The Butterfly Clinic operates the www.thebutterflyclinic.ie website, which provides the SERVICE.
This page is used to inform website visitors regarding our policies with the collection, use, and
disclosure of Personal Information if anyone decided to use our Service, the www.thebutterflyclinic.ie website.  If you choose to use our Service, then you agree to the collection and use of information in
relation with this policy. The Personal Information that we collect is used for providing and
improving the Service. We will not use or share your information with anyone except as
described in this Privacy Policy. Our policy complies with the Data Protection Act 2018
accordingly incorporating the EU General Data Protection Regulation (GDPR). The law requires
us to tell you about your rights and obligations to you in regards to the processing and control of
your personal data. We do this now, by requesting that you read the information provided at
www.knowyourprivacyrights.org Information Collection and Use

The Butterfly Clinic holds personal data as part of conducting a professional service. The data is
stored under the following headings: healthcare records, educational records, clinical records,
general administrative records, and financial 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. A wide range of information may
be collected in order to best meet the needs of the client, and to maintain a high quality service
which meets best practice requirements. 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,
Other contacts: name and contact details of GP and any other relevant healthcare
professionals involved.  

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For child services:

• Pre- and post-natal history: This can include information relating to mother’s pregnancy, and
child’s birth.
• Developmental data: developmental milestones, feeding history, audiology history.  

For adult services:
 

• Employment/vocational history
● Medical History
● Mental Health

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Educational records

Relevant Educational Reports, progress notes from educational staff and school reports may be
held.

Clinical records

We process information relating to the health (physical and mental) and education of the young
people attending our service. We also process text submitted via the Questionnaire form on our
contact page on our website.

Specific data in relation to communication skills may be collected and held, such as assessment
forms, reports, case notes, e-mails, text messages and transcripts of phone calls. We collect
information in manual/paper and electronic formats. We do not record telephone calls or online
Telehealth sessions.

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General administrative records

The Butterfly Clinic may hold information regarding attendance reports and accident report forms.
We do not send confidential information by email and we actively encourage families not to email
unencrypted confidential information to us.  Our email (info@thebutterflyclinic.ie) is hosted by Gmail via GSuite; you can read about Gmail and GDPR compliance here:

https://privacy.google.com/businesses/compliance/#?modal_active=none
 

Our online session takes place via Zoom (video-conferencing software). You can read about
Zoom and GDPR here: https://zoom.us/gdpr.  When you contact us, whether by telephone, through our website or by email, we collect the data that you have given us in order to reply with the information you need.  We record your request and our reply in order to increase the efficiency of our business.  We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high
quality service.

Financial records
A financial record pertains to all financial information concerning the practice, e.g. invoices,
receipts, information for Revenue. The Butterfly Clinic may hold data in relation to; receipts and
invoices. Information will include name of bill payer, client name, address and record of invoices
and payments made.

Credit/debit card details and associated cardholder names and addresses submitted via the
website are processed by Stripe and SumUp (card payment processor). You may be sent links to

complete payment via e-mail and/or SMS. You can read about SumUp GDPR compliance here:
https://help.sumup.com/hc/en-ie/articles/360004703114-GDPR-SumUp-and-my-data
The Butterfly Clinic does not store credit/debit card information. At the point of payment, you are
transferred to a secure page on the website of Stripe/SumUp or some other reputable payment
service provider. That page may be branded to look like a page on our website, but It is not
controlled by us.

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Log Data
 

We want to inform you that whenever you visit our Service, we collect information that your
browser sends to us that is called Log Data. This Log Data may include information such as your
computer’s Internet Protocol ("IP") address, browser version, pages of our Service that you visit,
the time and date of your visit, the time spent on those pages, and other statistics. We also
process text submitted via the Questionnaire form on the contact page of our website.

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Cookies
 

Cookies are files with a small amount of data that is commonly used as an anonymous unique
identifier. These are sent to your browser from the website that you visit and are stored on your
computer’s hard drive.  Our website uses these "cookies" to collect information and to improve our Service. You have the option to either accept or refuse these cookies, and know when a cookie is being sent to your computer. If you choose to refuse our cookies, you may not be able to use some portions of our Service. For more general information on cookies, please read "What Are Cookies".  

