PRIVACY POLICY

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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.

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Who I am:

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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.

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You can contact me by email at eilismcintyre.belfast@gmail.com or eilismcintyre.coaching_counselling@proton.me

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Gaining your consent:

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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.

 

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Information that I may record:

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Personal Information:

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• First name and surname/family name

• Residential address

• Telephone numbers

• Email

• Age/date of birth

 

Sensitive Personal Information:

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• Gender, ethnicity, and marital status

• Religious or other cultural beliefs

• Mental health conditions

• Physical health conditions

• Sexuality and sexual orientation

• Offences (including alleged offences)

• Financial information

• Employment status

 

Third Party Information:

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• 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

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My reasons for collecting and processing your data:

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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.

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How I record and store your data:

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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.

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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.

 

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Service Providers:

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If you avail of counselling with myself on referral from Abate Counselling & EAP Ltd, or via Irish Online & Psychotherapy Service (IOCPS), I will process your information in relation to the respective policies and procedures of Abate Counselling & EAP Ltd and IOCPS. ​

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If you avail of counselling with myself as an Aviva, Bupa or Vitality Health member, I will process your information as per the policies and procedures outlined by Aviva, Bupa and Vitality Health.

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​Online and Telephone Counselling & Life Coaching:

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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.  

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Communication:

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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.  

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Please note:   Receipts are generated when 'Frama Rsign' and 'Frama Rmail' are used.  The additional information recorded includes:

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• Date & time delivered/opened/signed

• IP address

• E-signature

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This information will be stored securely in the file holding your identifiable information.

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Any data provided in the use of these would be governed by the privacy policies of Google, ProtonMail, and Frama UK Ltd.

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How long I keep your data:

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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.   

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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. 

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​Manually held information will be shredded when the required retention period has ended.

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Payments:

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I provide paid-for services and use a third-party service for payment processing when paid by cheque, electronic bank transfer or 'Paym'.   Ulster Bank Ltd is the payment processor I use, and your personal information would be governed by that bank’s privacy policy. 

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Promoting my Services:

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I use Wix.com for my website.

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The logos displayed on my website in respect of The British Association for Counselling & Psychotherapy (BACP) and The Association for Coaching (AC), have hyperlinks to the relating Association's own website.   Any data provided in visiting these websites would be governed by each Association's individual privacy Policy.

 

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Feedback and Complaints:

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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 eilismcintyre.coaching_counselling@proton.me.

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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

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Your rights:

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• You can request a copy of your personal information, in writing to eilismcintyre.belfast@gmail.com, 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.

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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 

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Changes to this policy:

I will need to update my Privacy Notice as, and when required.

 

Updated 1st November 2022