The Ford Counselling and Psychotherapy Centre Privacy Statement
When you become a client of The Ford Counselling and Psychotherapy Centre, we need to collect data about you. We keep this data securely. Except where required by law, or health and safety requirements, we will not share your data with anyone else. When you have finished with our services, we will delete your data after a certain period of time. The following pages set out the legal and contractual arrangement in place relating to data protection and privacy.
This Privacy Notice gives you some helpful information about who we are, what personal data we collect about you, why, who we share it with and why, how long we keep it, and your rights.
1.Who we are: The Ford Counselling and Psychotherapy Centre offers low to no cost counselling/psychotherapy and support services. Counselling is currently available to those who are over eighteen years.
The Ford Counselling and Psychotherapy Centre is a trading name for Family Life Service Ferns CLG.
Registered Office; C/O St Bridget’s Centre, 12 Roche’s Road, Wexford, Y35Y4EP.
Registered in Ireland. No: 333778, CHY No: 20068 Charity Reg No.20079413
2.What personal data we collect and why
2.1 Counselling: We collect and use your personal data in order to deliver counselling services:
(a) Contact details: Name, surname, address, date of birth, telephone number, email address. This is so that we can identify you, contact you to arrange or change appointments, locate your file, manage your file and your records confidentially. Your telephone number is given to the therapist to whom you have been allocated so that the therapist can contact you and set up an appointment etc. We process this personal data on the basis of your contract with the Ford Counselling and Psychotherapy Centre (or to take steps at your request prior to entering into a contract).
(b) Personal details, health data: We collect personal data about you and your health where same will assist in your therapy. This may include your relationship status, employment status, next-of kin/emergency contact details, type of counselling required or circumstances leading to counselling, name of your GP, name of any other Doctors or medical practitioners under whose care you are or have been, details of any medication you are on, medical history, details of any prior counselling, etc. This information is taken so we can assess your needs and prepare an assessment report to determine if you are suitable for counselling and what might be the best approach for our work with you. We process this on the lawful basis of the provision of health or social care Article 9(2)(h) as our counsellors and psychotherapists are designated as health and social care professionals under S.I. No. 170/2018 - Health and Social Care Professionals Act 2005 (Section 4(2)) (Designation of Professions: Counsellors and Psychotherapists and Establishment of Registration Board) Regulations 2018
We also use this data to compile statistics about our service, and these statistics are returned to TUSLA (see further (4.3) below for more information).
(c) Counselling Notes: Counselling is a safe and confidential space. Your counsellor will make brief notes during your therapy. At the commencement of the counselling session, you will be assigned a client code. The notes will use your client code (never your real name) to enhance your privacy. Counsellors/psychotherapists are required to have their work supervised for regulatory requirements, quality control, and to ensure the counsellor/psychotherapist is meeting best practice. This means that issues arising in your therapy may be shared with the counsellor/psychotherapist’s supervisor. We employ supervisors who provide mandatory group supervision and in addition each therapist must have an individual supervisor external to the Ford Counselling and Psychotherapy Centre. Each supervisor in addition to their supervision qualifications is a qualified counsellor/psychotherapist accredited by either IACP and/or IAHIP, is designated as a health and social care professional under S.I.170/2018 and is bound by a strict duty of confidentiality in their supervisory work. We process this on the lawful basis of the provision of health or social care (Article 9(2)(h) as our counsellors and psychotherapists are designated as health and social care professionals under S.I.170/2018.
(d) Counselling appointment details: We record the date of attendance of a counselling session, details of non-attendance if relevant (e.g. cancellation, excused, no-show etc). We process this personal data on the basis of your contract with the Ford Counselling and Psychotherapy Centre (or to take steps at your request prior to entering into a contract).
(e) Payment data: Where you make a contribution towards your counselling costs, we issue a receipt. We record details of fee paid and any receipts issued to comply with our legal requirements as a registered charity. Cash receipts and donation details are shared with our accountants and auditors to prepare audited financial statements for us to comply with our legal obligations as a registered charity. Appointment dates and fees are shared with our accountants and auditors for that purpose, however our accountants and auditors do not see client names or counselling notes: attendance notes and fee payments/receipts data are held under the client code. We process this personal data because it is necessary for compliance with a legal obligation (Charities Act 2009, Taxes Consolidation Act 1997 etc).
(f) End of counselling: At the end of the counselling relationship, the therapist prepares an exit document for the file.
