Privacy Notice
Effective 13 August 2026 | Version 1.0
This notice explains what personal information I collect, why I use it, how I protect it, and the choices and rights available to you.
1. Who is responsible for your information?
Shoreline Counselling & Psychotherapy is the registered business name under which I, Ana Planas Domínguez, provide counselling and psychotherapy services as a sole trader.
Under the General Data Protection Regulation (GDPR) and the Data Protection Act 2018, I am the data controller. This means that I am responsible for deciding how and why your personal information is collected, used, stored and protected.
Data controller: Ana Planas Domínguez, trading as Shoreline Counselling & Psychotherapy
Business address: The Fairways, Ferrybank, Waterford
Email: info@shoreline-counselling.com
Telephone: +353 85 120 7357
2. Who does this notice apply to?
This notice applies to people who visit the Shoreline website, make an enquiry, request an appointment, receive therapy, or take part in individual, couple or family work. It also applies, where relevant, to parents, guardians, emergency contacts, referrers and other people whose information is included in a client record.
This notice explains data protection. The therapeutic agreement provides additional detail about confidentiality, professional boundaries, cancellations, safeguarding and the practical arrangements for therapy.
3. What information may I collect?
Depending on how you engage with Shoreline, I may collect:
· identity and contact details, including your name, address, date of birth, telephone number and email address;
· information contained in an enquiry or appointment request;
· contact preferences and information about whether it is safe to leave a voicemail, send a text message or use email;
· appointment details, attendance, cancellations and administrative correspondence;
· information about your health, wellbeing, relationships, family circumstances, personal history, neurodivergence, medication, risk or support needs;
· therapy assessments, working notes, session records, safety plans, referrals and correspondence connected with your care;
· information relevant to child or adult safeguarding, including risk to you or another person;
· information about parents, guardians, partners, family members, children, emergency contacts or other people discussed during therapy;
· payment, invoice and accounting information, although I do not need to retain full payment-card details;
· complaints, feedback, requests relating to your information and records of how those requests were handled; and
· technical website information such as IP address, browser, device, pages visited, referral source and cookie identifiers, where permitted by your cookie choices.
4. How do I obtain your information?
Most information is provided directly by you, for example through the website, by email or telephone, during an initial consultation, or in therapy.
With an appropriate basis, I may also receive information from a parent or guardian, a partner or family member participating in therapy, a referrer, another health or social care professional, an emergency contact, or a safeguarding or statutory body. Website and analytics providers may supply technical information about how the website is used.
If personal information is obtained from someone other than you, I will provide the information required by law when appropriate. There are limited exceptions, including where providing it would be impossible, involve disproportionate effort, seriously impair the purpose of the processing, or conflict with another person's rights or a duty of confidentiality.
5. Why do I use your information?
I only use personal information where there is a lawful reason to do so. The main purposes and legal bases used by Shoreline are explained below.
Responding to enquiries
I use the contact details and information you include in your enquiry to respond, understand what you are looking for and consider whether I can appropriately offer the service you need.
Lawful basis: Article 6(1)(b) of the GDPR — taking steps at your request before entering into a contract. If you provide health information in connection with possible care, Article 9(2)(h) may also apply.
Arranging and providing therapy
I use identity, contact, appointment, health, relationship and clinical information to arrange and provide counselling or psychotherapy.
Lawful basis: Article 6(1)(b) — performance of the therapeutic contract — and Article 9(2)(h) for the provision or management of health or social care, subject to professional confidentiality.
Maintaining appropriate records
I keep administrative, clinical, risk and safeguarding records to provide a safe and professionally appropriate service and maintain an accurate record of the work.
Lawful basis: Article 6(1)(b), Article 6(1)(c) or Article 6(1)(f), depending on the circumstances. Article 9(2)(h) applies to relevant health information, and Article 9(2)(f) may apply where information is needed for a legal claim.
Managing risk, emergencies and safeguarding concerns
I may use contact, clinical, risk, emergency-contact and safeguarding information where this is necessary to respond to a serious concern about your safety or another person’s safety.
Lawful basis: Article 6(1)(c), Article 6(1)(d) or Article 6(1)(f), depending on the circumstances, together with the appropriate condition under Article 9.
Billing, accounting and tax
I use identity, contact, payment and invoice information to manage payments, accounts and tax obligations.
