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Effective Date: September 1, 2026

Data Controller: The Gentle Clinic

Address: Wicklow Town, County Wicklow, Irealnd

Contact Email: admin@gentleclinic.ie

1. Introduction & Scope

The Gentle Clinic (“we,” “us,” or “our”) operates as a psychological group practice in Ireland. We respect your privacy and are committed to protecting your personal data in accordance with the General Data Protection Regulation (EU 2016/679) (GDPR), the Data Protection Acts 1988–2018, and the ethical principles set by the Psychological Society of Ireland (PSI).

This Privacy Policy applies to personal data collected through our website (www.gentleclinic.ie) when you submit an inquiry, book a consultation, or interact with our site.

Note: If you become an active client of our practice, you will receive a separate, comprehensive Clinical Privacy Notice & Consent Form covering therapeutic confidentiality, clinical session notes, and medical record retention.

2. The Personal Data We Collect

We collect personal data directly from you when you use our website contact forms, booking engine, or general email inquiries.

Standard Personal Data (Article 6 GDPR)

  • Contact Information: Full name, email address, phone number.
  • Inquiry Details: Preferred appointment times, service requests, or referral source.
  • Technical Data: IP address, browser type, device information, and website usage statistics via essential cookies.

Special Category Health Data (Article 9 GDPR)

  • Clinical Inquiries: Any health-related, psychological, or diagnostic details you voluntarily provide in free-text contact forms or pre-screening questionnaires. We strongly advise keeping pre-consultation website messages to general details.

3. Legal Basis for Processing

We process your data under the following legal bases:

Data TypePurposeLegal Basis under GDPR
Contact DataResponding to website inquiries, scheduling intake sessionsArticle 6(1)(b): Steps prior to entering into a contract.
Health Data (PHI)Pre-intake assessment to evaluate suitablity for psychological careArticle 9(2)(a): Your explicit consent, and Article 9(2)(h): Provision of healthcare services.
Technical DataWebsite security, analytics, and performanceArticle 6(1)(f): Legitimate interests in maintaining a secure site.

4. How We Use & Share Your Data

Internal Practice Access & Subcontractors

As a group practice, your inquiry may be assigned to a qualified associate psychologist or self-employed subcontractor practitioner working under our practice oversight. All subcontractors operate under strict Data Processing Agreements (DPAs) and professional duty of confidentiality.

Third-Party Data Processors

We do not sell, rent, or trade your data. We share your information only with trusted software processors necessary to run our practice, including:

  • Google Workspace (EU Data Region): Email and secure cloud document management.
  • Practice Management / EHR System: GDPR-compliant booking and clinical management software.
  • Website Hosting & IT Support Services.

All processors are bound by GDPR Article 28 data protection contracts ensuring robust encryption and confidentiality.

International Transfers

Your data is stored primarily within the European Economic Area (EEA). If any service provider transfers data outside the EEA, standard contractual safeguards (such as EU Standard Contractual Clauses) are enforced to maintain EU levels of protection.

5. Data Retention

We do not keep personal data for longer than necessary:

  • Unconverted Website Inquiries: Retained for up to 6 months from the last communication, then securely deleted.
  • Active Clinical Clients: In accordance with Irish clinical guidance and HSE record retention benchmarks, adult clinical records are retained for 8 years following the end of therapy.Records for children/adolescents are retained until their 25th birthday (or 26th birthday if treatment ended at age 17).

6. Your Data Protection Rights

Under GDPR and the Irish Data Protection Act 2018, you have the following rights:

  • Right of Access: Request a copy of the personal data we hold about you (Subject Access Request).
  • Right to Rectification: Request correction of inaccurate or incomplete data.
  • Right to Erasure (“Right to be Forgotten”): Request deletion of personal data where legal or professional retention mandates no longer apply.
  • Right to Restrict or Object: Object to processing based on legitimate interests.
  • Right to Withdraw Consent: Withdraw explicit consent at any time without affecting past processing.

To exercise any of these rights, contact us at admin@gentleclinic.com. We will respond within one calendar month.

7. Mandatory Disclosures & Confidentiality Limits

Confidentiality is a cornerstone of psychological practice. However, under Irish law, confidentiality can be breached without consent under rare circumstances:

  1. Clear and imminent risk of serious harm to yourself or others.
  2. Mandatory child protection reporting obligations under the Children First Act 2015.
  3. Direct order or subpoena issued by an Irish court.

8. Cookies

Our website uses essential functional cookies to ensure proper operation. We do not place non-essential tracking or marketing cookies on your device without your prior consent via our cookie banner.

9. Complaints & Supervisory Authority

If you have concerns about how we handle your personal data, please contact us first so we can resolve the issue.

You also have the right to lodge a formal complaint with the Irish Data Protection Commission (DPC):