Éilís McIntyre, Counsellor, Reg. MBACP (Accred.) & Life Coach.
ICO Registration Reference: ZA284655
The European Union’s General Data Protection Regulation (GDPR) came into effect on 25th May 2018. This policy explains your rights in respect of my Counselling and Life Coaching services.
Who I am:
I am a qualified Professional Counsellor and Life Coach. I am the Data Controller and Data Protection Officer within my Counselling and Life Coaching services.
Gaining your consent:
When you contact me or avail of my counselling /life coaching service, I will tell you how your information will be used and the circumstances when it may be necessary to share this information with other services.
If you do not want me to share your information, you should let me know, however, there may still be exceptional circumstances in which I would have to share information with an appropriate third party, due to legal or ethical requirements. These exceptional circumstances are:
If I have grounds to think that you may cause serious harm to yourself or to others.
If a Court instructs me to disclose information.
If you disclose any criminal activity or knowledge of criminal activity.
If I have grounds to think that a child or a vulnerable adult may be at risk of harm.
Information that I may record:
First name and surname/family name
Age/date of birth
Sensitive Personal Information:
Gender, ethnicity, and marital status
Religious or other cultural beliefs
Mental health conditions
Physical health conditions
Sexuality and sexual orientation
Offences (including alleged offences)
Third Party Information:
Name of your Doctor (GP) or other medical practitioners.
Name, address, and telephone numbers of your GP Surgery.
Names and addresses of other appropriate third parties in relation to safeguarding requirements.
Names and addresses of other counselling/mental health support services you have previously attended or are referred on to.
Name of your employer
My reasons for collecting and processing your data:
I collect and process your personal information so that I may be able to provide and manage my Counselling and Life Coaching services.
The Legal basis for processing your information is a combination of contract and legitimate interest.
How I record and store your data:
I record information both electronically and manually. A client reference number will be used on your counselling or life coaching notes file which will be filed in a separate locked filing cabinet to that which holds your identifiable information. The filing system is securely stored. Information on electronic devices is password or encryption protected.
Please remember that, while I use commercially acceptable means to protect your data, no method of transmission over the internet, or electronic storage, is guaranteed to be 100% secure.
If you avail of counselling with myself on referral from an Employee Assistance Programme (EAP) provider (that I have affiliation with) or from Onebright Ltd, I will process your information in relation to the policies and procedures of the relevant referral agency.
If you avail of counselling with myself as a Bupa member, I will process your information as per the policies and procedures outlined by Bupa for Bupa Providers.
Online and Telephone Counselling & Life Coaching:
I use third party services for online and telephone counselling & life coaching. EE is my mobile telephone provider. Microsoft Teams and zoom.us are used for my online meetings. Any data required to connect with these services would be governed by the privacy policies of EE, Microsoft, and zoom.us.
I use Gmail for my work correspondence, and ProtonMail when encrypted correspondence is required. When also required, I use e-signature and encryption tools ('Frama Rsign' & 'Frama Rmail'), provided by Frama UK Ltd.
Please note: Receipts are generated when 'Frama Rsign' and 'Frama Rmail' are used. The additional information recorded includes:
Date & time delivered/opened/signed
This information will be stored securely in the file holding your identifiable information.
Any data provided in the use of these would be governed by the privacy policies of Google, ProtonMail, and Frama UK Ltd.
How long I keep your data:
I will keep your personal information no longer than necessary for the purpose it was originally collected. Personal data is held up to seven years unless a longer time-frame is required for legal reasons, or to respond to questions/complaints in respect of the service(s) I have provided.
I will keep email messages (sent directly or via a counselling website/directory), texts, and voicemail messages only as required. If there is no further contact within seven days after an initial enquiry, your message will be deleted.
Manually held information will be shredded when the required retention period has ended.
Promoting my Services:
I use Wix.com for my website.
Feedback and Complaints:
You can let me know if you think that my collection or use of your information is unfair, misleading, or inappropriate by contacting me at email@example.com.
If you want to make a complaint about the way I have processed your personal information, you can contact the ICO as the statutory body which oversees data protection law - https://ico.org.uk
You can request a copy of your personal information, in writing to firstname.lastname@example.org, and once I have received your request I will respond within 30 days, free of charge.
You can request that I pass your personal information on to other organisations in a format that is easy to read and re-use.
You can request the correction of any information held about you that you believe to be inaccurate. If I have grounds not to make the correction, your request and viewpoint will be recorded.
You can request that I erase the personal information I hold on you. On receiving a request to erase personal information, I will confirm with you that your personal information has been erased or will explain the reasons why I cannot comply with the request.
You have the right to make a complaint. In the case where I receive a complaint against me, the information I hold about you may need to be made available to the relevant professional bodies.
NB: Proof of identity would be required in relation to the above requests.
For more information about your rights, please visit the Information Commissioner’s Office (ICO) website: https://ico.org.uk
Changes to this policy:
I will need to update my Privacy Notice as, and when required.
Updated 2nd August 2022