• Introduction

In Resolve Counselling we collect, store and process date that is necessary for the provision of our support services.
The categories of data which we process are listed below. We process this data to make sure you can use our services effectively and efficiently. We may also process data to send you communication emails regarding your bookings. You can opt out of these communications at any time (see section 3 Data Retention, Erasure, and Exporting below).

• Data Collection

We collect and Process “Therapy Data “, which includes health and treatment information that is required to facilitate therapy. The following is a breakdown of the different types of data and what it is used for:

• Data Sharing
  • Who we share your data with.

Here’s some more information about the purposes for which we may need to share your data with persons other than your counsellor:
Resolve Management:
As part of the assessment and onboarding process your data will initially be collected by a Resolve Management team member to refer you to your counsellor. The Resolve Management team members are also practicing counsellors and as such are held by the same confidentiality laws as your counsellor. Your information is also accessible to management for the purpose of ensuring ethical and professional standards and compliance.
Resolve Administration/Accountant:
Occasionally, your data may be used by Resolve Administration for purposes of collating information to provide receipts and statements of fees. Further to this payment and booking information is used for accounts purposes.
B2B Clients:
On occasion, if you have been referred through one of our business partners, data surrounding session uptake, demographics, referral concerns and outcomes may be shared, however this information will be anonymised using a PIC (Personal Identifiable Code).
Online Booking and Management System:
Your data is kept on our secure online management booking system, Writeupp. This site is only accessible by our team, through secure invite using a password and is GDPR compliant. All booking communications and forms are provided through this secure encrypted system, as well as our online counselling service.
Courts:
Your data may be shared to comply with applicable laws. For example, a court might subpoena information from us, this is where we would be required to share certain information requested in the subpoena. Keep in mind, that we will only share data or reports with a subpoena or court order. We have strict rules governing Therapist/Client relationships and the confidentiality requirements associated with that, which is noted in client contract, and this will be discussed in detail with your counsellor at your first session, we encourage you to discuss this with your counsellor if you have concerns about their disclosure obligations.
Billing and payment processing Service Providers:
We use Sumup & Paypal to help process payments in a secure way. For this purpose, we may share email addresses/phone number with Sumup and other data that is needed to send payment links.
Third Party Service Providers
Third party service providers which we use may utilise some of your data as outlined below, please see their individual Privacy policies available through them for more detailed information, these include:

• Webhosting Ireland: Website, Data hosting and storage providers, website page usage and emails
• WriteUpp: Business management and booking system.
• Sumup: Used for POS sales and online sales.
• Paypal: Used for online sales.
• Payhip: Online shop used for the purchase of online products.

• • How do we use your data to comply with the law?

When required by law, we cooperate with government agencies. For example, as mentioned above, a court might subpoena information from us where we would be required to share certain information requested in the subpoena.
You should also be aware that Counsellors may be obliged to disclose information to authorities or next of KIN to meet professional and legal responsibilities. Specifically, mental health professionals may be required to disclose information and/or take action for: (a) reported or suspected abuse; (b) serious suicidal potential; (c) threatened harm; and (d) court-ordered treatment. While this is all covered in your Client Contract and at your first session you should speak with your Counsellor if you have concerns about this.

• Data Retention, Erasure, and Exporting

The following sections describe both how long a client can expect their data to be retained for given specific account information as well as how to request data erasure and access. In this Policy, data erasure is defined as the permanent removal or obfuscation of identifiable data so that it is no longer accessible by anyone, (Please see GDPR Section 6 below for further clarification on your rights)

4.1 Retention Policy
Resolve is committed to ensuring that all data is retained only for the amount of time required in accordance with relevant legal requirements. Client data is required to be kept for 7 years after which time all data will be deleted from our systems.
4.2 Exercising Your Data Protection Rights:
As stated, you have certain rights under data protection laws, including the right to request a copy of it. The following sections describe how you can exercise this right.
4.3 Requesting Data Erasure:
While it is compulsory to retain mental health records for a period of 7 years, it is not possible to erase your data prior to this. However, after a period of 7 years you can request confirmation that your data has been erased.
To request data erasure confirmation, please directly contact our Data Protection Officer at security@resolvecounsellingcentre.ie . We will only comply with a request for the erasure of your data after 7 years and if we can verify your identity.
Requirements:

• Only you or in case of under 18’s, your Next of Kin, may make a request on your behalf.
• You must provide sufficient information that allows us to reasonably verify your identity or status as an authorized representative.
• You must provide details that allow us to understand, evaluate, and respond to your request.