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Why do we process personal data?

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It is necessary to process data as part of the process of providing Neuro Developmental Therapy
and Johansen IAS Sound Therapy services to a child, adolescent or adult. This includes, but is
not limited to booking appointments, conducting phone consultations and telehealth sessions,
carrying out assessments and interventions, making onward referrals, discussing a client’s case
with parents/legal guardians and other professionals (as appropriate). Data may also be
processed via the Sonorias encrypted website for ordering of customised Johansen Sound
Therapy Music. Additionally data may be processed for administrative purposes, including but
not limited to invoicing and day-to-day administration and financial activities (e.g. accounting,
end-of-year tax returns) that are within our legitimate interests.

Sometimes you might give your consent implicitly, such as when you send us a message by
e-mail to which you would reasonably expect us to reply, or when you leave a voicemail and you
would reasonably expect a return phone call.

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Service Providers 

We may employ third-party companies and individuals due to the following reasons:

● To facilitate our Service;
● To provide the Service on our behalf;
● To perform Service-related services; or
● To assist us in analyzing how our Service is used.

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We want to inform our Service users that these third parties have access to your Personal
Information. The reason is to perform the tasks assigned to them on our behalf. However, they
are obligated not to disclose or use the information for any other purpose.  Information Sharing and Disclosure.  Data processed by The Butterfly Clinic remains confidential and is not shared with individuals, companies or organisations except under the following circumstances:
1.Legal Reasons: We will share personal information with companies or organisations outside of
The Butterfly Clinic if disclosure of the information is reasonably necessary to:

▪ Meet any applicable law, regulation, legal process or enforceable governmental request.
▪ Meet the requirements of the Children First Act 2015.
▪ To protect against harm to the rights, property or safety of The Butterfly Clinic, our service
   users or the public as required or permitted by law.

2. Information sharing – with your consent, we may share personal information pertaining to the
younger person when we have the written consent of their parents or legal guardians to do so.
Information sharing in this way will only take place in the case that it is in the best interest of the
young person.

3. For processing by third parties – Cathy Shilling, Principle Provider of Johansen Sound
Therapy via the encrypted and password protected Sonorous Website, Gmail (email platform),
Zoom (video-conferencing platform), PayPal/SumUp/Stripe/Revolut (card payment processor) and our Accountant.

How and when we obtain consent

At the initial assessment or consultation, a link to the copy of the data protection policy will be
provided to clients along with a client referral form which is the contract between The Butterfly
clinic and client. A consent form will need to be signed by the client prior to commencing the
service. Users will be directed to read the privacy statement.  Should a client wish to withdraw their consent for data to be processed, they can do so by contacting Grainne Dillon at The Butterfly Clinic.

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Storage of Personal Data

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

Electronic Data

Each member of The Butterfly Clinic uses/may use a laptop, mobile phone or tablet. All devices
are password protected to avoid inappropriate misuse of personal data. Your Neuro
Developmental Therapist will confirm how data is stored with the client’s/parent/carer’s written
consent.
This system provider is aware of their requirements for GDPR compliance. - All persons require a
login and Password in order to access the records.

Physical Files

All physical data is located in your Neuro Developmental Therapist office bases in Bangla
Therapy centre, Balrath, Co.Meath and Ryan House, Emmet street, Trim, Co.Meath. Your Neuro Developmental Therapist will advise you of where records are stored during your initial meeting.

- Only persons working for The Butterfly have access to these records.
- These records are kept in a container secured with a lock and key.

Retention of Records

We retain data in line with data retention guidelines provided by the HSE. We retain all electronic
and/or paper/physical data relating to an adult for 8 years after last consultation and for the
young person until their 25th birthday or until their 26th birthday if the young person was 17 at
the conclusion of treatment, or 8 years after death. Financial data for the current year and
previous six financial years is retained. All data is destroyed under confidential conditions upon
expiration of the retention period.