(g) Events: Where you are undertaking a further education and training course or CPD for counselling professionals, with us, we may use your contact details to invite you to further events that may be of interest to you. We process this personal data on the basis of your Consent. Where you have given us Consent to contact you about events, you can withdraw that consent at any time.
2.2 Other data: depending on various issues, we may hold additional data relating to you. For example, if you ask your solicitor to write to us about matters, we may hold data relating to correspondence with your solicitor, documents relating to court proceedings, discovery or subpoena documentation etc. We use personal data for purposes including: delivering the counselling service; office administration; billing and accounts; running the Centre efficiently, complying with our legal obligations; allocating resources effectively across the Centre; complying with regulatory requirements (supervision, registration etc); to manage risk; for resolving disputes and taking/defending litigation etc. We process this personal data on the basis of our legitimate interests in running an efficient counselling service, and on the lawful basis of the processing being necessary for the establishment, exercise or defence of legal claims.
- How long we keep it: We retain counselling files for 7 years after the counselling relationship has ended in order for our counsellors/psychotherapists to comply with their professional indemnity insurance requirements. That period may be extended if some issue has arisen, e.g. if there are any particular issues relating to client care and/or regulatory standards, the records may be retained for engagement with the counsellor’s accrediting body (IACP and/or IAHIP) and for appropriate follow-up action. If any investigation/inquiry is under way by any statutory authorities (e.g. An Garda Síochána, TUSLA, HSE, etc.) or by any regulatory bodies (e.g. CORU, the Health and Social Care Professionals Council) in relation to any matter in respect of which the data held by the Ford Counselling and Psychotherapy Centre are required, those data will be retained so that Ford Counselling and Psychotherapy Centre can fully cooperate with all such investigations/inquiries and the data will be retained until all such matters are fully concluded. If proceedings are ongoing or are threatened the data will be retained in “legal hold “to ensure they are available to assist the administration of justice and pending the conclusion of all litigation matters.
- Who we share it with: The Centre provides a safe counselling space, and counselling is confidential. However, there are limits to confidentiality and we share personal data with third parties in certain situations to protect you and to protect others. In certain situations, we will share your personal data without your consent. For example, we share personal data where we are required to do so to comply with our legal obligations (e.g. mandatory reporting, duty of care), or where it is in our legitimate interests to do so. For the avoidance of any doubt, our reporting/disclosing your personal data in this manner does not constitute a breach of confidence.
4.1 Doctors/other health professionals etc:
(a) If in the therapist’s opinion you are at risk of harming yourself or someone else, the Centre reserves the right to contact your doctor(s) and/or other health professionals, and/or contact your family, and/or contact any other appropriate person or body (e.g. An Garda Síochána, TUSLA etc) so that steps can be taken to ensure your safety or the safety of others. In such circumstances, we will share your personal data with them where in our professional opinion it is necessary to protect your health or wellbeing (or to protect the vital interests of you or another person). In appropriate cases we will notify you that this is being done. We reserve the right not to notify you this is being done if that would put another person at risk.
(b) If in the therapist’s opinion you are in need of immediate assistance from your GP, psychiatrist or any other clinical/health professional, a referral shall be made by the The Ford Counselling and Psychotherapy Centre therapist so that steps can be taken to ensure your safety and wellbeing. Where possible, this will be done with your knowledge and agreement. We reserve the right not to notify you this is being done if that would put another person at risk.
Your therapist reserves the right to discuss these matters with the Manager of the Ford Counselling and Psychotherapy Centre.
4.2 Mandatory reporting: psychotherapists and counsellors are under a legal obligation to report child abuse, child sexual abuse, historical abuse, abuse of vulnerable persons, and to report where a child is at risk of harm to TUSLA (Children First Act 2015) and An Garda Síochána (Criminal Justice (Withholding of Information on Offences against Children and Vulnerable Persons) Act 2012). In the event that your therapist/The Ford Counselling and Psychotherapy Centre makes such a mandatory report we will not seek your consent. In appropriate cases we may notify you that this is being done unless to do so would put a child at risk. We reserve the right to consult with the Centre’s Designated Liaison Person (DLP) to ensure full and proper reporting is made to TUSLA and An Garda Síochána. We rely on all the protections within the Protection for Persons Reporting Child Abuse Act 1998. We comply with the following statutory guidance and professional codes:
- Children First’: National Guidance for the Protection and Welfare of Children: Department of Children and Youth Affairs 2017,
- Code of Ethics and Practice: Irish Association for Counselling and Psychotherapy (“IACP”), and
- Code of Ethics and Practice for Psychotherapists: Irish Association of Humanistic and Integrative Psychotherapy (“IAHIP”).
