Privacy Policy

When you use Therapy Solutions you trust us with your information. This privacy policy is meant to help you understand what data we collect, why we collect it, and what we do with it. We have tried to make it as simple as possible but if you have any questions please contact us.

Therapy Solutions assumes the function of data controller and supervises the compliance with General Data Protection Regulation (GDPR) within the business.

- Information we collect
- Where we get our information
- How we use the information we collect
- Information we share
- How and when consent is obtained
- How we protect your data
- Protecting your rights to data
- Security of your personal data

1 Information we collect

Therapy Solutions holds personal data as part of conducting a professional service. The data follows under the following headings: healthcare records, clinical records, general administrative records, and financial records.

1.1 Healthcare records

A healthcare record refers to all information collected, processed and held both in manual and electronic formats pertaining to the service user and their care. In order to provide a high quality service, a range of information may be collected.

Examples of data collected and held on all current and active clients include the following:

- Contact details: Name, address, phone numbers, e-mail address,
- Personal details: date of birth, diagnosis
- Other contacts: name and contact details of relevant healthcare professionals involved.

For child services:

Parent/guardian details

1.2 Clinical records

Specific data in relation to ordering a garment may be collected and held, such as assessment and measuring forms, faxes and e-mails. Picture files may also be collected and stored.

1.3 General administrative records

Therapy Solutions may hold information regarding clinic lists, order list, and delivery list.

1.4 Financial records

A financial record pertains to all financial information concerning the practice, e.g. invoices, receipts, information for Revenue. Therapy Solutions may hold data in relation to: Purchase orders, invoices and receipts. Information will include name of invoice payer, client name, address and record of invoices and payments made.

2 Where we get our information

Personal data will be provided by the client, or in the case of a child (under 16 years), their parent(s)/guardian(s), and directly from relevant third parties such as allied health care professional who have attained prior consent from the client/parent(s)/guardian(s). This information will be collected as part of the measuring process prior to ordering.

3 How we use the information that we collect

We use the information we collect to provide a garment as per the relevant professional guidelines, as well as to maintain the general running of the business, such as running our electronic ordering system, keeping our accounts and updating you of any changes in policies or fees.

3.1 Data retention periods

The retention periods are the suggested time periods for which the records should be held based on the organisation’s needs, legal and/or fiscal precedence or historical purposes. Following the retention deadline, all data will be destroyed under confidential means.

3.2 Client Records

3.2.1 Clinical Records

Therapy Solutions keeps both physical and electronic records of clinical data in order to provide a service.

The preferred format for clinical data is both paper and electronic.
Clinical data is deleted/confidentially destroyed after 5 years from last invoiced session.
Clinical data used for research purposes, may be kept for longer than 2 years.
Video records/ photos relating to client care/ records may be recorded with consent, analysed and then destroyed. If written consent is provided to use recordings for training purposes, the client will have the option to withdraw consent at any time.

3.2.2 Financial Records

Therapy Solutions keeps electronic/paper records of financial data from those who use our services.

Section 886 of the Direct Tax Acts states that the Revenue Commissioners require records to be retained for a minimum period of six years after the completion of the transactions, acts or operations to which they relate. These requirements apply to manual and electronic records equally.

Financial Data is kept for 6 years to adhere to Revenue guidelines.
Financial Data (including non-payment of bills) can be given to Revenue at Revenue’s request.

3.2.3 Contact Data

Contact Data is kept for 6 years to allow processing of Financial Data if required. (This may be retained for longer for safety, legal request, or child protection reasons.)

3.3 Exceptions

If under investigation or if litigation is likely, files must be held in original form indefinitely, otherwise files are held for the minimum periods set out above.

4 Information we share

Therapy Solutions share the personal information gathered as part of the ordering process with the manufacturer, Lymed Oy, Pyhäjärvenkatu 5 A, 33200 Tampere, Finland.
Therapy Solutions do not share personal information with any other additional third parties unless one of the following circumstances apply:

4.1 With your consent

We will only share your Personal Identifying Information (PII) to third parties when we have express written permission by letter or email to do so. We require opt-in consent for the sharing of any sensitive information. Third parties may include: hospitals, GPs, other allied health professionals.