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Security

We value your trust in providing us your Personal Information, thus we are striving to use
commercially acceptable means of protecting it. But remember that no method of transmission
over the internet, or method of electronic storage is 100% secure and reliable, and we cannot
guarantee its absolute security.  The Butterfly Clinic, 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 The Butterfly Clinic are briefed on the proper management, storage and safekeeping of data.  All data used by The Butterfly Clinic, including personal data may be retained in any of thefollowing formats:

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1. Electronic Data
2. Physical Paper Files

The type of format for storing the data is decided based on the format the data exists in.
Where applicable, The Butterfly Clinic may convert physical files to electronic records to allow us
to provide a better service to clients and avoid unnecessary storage of paper files. Paper files will
be destroyed appropriately if information is stored electronically. All physical devices used by
persons working in The Butterfly Clinic which may contain any identifiable information are
enabled with loss theft tracking and remote wipe abilities.

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Data Processed outside of the European Union

Our website is hosted by Wix. We may also use outsourced services in countries outside the
European Union from time to time in other aspects of business (e.g. Sonorias, Gmail, GSuite,
SumUpp, PayPal etc). Accordingly, data obtained within Ireland or any other country could be
processed outside the European Union. It is our understanding that these companies are GDPR
compliant and have subscribed to the EU-US and Swiss-US Privacy Shield and/or EU Model
Contract Clauses (MCCs, also known as Standard Contractual Clauses or SCCs) which ensures
that EU citizens are protected under EU data protection laws. You can read more about Privacy
Shield here: https://www.privacyshield.gov/welcome.

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Links to Other Sites
 

Our Service may contain links to other sites. If you click on a third-party link, you will be directed
to that site. Note that these external sites are not operated by us. Therefore, we strongly advise
you to review the Privacy Policy of these websites. We have no control over, and assume no
responsibility for the content, privacy policies, or practices of any third-party sites or services.

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Children's Privacy
 

Our Services do not address anyone under the age of 13. We do not knowingly collect personal
identifiable information from children under 13. In the case we discover that a child under 13 has
provided us with personal information, we immediately delete this from our servers. If you are a
parent or guardian and you are aware that your child has provided us with personal information,
please contact us so that we will be able to do necessary actions.

Access to your personal information
 

At any time you may review or update personally identifiable information that we hold about you,
by contacting us by email at info@thebutterflyclinic.ie. If your request is deemed to be
valid then it will be dealt with in the appropriate manner and timeframe as required by “Art. 15
GDPR Right of access by the data subject”. This includes “the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing.”

Complaints about how your data is processed

 

When we receive a complaint, we record all the information you have given to us. We use that
information to resolve your complaint. If your complaint reasonably requires us to contact some
other person, we may decide to give to that other person some of the information contained in
your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as
to whether we do give information, and if we do, what that information is. We may also compile
statistics showing information obtained from this source to assess the level of service we provide,
but not in a way that could identify you or any other person. If you are concerned about how your
personal information is processed by The Butterfly Clinic, please contact us by emailing
info@thebutterflyclinic.ie

Data Breaches
 

In the highly unlikely situation that we suffer a data breach then we will inform all those affected
in the appropriate manner and timeframe as required by “Art. 33 GDPR Notification of a personal data breach to the supervisory authority”. For more information on this visit:
http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612052

 

Changes to This Privacy Policy
 

The Butterfly Clinic understands that requirements for electronic and physical storage may
change with time and the state of the art. As such, the data controller in The Butterfly Clinic
reviews the electronic and physical storage options available to The Butterfly Clinic every 12
MONTHS. Thus, we advise you to review this page periodically for any changes. We will notify
you of any changes by posting the new Privacy Policy on this page. These changes are effective
immediately, after they are posted on this page.

Compliance with the law
 

Our privacy policy has been compiled so as to comply with GDPR Regulations. If you think it fails
to satisfy GDPR regulations, we should like to hear from you. We will make whatever changes
deemed necessary and within the appropriate time frame should we be required to do so by the
Office of the Data Protection Commissioner. Our Privacy Policy was created with the help of the Privacy Policy Template and the Privacy Policy Generator.

 

Contact Us
 

If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us.
 

Grainne Dillon
The Butterfly Clinic
Bangla Therapy Centre,
Balrath,
Navan,
Co.Meath
info@thebutterfly.ie

086-8030745