4.4 Requesting a copy of your data.
To receive a summary copy of your data, please email us to request a ‘Subject Access Request Form’.  Once this form has been received, will normally send you a copy within one month of your request. However, that period may be extended by two additional months where necessary, considering the complexity of the request or the difficulty in accessing the data that you request. There is usually no charge. In exceptional circumstances however, we may charge a reasonable fee after discussing the fee with you.
The data you will receive as part of this request includes the contact information, questionnaire answers, worksheet entries, emergency contact information, counsellor notes, and other personal information.
We will only comply with a data request if we can verify your identity.
Requirements:

• Only you or in case of under 18’s, your Next of Kin, may make a request on your behalf.
• You must provide sufficient information that allows us to reasonably verify your identity or status as an authorized representative.
• You must provide details that allow us to understand, evaluate, and respond to your request.

• Security and Anonymity

• •  Keeping your Data secure

We apply industry standards and strive to apply best practices to prevent any unauthorized access and disclosure. Our systems utilise, encryption technology, and are GDPR compliant. Our system, operation and processes are all designed, built, and maintained with your security and privacy in mind.
Resolve has a dedicated and experienced cyber security and data protection officer whose job it is to make sure we use secure technology to protect your data.
We have numerous robust security practices such as:

• All communications between a client’s and their counsellors are secure.
• Our browsing encryption system (SSL) follows modern best practices.
• Our databases are encrypted and scrambled rendering them useless in the unlikely event that they are stolen or inappropriately retrieved.

For your own security, keep the following in mind:
Phishing: This is a type of online identity theft or account hacking. We will never request your login information(counsellors) or credit card information(clients) in any non-secure or unsolicited communication. All personal identifiable information and clinical data is through our secure writeup system. You should always be diligent when you are asked to provide your account information and make sure it is in our secure system.
External links: Occasionally, for therapeutic or psychoeducation purposes counsellors may share external links with you. We do not control external websites, and do not have control over their privacy policies and terms of use. The fact that we link to a website is not an endorsement, authorization, or representation of our affiliation with that external party or of their privacy and security policies or practices.

• • Who can see the interactions you have with your Counsellor?

Only your counsellor can see the messages you send, forms or worksheets you fill in, no other counsellors in Resolve have access to this information.
Management also have access to this information for compliance and to ensure maintenance of ethical and professional standards.

• • How can I stop receiving reminder emails.

You can opt out of reminder emails by asking your counsellor or email us at info@resolvecounsellingcentre.ie. Please remember, that the 24hr cancellation still applies even when opted out of reminder.

• • Children’s Data

Resolve clients under the age of 16 years are subject to the same data protection and privacy laws by way of their Parents/Legal Guardians (Next of Kin as set out in writeup). Consent from all legal guardians is necessary prior to any therapeutic interventions beginning (see Resolve Child Protection & Safeguarding Policy for more information).

• Cookie Policy
  • What is a cookie?

A “cookie” is a small data file that is accessible within a folder on a computer, and it is used for record-keeping purposes. Cookies are used to enhance performance websites, personalize your experience. For example, cookies may be used to help you quickly log into certain platforms and websites without having to enter your credentials every time.

• • What are you using cookies for?

Cookies help to deliver a faster and safer online browsing experience, they can also be used to monitor and analyse usage, to comply with laws.

• • What cookies do we use?

