Privacy and clinical information
Privacy Policy
How Dublin City Counselling Services Ltd handles personal information and clinical boundaries.
Dublin City Counselling Services Ltd | Last updated: October 2026
1. Who we are
Dublin City Counselling Services Ltd (DCCS), Company No. 652341, registered in Ireland, is the data controller for personal information processed through its website and services. Contact: info@dublincounsellors.ie | +353 1 537 6456.
DCCS has not appointed a Data Protection Officer, as one is not required for a practice of its size. Data protection questions can be sent to the address above.
2. What this policy covers
This policy covers website visits, enquiries, bookings, online counselling and psychotherapy, services funded by an employer or Employee Assistance Programme (EAP), communications and complaints.
Clients also receive a shorter Client Information and Privacy Notice before their first session; the two documents are consistent.
3. Information we process
Depending on your circumstances, DCCS may process:
- name, contact details and appointment information;
- payment and invoicing records;
- information about your health, wellbeing, concerns and goals, including questionnaire or worksheet responses;
- clinical notes and related professional correspondence;
- risk, safeguarding and emergency information, including your location during online sessions;
- for clients aged 16–17, parent or guardian details;
- website and cookie data, where you have agreed to analytics cookies.
4. Where information comes from
Most information comes directly from you, through enquiries, booking, intake and sessions. Some may come from a parent or guardian, an employer or EAP provider, or another professional who refers you, where this is relevant and lawful.
5. Why we use it and our lawful basis
DCCS uses personal information only where there is a lawful basis under Article 6 GDPR. Health information is special category data and is processed only where a condition under Article 9 GDPR and the Data Protection Act 2018 applies. For routine counselling, that condition is the provision of health care by a professional bound by confidentiality (Article 9(2)(h) GDPR and section 52 of the Data Protection Act 2018).
| Purpose | Article 6 basis | Health information (Article 9) |
|---|---|---|
| Responding to enquiries and assessing suitability | Steps at your request before a contract (6(1)(b)) | Health care (9(2)(h)) and s.52 DPA 2018 |
| Providing counselling and keeping clinical records | Contract (6(1)(b)) | Health care (9(2)(h)) and s.52 DPA 2018 |
| Clinical supervision | Legitimate interests and professional obligations (6(1)(f)) | Health care (9(2)(h)) and s.52 DPA 2018 |
| Payments, invoicing and accounts | Contract and legal obligation (6(1)(b), 6(1)(c)) | Not applicable |
| Child protection reporting to Tusla and other legal requirements | Legal obligation (6(1)(c)) | Health care (9(2)(h)) and s.52 DPA 2018; Children First Act 2015 |
| Serious and imminent risk to life | Vital interests (6(1)(d)) | Vital interests (9(2)(c)) |
| Complaints, insurance and legal claims | Legitimate interests (6(1)(f)) | Legal claims (9(2)(f)) |
| Session recording (only with written agreement) and analytics cookies | Consent (6(1)(a)) | Explicit consent (9(2)(a)) |
Consent is not the basis for counselling or clinical record keeping. It is used only for optional matters, and you can withdraw it at any time.
6. Confidentiality
What you discuss in counselling is treated confidentially, but confidentiality is not absolute. Information may be disclosed where required by law, where safeguarding responsibilities apply (including reporting child protection concerns to Tusla under the Children First Act 2015), where there is a serious concern about your safety or another person’s safety, or to emergency services. Any disclosure is limited to what is necessary. Where it is appropriate and safe, DCCS will discuss a disclosure with you first.
Clinical work may be discussed in professional supervision, with identifying details left out wherever reasonably possible.
7. Recording of sessions
Sessions are not recorded by either the client or the therapist without the other’s prior written agreement. This includes Zoom’s built-in recording, any other audio, video or screen recording, screenshots, and AI transcription or note-taking tools. DCCS does not use AI transcription or note-taking tools in sessions.
8. Clients aged 16–17
Counselling for 16–17-year-olds begins only after an initial consultation. Parents or guardians do not automatically receive information about session content. Safeguarding and child protection obligations apply as described in section 6.
9. Employer and EAP-funded services
If an employer funds your sessions, your employer does not receive clinical content or information that identifies what you discuss. Any reporting to an employer is aggregated and anonymised. If you are referred through an EAP provider, the provider may receive the limited information its contract with DCCS requires, such as attendance, outcome questionnaire scores or notification of a serious safety concern. This is kept to the minimum necessary. The EAP provider’s own privacy notice explains how it uses your information.
10. Service providers and sharing
DCCS uses service providers for booking, payment, video sessions, clinical records, website hosting, email and accounting. They receive only the information they need and act on DCCS’s instructions. Information may also be shared with professional advisers, insurers, regulators, safeguarding authorities, healthcare or emergency services, or courts, where there is a lawful basis.
If you need support between sessions, DCCS may suggest contacting your GP. Information is not shared with your GP without your consent, except where there is a serious concern for your safety.
DCCS does not sell personal information.
11. International transfers
Some providers, such as video and email services, may process information outside the European Economic Area. Where they do, recognised legal safeguards apply, such as a European Commission adequacy decision (including the EU–US Data Privacy Framework) or Standard Contractual Clauses. Details are available on request.
12. How long information is kept
- Adult clinical records and counselling notes: seven years after your last session, or longer where required by law or by professional or insurance requirements. Intake forms and counselling agreements are kept with the clinical record.
- Records of clients who were 16–17: in line with IACP guidance for records of young people.
- Financial records: six years, as required by Irish tax law.
- Enquiries that do not lead to a service: up to 12 months.
- Complaint records: for as long as needed to deal with the complaint and any related claim.
Records are then securely deleted or anonymised.
13. Your rights
You may ask to access or correct your personal information, request erasure or restriction, object to certain uses, receive certain information in a portable format, or withdraw consent where consent is the basis. These rights are not absolute in every circumstance; for example, clinical records may need to be kept for the period above. Contact info@dublincounsellors.ie. DCCS will respond within one month, and may ask you to confirm your identity.
DCCS does not use automated decision-making or profiling.
14. Data protection complaints
Please contact DCCS first so we can try to resolve your concern. You may also complain to the Data Protection Commission at www.dataprotection.ie. Concerns about counselling itself are handled under the DCCS Complaints Procedure at dublincounsellors.ie/complaints-procedure.
If a concern cannot be resolved directly, you may also be able to raise it with the Irish Association for Counselling and Psychotherapy (IACP), where the matter falls within its complaints remit.
15. Cookies
The website uses essential storage to remember your cookie preferences. Analytics cookies are used only if you agree to them, and you can change your choice at any time through Cookie Settings. See the Cookie Policy for details.
16. Security
DCCS uses appropriate technical and organisational measures to protect personal information. Please do not send detailed clinical or highly sensitive information by ordinary email, WhatsApp or the website enquiry form.
17. Information you need to provide
Some information is needed to respond to you, assess suitability, provide appointments, process payment and meet safety, safeguarding or legal requirements. If it is not provided, DCCS may be unable to offer or continue a service.
18. Changes to this policy
This policy may be updated. Material changes affecting existing clients will be communicated directly where appropriate. The date at the top shows when it was last updated.