Privacy Notice
Who We Are
We are Ability Occupational Therapy of 44 Devon Park, Salthill, Galway.
You can contact us at this address by post or by email pauline@abilityot.ie
The data protection representative is Pauline Robinson who can be contacted at the above address or email address.
Purpose of this Notice
This notice explains how Ability Occupational Therapy (“we” or “us”) looks after the personal data we collect and process about you in connection with the services and functions of the organisation.
For the purposes of GDPR, Ability Occupational Therapy is the data controller, which means we are responsible for deciding why and how your personal data will be processed. This notice applies to prospective clients, recipients of occupational therapy assessment and/or treatment, visitors to the website and business to business communication. It is important that you read this notice so that you are aware of how and why we are collecting, processing, and storing your personal data.
Please be aware that this privacy notice may be updated in the future. The updated document will be posted on our website at www.abilityot.ie.
What Personal Data will Ability Occupational Therapy be Collecting?
Personal data is any information about you which allows you to be specifically identified.
How will Personal Data be Collected
Personal data will be collected and processed by Ability Occupational Therapy when you or a referrer (e.g. employer) or a health care professional (e.g. occupational health nurse) engage with us and/or avail of our services.
We collect personal data in the following ways:
When you provide your name and contact details via the enquiries form on the Ability Occupational Therapy website.
As part of our referral process when you or another individual (such as your employer or a health care professional) submits a referral form to the service
Personal data will be collected directly from you through your use of Ability Occupational Therapy assessment/treatment services. You may give us your personal data and special categories of more sensitive personal data including health data by corresponding with us by post, phone, email and/or meeting during any clinical assessment or treatment or otherwise.
Video footage and photographs may be taken during the assessment, however, these will only be collected and retained with your consent to do so.
Reports and/or referral letters containing personal data may be obtained at any stage of your involvement with our services. Consent will be obtained from you prior to request of any personal data from a third-party source.
Personal data may be collected from other professionals, relatives, third parties and agencies who have knowledge of or are involved in your care including assistive technology professionals, health care professionals or a family member. Consent will be obtained from you prior to request of any personal data from a third-party source.
Personal data may be collected when you become involved with us in any other way than as stated above, for example, such as a phone-call to the service.
When you provide us with your contact details such as a business card at events that we attend.
If you apply to join Ability Occupational Therapy.
How we use your Personal Information and the legal basis for doing so
Any personal data you provide will be used for the purpose for which you supply it, or the referral party provided, or as necessary for our business; and will be treated with the highest standards of security and confidentiality, strictly in accordance with General Data Protection Regulations.
Ability Occupational Therapy collects and uses your personal data to deliver Ability Occupational Therapy services, including assessment, treatment, case management or consultation service(s).
Personal data may be used for the following purposes:
To respond to your requests for information.
To consider your referral for assessment and/or treatment services of Ability Occupational Therapy.
To prepare a quote of delivering our services.
To liaise with referrers and other professionals and case workers.
To undertake and complete Occupational Therapy assessment and/or treatment services.
To share your information with third parties where this is required to provide our service to you, based on your prior consent, or is required by law.
For invoicing and billing purposes.
Business to business communication to make suggestions and recommendations about services that may be of interest to you.
To use your information lawfully, we rely on one or more of the legal bases, identified in the chart above.
Who Has Access to the Information We Collect?
Ability Occupational Therapy does not share your identifiable personal information with any third party except as necessary to operate services, and for which we will have obtained prior consent. On rare occasions information may need to be shared to fulfil legal and regulatory obligations, for example with revenue commissioners and other regulators, our accountant, our insurer, or An Garda Síochána.
Disclosure with your consent
Disclosure can be made with your explicit consent. This could be a request from an insurance company, employer, or legal proceedings request but any disclosure must be with, and limited to, the authority provided by you.
Disclosure without your consent
Disclosure can be made without your consent in two instances:
If the disclosure is required by law. For example, when ordered by a judge in a court of law, or by a tribunal or body established by an Act of the Oireachtas.