4.2 For legal reasons

We will share personal information with companies or organisations outside of Therapy Solutions if disclosure of the information is reasonably necessary to:

- Information we collect
- Where we get our information
- How we use the information we collect
- Information we share
- How and when consent is obtained
- How we protect your data
- Protecting your rights to data
- Security of your personal data

4.3 To meet financial requirements

Therapy Solutions also is required to share financial data with Paschal Bergin & Co. in order to comply with local tax laws. Therapy Solutions has obtained a copy of the Paschal Bergin & Co’s own Data protection policy.

5 How and when we obtain consent

Prior to initial assessment or consultation, a link to the data protection policy will be provided and a consent form will need to be signed by the client prior to commencing the service. Copies of the signed consent form will be given to both parties.

6 How we protect your data

In accordance with the General Data Protection Regulation (GDPR), we will endeavour to protect your personal data in a number of ways

6.1 To meet financial requirements

All data collected by us will be collected solely for the purposes set out at 1 above and will be collected for specified, explicit and legitimate purposes. The data will not be processed any further in a manner that is incompatible with those purposes. Furthermore, all data collected by us will be adequate, relevant and limited to what is necessary in relation to the purposes for ordering a garment.

6.2 To meet financial requirements

Data will only be share and transmitted, be it on paper, electronically only as is required, and as set out in section 4.

6.3 To meet financial requirements

when it is required and by limiting its accessibility to any other third parties.

6.4 To meet financial requirements

which in this case 5 years except for circumstances in which retention of data is required in circumstances set out at part 3.1 above or in certain specific circumstances as set out at Article 23(1) of the GDPR.

6.5 By destroying the data securely and confidentially after the period of retention has elapsed.

This could include the use of confidential shredding facilities or, if requested by the individual, the return of personal records to the individual.

7 Protecting your Rights to Data

7.1 Adult clients

Adults have the right to request data held on them as per article 15 of GDPR. A request must be made in writing. Further information regarding accessing your personal data are available in the document ‘Rights of Individuals under the General Data Protection Regulation’, downloadable from: www.gdprandyou.ie

7.2 Children

For children under the age of 16, data access requests are made by their guardians. When a child turns 16, then they may make a request for their personal data. However, this is subject to adherence with the Children First Act.

8 How we protect your data

Therapy Solutions as with most providers of healthcare services is aware of the need for privacy. As such, we aim to practice privacy by design as a default approach, and only obtain and retain the information needed to provide you with the best possible service. All persons working in, and with Therapy Solutions in a professional capacity are briefed on the proper management, storage and safekeeping of data. All data used by Therapy Solutions including personal data may be retained in any of the following formats:

- Electronic Data
- Physical Files

The type of format for storing the data is decided based on the format the data exists in. Where applicable, Therapy Solutions may convert physical files to electronic records to allow us to provide a better service to clients.

8.1 Data Security

Therapy Solutions understands that the personal data used in order to provide a service belongs to the individuals involved. The following outlines the steps which Therapy Solutions use to ensure that the data is kept safe.

8.1.1 Electronic Data

The systems used are Windows PC and info@therapysolutions.ie
Windows PC is located in Therapy Solutions, 18 The Grove, Weir View, Castlecomer Road, Kilkenny, Ireland.
The system has a Live Update for security enabled.
All persons working in Therapy Solutions have access to records.
All persons require a Log on and Password in order to access the
The data controller in Therapy Solutions can remove or delete users.

8.1.2 Clinical Records

All physical data is located in Therapy Solutions, 18 The Grove, Weir View, Castlecomer Road, Kilkenny, Ireland.
Only persons working in Therapy Solutions have access to these records.
These records are kept in a container secured with a lock and key.

8.2 Security Policy

Data will only be share and transmitted, be it on paper, electronically only as is required, and as set out in section 4.

8.2.1
Therapy Solutions understands that requirements for electronic and physical storage may change with time and the state of the art. As such, the data controller in Therapy Solutions reviews the electronic and physical storage options available to Therapy solutions monthly.

8.2.2
All persons working in Therapy Solutions are aware and briefed on the requirements for good data hygiene every 6 months.