Privacy Policy

Last updated: 22 August 2026

1. Who is responsible for your information

Dublin City Counselling Services Ltd
Company No. 65234
Registered in Ireland
Dublin, Ireland
Email: info@dublincounsellors.ie

Dublin City Counselling Services Ltd, referred to as “DCCS” in this policy, is responsible for the personal information it processes in connection with its services.

Questions about this Privacy Policy, or requests concerning personal information, can be sent to the email address above.

2. Scope of this policy

This Privacy Policy explains how DCCS collects, uses, stores and shares personal information when a person:

1. Visits the DCCS website.
2. Makes an enquiry.
3. Books or attends an appointment.
4. Uses a counselling, psychotherapy, CBT or consultation service.
5. Participates in an employer funded or EAP funded service.
6. Communicates with DCCS.
7. Makes a complaint or exercises a data protection right.

Separate information may be provided through the Counselling Agreement, intake process, Child Safeguarding information, Cookie Policy and Terms and Conditions.

3. Information DCCS may process

Depending on the service and circumstances, DCCS may process:

1. Identity and contact information, including a person’s name, email address, telephone number and preferred contact method.
2. Appointment and administrative information.
3. Payment, transaction, invoice and receipt information.
4. Clinical, health and wellbeing information relevant to counselling or psychotherapy.
5. Information about a person’s needs, concerns, goals, medication, previous support or current circumstances where relevant.
6. Clinical notes and professional correspondence.
7. Information concerning risk, safety, safeguarding or emergency arrangements.
8. Current location, country of residence and emergency contact information where required for online counselling.
9. Parent or guardian information where services are being considered for a young person aged 16 or 17.
10. Limited information received from an employer, EAP provider, referrer or other organisation where relevant to arranging a service.
11. Complaints, feedback and data protection correspondence.
12. Limited website, device and cookie preference information.

Health and clinical information may constitute special category personal data under the GDPR and receives additional protection.

4. How information is collected

DCCS may receive information:

1. Directly from the person making an enquiry or attending counselling.
2. Through appointment booking, payment or secure intake processes.
3. During counselling, assessment or consultation.
4. From a parent or guardian where appropriate.
5. From an employer, EAP provider or referrer where a service is funded or facilitated by another organisation.
6. From another professional or service where the person has authorised the disclosure or another lawful basis applies.
7. Through necessary website storage and optional cookies where consent has been provided.

Sensitive clinical or health information should not be submitted through the public enquiry form. Where required, DCCS provides an appropriate secure method for supplying that information.

5. Why information is processed

DCCS may process personal information to:

1. Respond to enquiries.
2. Assess whether a service may be appropriate.
3. Arrange and administer appointments.
4. Provide counselling, psychotherapy, CBT and related professional services.
5. Maintain appropriate clinical and administrative records.
6. Communicate with clients.
7. Process payments and maintain financial records.
8. Manage risk, safety, safeguarding or emergency concerns.
9. Meet applicable legal, tax, insurance and professional responsibilities.
10. Manage complaints, legal matters and data protection requests.
11. Administer employer funded or EAP funded services.
12. Protect the security and proper operation of the website and services.

6. Lawful bases under Article 6 GDPR

DCCS must have a lawful basis under Article 6 GDPR for each use of personal information. Depending on the confirmed purpose, the applicable basis may include:

1. Taking steps at a person’s request before entering a contract or performing a contract.
2. Compliance with a legal obligation.
3. DCCS’s legitimate interests, where those interests are not overridden by the person’s rights and freedoms.
4. Protection of a person’s vital interests in exceptional circumstances.
5. Consent where consent is genuinely the appropriate basis for an optional activity.

Consent is not automatically the basis for every aspect of counselling, clinical record keeping or safeguarding.

7. Health and other special category information

Counselling and psychotherapy may involve information about mental or physical health and other information classified as special category personal data under Article 9 GDPR.

DCCS processes special category information only where an applicable Article 9 condition and any relevant Irish data protection requirement permit the processing.

This information is subject to additional confidentiality, security and data protection safeguards.

8. Confidentiality and safeguarding

Counselling information is treated confidentially in accordance with applicable professional, ethical and legal responsibilities.

Confidentiality is not absolute. Information may need to be disclosed where:

1. Disclosure is required by law.
2. A safeguarding responsibility applies.
3. There is an exceptional and serious concern about a person’s safety or the safety of another person.
4. Disclosure to a statutory, regulatory, healthcare or emergency service is otherwise lawfully justified.

Any disclosure should be limited to information reasonably necessary and proportionate to the circumstances.

Where appropriate and safe, DCCS will seek to discuss a proposed disclosure with the client before it occurs. This may not be possible where doing so could increase risk, place someone in danger or interfere with a statutory process.

9. Young people aged 16 and 17

Counselling for a young person aged 16 or 17 will only begin following an initial consultation to consider suitability, consent and safeguarding requirements.

DCCS may need to process information about the young person’s circumstances, consent and capacity, parent or guardian involvement, emergency arrangements, current location and any relevant safety or safeguarding concern.

Parents or guardians do not automatically receive counselling content. Equally, confidentiality cannot be absolute where a serious safety or safeguarding concern arises.

Further information is available in the DCCS Child Safeguarding information.

10. Corporate and EAP funded counselling

Where counselling is funded or facilitated by an employer, EAP provider or another organisation, DCCS maintains the confidentiality of the therapeutic relationship.