If the disclosure is in the public interest. For example, in circumstances where there is a threat of serious harm to yourself or others.
Processors Involved in Processing of your Personal Data
Ability Occupational Therapy uses Microsoft 365 Business services, specifically ‘Outlook’ for email, and ‘OneDrive’ for file storage. Microsoft 365 Business provide device management and data protection controls across the network and devices, to ensure data is kept secure. Microsoft data centre locations for the services used by Ability Occupational Therapy are within the European Union. Microsoft 365 Business offers controls such as privacy settings in Office applications and encryption of documents, which further helps in keeping stored personal data secure.
Ability Occupational therapy access IT support on occasion; however this business does not have access to personal information on our system.
Transfers of Personal Data to a Third Country
Ability Occupational Therapy will not transfer personal data to a third country.
How Long will Ability Occupational Therapy keep Personal Data?
Ability Occupational Therapy will securely store client clinical files for a period of 7 years from when the occupational therapy service has been completed, as per regulations. Paper files will be shredded, and electronic files will be deleted once the 7 year period is complete. The file may need to be kept for longer than 7 years if the information is required relating to an unresolved legal issue or other issue.
Other personal data will be retained by Ability Occupational Therapy for as long as it is required for us to discharge our obligations during the period of our interactions with you and for a reasonable period thereafter, subject to any request from you to remove or delete your data, having regard for any and all relevant legislation in force at that time. We do not hold personal data for longer than necessary.
Your Rights
You have the following rights under the GDPR, in certain circumstances and subject to certain exemptions, in relation to your personal data:
Right of access – you have the right to request a copy of the information that we hold about you.
Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
Right to erasure – in certain circumstances, you can ask for the data we hold about you to be erased from our records. If we have no lawful basis to retain your personal data your personal data will be deleted.
Right to restriction of processing – you have a right to request restriction of processing of personal data for particular purposes.
Right of portability – subject to certain restrictions, you have the right to have the data we hold about you transferred to another organisation where we hold it in electronic form. This right of data portability applies to:
- personal data that we process automatically (i.e. without any human intervention);
- personal data provided by you; and
- personal data that we process based on your consent or in order to fulfil a contract.
Right to object – you have the right to object to certain types of processing such as direct marketing.
Right to lodge a complaint - you have the right to lodge a complaint with the Irish supervisory authority, the Data Protection commission.
Right to withdraw consent- this does not affect the lawfulness of the processing that took place prior to the withdrawal. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
All of the above requests can be directed to the individual listed at the end of this notice. If you are unhappy with how we process personal data, we ask that you contact us so that we can rectify the situation.
Cookies
Cookies are small text files stored on a device and are commonly used on websites. We have set the settings on our website to prevent the website host from sending analytics cookies to visitors to the site until you have clicked ‘ok’ on the website cookie banner. For more information about the cookies we use, please see our Cookie policy.
Security
The internet is not a secure medium. However, we have implemented technology and policies to safeguard your privacy from unauthorised access and improper use.
Linking to Third Party Websites
We cannot be responsible for the privacy policies and practices of other sites, even if these sites have been accessed using links from our site. We recommend that you check the policy of each site you visit and contact the organisation concerned if you have any questions.
Requirement to Process Personal Data
In rare circumstances, the service cannot be provided if the personal data required to fulfil a contract is not given to Ability Occupational Therapy.
Automated Decision Making and Profiling
We do not use personal information for the purposes of automated decision making or profiling.
How to Contact Ability Occupational Therapy Regarding Personal Data
Should you have queries regarding this privacy policy or regarding any aspect of how your personal data is collected, processed, protected stored or disposed of, please contact Pauline Robinson (Owner/Occupational Therapist) at email pauline@abilityot.ie or by post at:
Ability Occupational Therapy,
44 Devon Park,
Salthill,
Galway,
H92 HKX6.