Privacy Policy Think Well Psychotherapy Clinic
Effective Date: 6 June 2023

At Think Well Psychotherapy Clinic, we are fully committed to protecting the privacy, dignity, and trust of everyone who engages with our services. Our data protection practices are grounded in the ethical principles of the Irish Association for Counselling and Psychotherapy (IACP), the British Association for Counselling and Psychotherapy (BACP), and the Irish Association of Humanistic and Integrative Psychotherapy (IAHIP). We operate in full compliance with the General Data Protection Regulation (GDPR) (EU) 2016/679.

This policy outlines how we collect, store, use, and protect your personal data, and the rights you have in relation to that data.

1. Data We Collect
We collect only the personal data that is necessary for the ethical and effective provision of psychotherapy. This may include:
• Name, address, email address, and telephone number
• Date of birth
• General Practitioner and emergency contact information
• Medical or psychological history relevant to your care
• Session notes and clinical documentation
• Signed consent forms and therapeutic contracts
• Correspondence through email, text, phone, or online platforms

2. Legal Basis for Processing
We collect and process personal data under the following lawful bases, as defined by GDPR:
• Consent: We obtain your clear and informed consent at the outset of our work
• Contract: Data is processed in order to fulfil our professional agreement with you
• Legitimate interest: Data may be processed for the provision of continuity of care and ethical clinical practice
• Legal obligation: In specific circumstances, we may be required to process or disclose data as required by law

3. How Your Data is Used
Your data is used for the following purposes:
• To deliver safe and appropriate psychotherapy
• To assess your needs and ensure continuity of care
• To contact you regarding appointments and scheduling
• To document and support clinical decision making
• To engage in professional supervision, always in an anonymised and protected format
• To comply with legal, ethical, and regulatory requirements

4. Confidentiality and Disclosure
All personal data is treated as confidential and is not shared without your express permission, except in the following circumstances:
• If you give explicit written consent for information to be shared with another professional
• If there is a serious risk to your safety or the safety of others
• If there is a legal obligation to disclose information, for example, under a court order
• If required by safeguarding protocols concerning children or vulnerable adults
• In supervision, where all identifying details are removed

5. Storage and Retention of Data
All client records, including clinical notes, are held in strict accordance with the codes of ethics of the IACP, BACP, and IAHIP, as well as in compliance with our professional indemnity insurance requirements.

Clinical notes are maintained in a secure and protected manner. They are stored either in encrypted digital systems or in locked filing systems, accessible only to authorised clinical staff. These notes are used solely for the purpose of supporting your therapeutic care.

Client records are retained for a period of seven years following the conclusion of therapy, after which they are securely deleted or anonymised, in accordance with professional guidance.

All data-related queries and responsibilities are managed by our appointed Data Manager.

6. Your Rights Under GDPR
Under GDPR, you have the following rights regarding your personal data:
• The right to access the personal data we hold about you
• The right to request correction of inaccurate or incomplete data
• The right to request erasure of your data, where appropriate
• The right to restrict or object to data processing in certain circumstances
• The right to withdraw consent at any time
• The right to lodge a complaint with the Data Protection Commission (Ireland) if you believe your data has been mishandled

7. Website and Online Engagement
Our website may collect anonymised usage data to monitor traffic and improve services. We do not use intrusive cookies or share any visitor information with third parties. Any online contact form is protected by encryption and is used only for administrative purposes related to your enquiry or care.

8. Contact Information
If you have any questions or concerns regarding this policy or the handling of your personal data, please contact our Data Manager:

Data Protection Officer
Think Well Psychotherapy Clinic
1 College Street
Mullingar, County Westmeath
N91 W622
Email: care@thinkwell.ie
Website: www.thinkwell.ie