PRIVACY POLICY

EU GDPR PRIVACY POLICY
Helen Bradley Coaching

INTRODUCTION
Helen Bradley Coaching is committed to protecting and respecting your privacy. This Privacy Policy explains how I use the personal data I collect from you, in accordance with the EU GDPR (2016/679) and the Data Protection Act 2018. Personal information is any information related to a person who can be identified either directly or indirectly through that information.

This online Privacy Policy relates to personal information which I collect through my website
www.helenbradley.ie and associated technologies, including personal information which is
collected electronically. By willingly providing personal and other information to me, you are consenting to the terms and conditions of this Privacy Policy.

WHAT DATA DO I COLLECT?
When you browse my website www.helenbradley.ie, I may collect information about you, such as the website you came from, IP address, your browser type, the country where your internet service is located, the pages of my site that were viewed during your visit, and search terms you used. This information is only used for my own research and to improve my service to you.

Your IP address is used to gather local broad demographic information. To measure the effectiveness of my online presence, Helen Bradley Coaching may use Cookies to determine the path users take on my site and to identify repeat visitors to the website.

I collect personal information from you when you register on my website, either by email, or when you complete and submit any of my online forms. Additionally, when you subscribe to my newsletters and to my emailing list, I will collect personal information. When you make a booking for any of my services, particular categories of personal data are collected and processed. The categories of personal information that I process include your name, email address, postal address, phone number.

To safely provide a service to clients, I require clients’ personal details including, but not limited to, name, age, contact details, personal relationships, family history, significant life events and any involvement of other services and/or professionals. I keep brief notes for my own use and maintain case notes, recording factual information, after each session. These are stored securely in a locked cabinet and shredded before disposal.

HOW I USE YOUR DATA
In accordance with EU GDPR legislation, I will rely most commonly on the following legal bases to collect and further process your personal information: Consent, Contractual Necessity, Legal Obligation, Legitimate Interest, Public Interest.
I may engage with third-party stakeholders and working partners for the following purposes:
To facilitate the delivery of my products and services;
To perform related services; or
To assist me in analysing how my products and services are used.
I may process your personal information for more than one lawful basis depending on the specific purpose for which I am using your personal information.

DO I USE COOKIES?
I use Cookies on www.helenbradley.ie. Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. When you visit my website, I may collect information from you automatically through Cookies or other similar technology.

I use Cookies to enable core functionality, such as security, network management and accessibility. You can set your browser not to accept Cookies and can remove Cookies from your browser. If you do, some of my website features may not function. For full information on my use of Cookies, I refer you to my separate Cookie Policy which you will find on my website www.helenbradley.ie.

THIRD PARTY SITES
My service may contain links to other sites. If you click on a third-party link, you will be directed to that website. My privacy policy applies only to my website, so if you click on a link to another website, you should read their privacy policy.

INTERNATIONAL TRANSFERS
The website of Helen Bradley Coaching is hosted on secure servers in the UK.

HOW I KEEP YOUR PERSONAL INFORMATION SAFE
Helen Bradley Coaching is committed to the protection and security of your personal
information. I use a variety of security technologies and procedures to protect your personal information from unauthorised use and access, accidental loss, unlawful destruction, alteration, and unlawful disclosure. Paper-based data is stored in lockable cabinets. However, no physical or electronic system is entirely secure. I cannot guarantee the complete security of my database, nor can I guarantee that information that you supply will not be intercepted while being transmitted to me over the internet. I have implemented strict internal guidelines to ensure that your privacy is safeguarded.

I will continue to revise policies and procedures, and review my systems. I will implement additional security features as new technologies become available. Any transmission of personal information is at your own risk. When I receive your personal information, I use appropriate security measures to prevent your personal information from being compromised in any way. When you contact me to ask about your personal information, I may ask you to identify yourself; this is to help protect your personal information.

HOW LONG DO I KEEP YOUR PERSONAL INFORMATION?
I comply with my legal obligations in relation to the retention and deletion of personal data. Personal data that I process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. I will retain your personal data as follows:
Personal data will be retained for a minimum period of 7 years.
In some cases it is not possible for me to specify in advance the period for which your personal data will be retained. In such cases, I will determine the period of retention based on the following criteria:
the period of retention of purchase history will be determined based on the need to keep this information on file for taxation purposes.
I may retain your personal data where such retention is necessary for compliance with a legal obligation to which I am subject, or in order to protect your vital interests or the vital interests of another person.


WHO DO I SHARE YOUR PERSONAL INFORMATION WITH?
There may be circumstances when I am legally mandated to share personal information in accordance with independent statutory legislation and regulatory requirements. In addition, there may be circumstances where it is necessary to share personal information with working partners and stakeholders to enable me to provide my products and services efficiently. Helen Bradley Coaching will ensure that all Data Sharing Agreements and Contracts have been implemented prior to the sharing of any personal information. Access to personal information to external stakeholders and working partners will only be afforded when a specific legal and lawful purpose (s) has been identified.

In line with best practice guidelines, I engage in clinical supervision. This means that cases are discussed with a superior to ensure a high standard of care. Any material used in case studies will be adequately disguised, where appropriate, to ensure the client’s identity is protected.

I will share personal information with a third party if:
The individual requests this. I will request specific permission from the individual to share their personal information, for example, in order to process a referral.
I have an immediate concern about an individual’s safety.
I have a safeguarding concern. Wherever possible this will be discussed with the individual before this step is taken.

Payments are processed by the following third-party agencies: Stripe and AIB. I will share transaction data with my payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. These third parties have undertaken that they will protect that information. Consent is assumed when clients provide their details through these agencies. Responsibility for GDPR regarding these third parties rests with the third party themselves.

WHAT ARE YOUR DATA PROTECTION RIGHTS?
In accordance with the EU General Data Protection Regulation (EU 2016/679) and the Data Protection Act (2018) you are afforded the following rights in certain circumstances:
Right of Access
You have the right to request from me copies of your personal data.
Right to Rectification
You have the right to the rectification of inaccurate personal information about you without undue delay.
Right to Erasure
You may ask me to delete your personal information, however, this is not an absolute right, and any such request will be considered in accordance with EU GDPR legislation and local legislation.
Right to Restrict & Object
You have the right to restrict and object to Helen Bradley Coaching using your personal data, under certain conditions.
Right to Data Portability
You have the right to request that Helen Bradley Coaching transfers the data that I have collected to another organisation, or directly to you, under certain conditions.

HOW TO CONTACT ME
If you have any questions about my privacy policy, the data I hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact me, by email at [email protected] or write to me at Helen Bradley Coaching, 13 Adelaide Road, Dublin,
D02 P950.

HOW TO CONTACT THE APPROPRIATE AUTHORITY
The Data Commissioner’s Office can be contacted at: 21 Fitzwilliam Square South, Dublin 2.

CHANGES TO THIS PRIVACY POLICY
I will make keep my privacy policy under review and place any updates on this web page. By continuing to use my site after I post any such changes, you accept and agree to the privacy policy as modified.

This privacy policy was last updated on 24 MARCH 2023