When you visit our site, you have the option to accept or reject cookies. To find out which cookies are set when you either agree or reject them, you can check using your web browser tools, as cookies used can differ based on your preferred browser application eg explorer, google etc. Here’s how you can do it:

• Open Developer Tools: In most web browsers, they can do this by right-clicking on the webpage and selecting “Inspect,” or by pressing F12 on their keyboard.
• Navigate to the “Application” Tab.
• Check Cookies: Within the “Application” tab, you should find a section labelled “Cookies” where you can see the cookies set by the website.

• General Data Protection Regulation (GDPR)

This section provides additional information about our Policy relevant to specific legislation according to General Data Protection Regulation (GDPR)

• • When is your data used?

Your data is only used when it is required due to legitimate interests or an external third party’s legitimate interests (“legitimate interest” is a term defined by the General Data Protection Regulation (GDPR)). Our legitimate interests in this instance include managing the business, providing counselling and other therapeutic services, safety and security of the infrastructure, prevention of fraud/loss of sales, business development, management of B2B contracts and legal claims.
When it is necessary to do so to comply with any legal obligations imposed upon us under our contractual obligations or our contractual obligation or applicable law.
In rare instances, when it is a medical emergency, we may use your data to protect your or another’s vital interests if consent is not a reasonable option.
When you have consented to the use of your data, through the use of cookies and web beacons. Where consent is the legal basis, you have the right to withdraw your consent at any time.

• • What is the Lawful Basis for Sensitive Data being processed?

Resolve may also collect and Process certain categories of personal information, which may be considered “sensitive personal information”. The lawful basis for collecting or processing this information is:
(1) Provision of Mental health services.
(2) The establishment, action, or defence of a right or legal obligation,
(3) Substantial public interest, i.e. referrals through a B2B client.
(4) Consent.
Sensitive personal information that we Process may include but is not limited to your racial or ethnic origin, religious or philosophical beliefs, health, medications, diagnosis, or sexual orientation. This information is only ever processed with your consent and never shared with third parties in a way that makes it identifiable to you.

When you begin to use our services and are set up on our system, we ask you to provide answers to assessments and intake forms, to match you with a counsellor and provide counselling or related services to you. In providing your responses to the questionnaire you may provide us with “sensitive personal information” as described above. You may also continue to share such data with us as you receive services. This data is necessary as it allows us to continue provide continuity and professionality of service and best practice.

• • What are my rights under GDPR?

European residents have specific rights regarding their data. This section describes your rights if you are resident in the EU and explains how to exercise those rights:
Subject access request: You may be entitled to ask us for a copy of any data which we hold. We will normally send you a copy within one month of your request. However, that period may be extended by two additional months where necessary, considering the complexity of the request or the difficulty in accessing the data that you request. There is usually no charge. In exceptional circumstances, we may charge a reasonable fee after discussing the fee with you.
Right to rectification: If the data we hold about you is inaccurate, you may request rectification. The data will be checked, and, where appropriate, inaccuracies will be rectified.
Right to erasure: Unfortunately, in the health care system we are bound by Law to hold onto your data for a period of 7 years, after which it will be destroyed.
Right to data portability: In certain circumstances, you may wish to move, copy, or transfer the electronic data that we hold about you to another organization.
Right to object: You may object to your data being used for direct marketing however we do not do this in Resolve. You may object to the continued use of your data in any circumstances where we rely upon consent as the legal basis for Processing it, however this would impact our ability to be able to support you and may require counselling to be terminated.

• • Additional Privacy Notice for non-EU residents.

As a part of our standard business practices, data may be transferred outside of Ireland. Fortunately, given the robust and rigorous nature of privacy laws in the EU(GDPR) with which we comply, Resolve considers that this has the effect of protecting user information in a way that, overall, is at least substantially similar or in many ways exceeds data privacy legal requirements of other non-EU countries. We ensure that any third parties which we may contract with are also GDPR compliant.

• Contact us.

You can contact our Data Protection Officer with questions, about this Policy, or about your data to security@resolvecounsellingcentre.ie
While we’ll always work with you to resolve any concerns you have about the use of your data, under GDPR you have the right to lodge a complaint with the supervisory authority in your country of residence if you have any concerns about our use of your personal information.