- Code of Ethics and Best Practice The Ford Counselling and Psychotherapy Centre 2019.
4.3 TUSLA: The Ford Counselling and Psychotherapy Centre receives funding from TUSLA, and as a condition of our funding agreement we are required to provide statistical returns to TUSLA about the counselling services delivered through the Association for Agency based Counselling and Psychotherapy in Ireland. This means that TUSLA receives the following statistics form The Ford Counselling and Psychotherapy Centre.:
(a) Number of client sessions attended
(b) Number of client sessions cancelled
(d) Funder of session
(e) Presenting issues
(f) Relationship status
(g) Age category
(h) Referral source
(i) Employment status
(j) Risk assessment.
(l) Length of waiting list.
TUSLA does not obtain individualised client data. The above statistics are provided in numerical form only, and no client names/addresses/PPS numbers/date of birth are disclosed to TUSLA.
4.4 Counsellor’s supervisor: as discussed above, issues arising in your counselling sessions may be shared with your professional supervisor. Any reference to your presenting issues will use your client code (never your real name) to enhance your privacy. The with whom the issues arising may be those employed by The Ford Counselling and Psychotherapy Centre. Each supervisor is a qualified counsellor/psychotherapist accredited by either IACP and/or IAHIP, designated as health and social care professional under S.I.170/2018, and is bound by a strict duty of confidentiality in their supervisory work.
4.5 Therapists in training and their accrediting bodies: where therapists-in-training are undertaking certain academic courses they will be required to share some of their work with their accrediting university. Your therapist will inform you if he/she is in training. Where the sharing of work involves client case studies, sharing will only occur where it is ethical to do so and where the client has Consented to same. This will be discussed in advance with the client, and sharing will only occur where the client has confirmed it is OK to do so and has signed a Consent Form for that purpose.
4.6 Your solicitor: You can make a data access request to obtain a copy of your personal data at any time. If you instruct your solicitor to make a data access request to us, and where they furnish us with a copy of your written authority for us to do so, we will send data access request documents to your solicitor.
4.8 Court proceedings and/or administration of justice: The Ford Counselling and Psychotherapy Centre complies with court orders, discovery orders, subpoenas, etc.
4.9 Accountants, Auditors, Revenue, CRA: Appointment dates, cash receipts and donation details are shared with our accountants and auditors for us to comply with our legal obligations as a registered charity to prepare audit financial statements. No names are disclosed and the client reference number is used. Information is also returned to the Revenue Commissioners for audit and verification purposes. Our financial records and donations information can be audited by the Charities Section of the Revenue Commissioners and/or the Charities Regulatory Authority at any time for regulatory compliance.
4.10 Insurance company and our legal advisers: We may share your information with our insurance company, our legal advisers, and other service providers (including IT providers, security providers, etc) to enforce our legal rights, and to resolve disputes and defend litigation.
4.11 An Garda Síochána: We will share your personal data with law enforcement bodies including An Garda Síochána where it is necessary for the detection, investigation and prosecution of offences. For example, if a client is threatening or abusive to any member of staff or another client, we will report the matter to An Garda Síochána, transfer any relevant data to them, discontinue the provision of therapeutic treatment to the client and terminate the counselling contract with that client.
4.12 Funding bodies: We will share statistical information (e.g. number of service users, numbers of counselling sessions delivered etc) with our funding body, TUSLA. Statistical information is also included in our annual report which is published on our website. If you would like further information about who we share your data with, please contact us.
- Third country transfers: In general we do not transfer your personal data outside the EEA.
- Your rights: You have the following statutory rights that can be exercised at any time:
(a) Right to complain to supervisory authority.
(b) Right of access.
(c) Right to rectification.
(d) Right to erasure.
(e) Right to restrict processing.
(f) Right to data portability.
(g) Right to object, and to object to automated decision making/profiling.
For further information, please contact us. Please note that if your solicitor requests a copy of your counselling notes, we will require him/her to forward your written Authority and such information/documents as may be necessary to verify your identity before we will release anything to your solicitor. Where such notes are required for a particular date, it is your obligation to ensure these are requested in reasonable time to give the Ford Counselling and Psychotherapy Centre adequate time to facilitate your request. Unfortunately, due to the demands on our voluntary service, we cannot facilitate last-minute requests for documents.
- Contact us: if you need further information, please contact the Manager, The Ford Counselling and Psychotherapy Centre, C/o St Bridget’s Centre 12 Roche’s Road Wexford
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