DCCS does not provide employers with counselling content, clinical notes or other identifiable clinical information as part of routine organisational reporting.

Where organisational reporting is required, it is limited to aggregated or anonymised information from which individuals cannot reasonably be identified.

Relevant confidentiality arrangements and any applicable limits are explained to the client.

11. Professional supervision

Clinical work may be discussed in professional supervision where appropriate.

Information is minimised and, wherever reasonably possible, discussed without identifying the client. Professional supervision remains subject to confidentiality and applicable professional standards.

12. Service providers and other recipients

DCCS may use appropriately selected service providers supporting:

1. Appointment booking.
2. Payment processing.
3. Secure communication and video consultations.
4. Clinical record management.
5. Secure intake and forms.
6. Website hosting and security.
7. Email and business communication.
8. Accounting, professional and business administration.

These providers should receive only information relevant to the service they provide and must process it under appropriate data protection arrangements.

Where an appropriate lawful basis exists, information may also be disclosed to professional advisers, accountants, insurers, professional or regulatory bodies, safeguarding authorities, healthcare or emergency services, courts or other authorities.

DCCS does not sell personal information.

13. International processing and transfers

Some providers supporting DCCS may process or allow access to personal information outside Ireland or the European Economic Area.

Where an international transfer occurs, DCCS will ensure that the transfer is governed by a lawful GDPR transfer mechanism and any required safeguards.

Information about applicable safeguards can be requested by contacting info@dublincounsellors.ie.

14. Retention

DCCS retains personal information only for as long as necessary for the purpose for which it was collected and to meet applicable legal, professional, insurance, safeguarding, tax and accounting responsibilities.

The following periods and criteria apply:

• Adult clinical records and counselling notes: retained for seven years after the last date of service, subject to any longer period required by law, professional or insurance requirements, or circumstances requiring continued retention.
• Intake forms and Counselling Agreements: where these form part of the clinical record, they are retained with that record for the same applicable period.
• Appointment and administrative records: retained only for the period required for service administration, accounting, legal or professional purposes. The clinical-record period is not automatically applied to purely administrative information.
• Enquiries and routine communications that do not lead to a client relationship: retained for an appropriate limited period and securely deleted when no longer required for handling the enquiry, related communications, or any applicable legal or professional need.
• Payment records, invoices and receipts: retained in accordance with applicable Irish tax and accounting record-keeping requirements. These financial records do not automatically follow the clinical-record period.
• Safeguarding and risk records: retained according to applicable legal, safeguarding, insurance and professional requirements. Where this information forms part of the clinical record, the applicable clinical-record period is also considered.
• Complaints: retained for the period reasonably necessary to manage the complaint and meet any related legal, regulatory, professional or insurance requirements.
• Records created while a client was aged 16 or 17: retained in accordance with the current IACP requirements applying to records created while a client was under 18, rather than automatically applying the adult seven-year period.

Information will be securely deleted or anonymised when it is no longer required, subject to any lawful reason for continued retention.

15. Data protection rights

Depending on the circumstances and applicable law, individuals may have the right to:

1. Request access to their personal information.
2. Request correction of inaccurate or incomplete information.
3. Request erasure of information.
4. Request restriction of processing.
5. Object to certain processing.
6. Receive certain information in a portable format.
7. Withdraw consent where consent is the lawful basis.
8. Complain to the Irish Data Protection Commission.

These rights are not absolute in every circumstance. DCCS may need to retain certain information to meet legal, professional, safeguarding or legal claims requirements.

Requests can be sent to info@dublincounsellors.ie. DCCS may request reasonable information to confirm the requester’s identity before releasing personal information.

Exercising these rights is normally free of charge. Applicable law may permit a reasonable fee or refusal where a request is manifestly unfounded or excessive.

Withdrawing consent does not affect the lawfulness of processing completed before consent was withdrawn.

16. Complaints to the Data Protection Commission

Anyone concerned about how DCCS processes personal information should contact DCCS so the concern can be considered.

Individuals also have the right to lodge a complaint with the Irish Data Protection Commission. Information about making a complaint is available from the Irish Data Protection Commission.

This data protection complaint process is separate from the DCCS service Complaints Procedure.

17. Cookies and website information

The DCCS website uses essential browser storage to remember cookie preferences. Optional analytics cookies will only be used where permission has been given.

Cookie preferences can be changed through Cookie Settings in the website footer. Further information is available in the DCCS Cookie Policy.

18. Security

DCCS uses appropriate technical and organisational measures intended to protect personal information against unauthorised access, loss, alteration, disclosure or destruction.

Access should be limited to people and providers who require the information for an authorised purpose.

No electronic system can be guaranteed to be completely secure. Clients should avoid sending detailed clinical or highly sensitive information through ordinary email, WhatsApp or the public enquiry form unless DCCS has confirmed an appropriate method.

19. Providing information

Some information is necessary to respond to an enquiry, assess suitability, arrange and deliver an appointment, process payment or meet safety, safeguarding and legal requirements.

If required information is not provided, DCCS may be unable to offer or continue a particular service. Optional information will be identified where appropriate.

20. Changes to this policy

DCCS may update this Privacy Policy when its services, systems or legal and professional requirements change.

The date at the top of the policy will show when it was last updated. Material changes affecting existing clients will be communicated where appropriate.