFORMATION

You can request the following information: 

Identity and the contact details of the person or organisation (CS Aistear Ltd) that has determined how and why to process your data.  

Contact details of the data protection officer, where applicable.  The purpose of the processing as well as the legal basis for processing. 

If the processing is based on the legitimate interests of CS Aistear Ltd and information about these interests. 

The categories of personal data collected, stored and processed. 

Recipient(s) or categories of recipients that the data is/will be disclosed to. 

How long the data will be stored. 

Details of your rights to correct, erase, restrict or object to such processing. 

Information about your right to withdraw consent at any time. 

How to lodge a complaint with the supervisory authority (ICO). 

Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data. 

The source of personal data if it wasn’t collected directly from you. 

Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

DATA SECURITY AND PROTECTION

We ensure the security of any personal information we hold by using secure data storage technologies and precise procedures in how we store, access and manage that information. Our methods meet the GDPR compliance requirement.

HOW CAN I ACCESS MY PERSONAL DATA

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.  

Subject Access Request: All subject access requests should be made in writing and sent to the email or postal addresses shown.  There is a nominal administrative charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) further fees may be charged to cover our administrative costs in responding.  We will respond to your subject access request within 40 working days of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of progress. 

Limitations: In some cases, where you are involved in litigation and access to your data may undermine a medical legal case, it may be necessary to inform the solicitors and the Court involved in the case, and their approval sought, before such data can be provided. Claimants should note that in a medical legal case the solicitor requesting the assessment (and ultimately the Court) is also the data controller in a legal case and therefore a subject access request may have to be made to more than CS Aistear Ltd for access to the data it holds on you and may be denied by the solicitor or the Court if access to that data, at that time, may undermine a legal case.

What are my rights?

Under the GDPR, you have the right to access the information we hold about you.  If you find that any of the information is incorrect, you also have the right to have it changed.  You can also request to have your records erased.  When we receive your request, we will comply with that within one month of receiving it.

Your Rights