Lawful basis: Article 6(1)(b) for the therapeutic contract and Article 6(1)(c) for legal obligations.
Operating and protecting the website and business systems
I use limited technical and security information to operate the website, protect Shoreline’s systems and prevent unauthorised access or misuse.
Lawful basis: Article 6(1)(f) — my legitimate interests in operating and protecting a small professional practice.
Website analytics
If you consent, Squarespace Analytics and Google Analytics use cookie identifiers and website usage information to help me understand how visitors find and use the website.
Lawful basis: Article 6(1)(a) — consent. Non-essential analytics are not activated unless you choose to accept them.
Complaints, regulatory matters and legal claims
I may use relevant correspondence, administrative information and clinical records to respond to a complaint, meet a regulatory requirement or establish, exercise or defend a legal claim.
Lawful basis: Article 6(1)(c) or Article 6(1)(f), together with Article 9(2)(f) where special-category information is required for a legal claim.
Where I rely on legitimate interests, those interests include running and securing the practice, maintaining appropriate records, communicating with clients, and establishing or defending legal claims. I consider the likely impact on your rights before relying on this basis.
Consent to receive therapy is not the same as consent under data protection law. I do not rely on GDPR consent where another legal basis is more appropriate. Where I do rely on consent, such as for non-essential analytics cookies, you may withdraw it at any time.6. Health and other sensitive information
Information about physical or mental health is special-category personal data under the GDPR and receives additional protection. Where this information is needed to consider, arrange or provide therapy, I generally process it under Article 9(2)(h) of the GDPR for the provision or management of health or social care, subject to my professional duties of confidentiality.
Different conditions may apply where information is required to protect vital interests, meet a safeguarding or legal obligation, or establish, exercise or defend a legal claim. I will only use sensitive information where it is necessary and proportionate.
6. Health and other sensitive information
Information about physical or mental health is special-category personal data under the GDPR and receives additional protection. Where this information is needed to consider, arrange or provide therapy, I generally process it under Article 9(2)(h) of the GDPR for the provision or management of health or social care, subject to my professional duties of confidentiality.
Different conditions may apply where information is required to protect vital interests, meet a safeguarding or legal obligation, or establish, exercise or defend a legal claim. I will only use sensitive information where it is necessary and proportionate.7. Confidentiality and when information may be shared
What you bring to therapy is confidential. Confidentiality is central to my work, but it is not absolute. I may share relevant information where you have asked me to do so, where this is necessary to provide the service, where the law requires or permits it, or where there is a serious concern about your safety or another person's safety.
Depending on the circumstances, information may be shared with:
· service providers that support the secure operation of the website, communications, administration, storage or online sessions;
· my professional supervisor, normally using anonymised or minimised information wherever practicable;
· a parent or guardian where a young person is receiving therapy, within the confidentiality boundaries agreed at the beginning;
· a GP, health professional, emergency service or emergency contact where this is appropriate and lawful;
· Tusla, An Garda Síochána or another safeguarding or statutory body where disclosure is required or justified;
· a court, regulator or professional body where there is a valid legal or regulatory requirement; and
· an accountant, insurer or legal adviser where information is necessary for accounting, insurance, advice or legal claims.
I will share only the information reasonably necessary for the purpose. I do not sell personal information and I do not provide client information to advertisers.
7. Confidentiality and when information may be shared
What you bring to therapy is confidential. Confidentiality is central to my work, but it is not absolute. I may share relevant information where you have asked me to do so, where this is necessary to provide the service, where the law requires or permits it, or where there is a serious concern about your safety or another person's safety.
Depending on the circumstances, information may be shared with:
· service providers that support the secure operation of the website, communications, administration, storage or online sessions;
· my professional supervisor, normally using anonymised or minimised information wherever practicable;
· a parent or guardian where a young person is receiving therapy, within the confidentiality boundaries agreed at the beginning;
· a GP, health professional, emergency service or emergency contact where this is appropriate and lawful;
· Tusla, An Garda Síochána or another safeguarding or statutory body where disclosure is required or justified;
· a court, regulator or professional body where there is a valid legal or regulatory requirement; and
· an accountant, insurer or legal adviser where information is necessary for accounting, insurance, advice or legal claims.
I will share only the information reasonably necessary for the purpose. I do not sell personal information and I do not provide client information to advertisers.
8. Service providers
Shoreline currently uses Squarespace to host the website and provide website forms and analytics. Form submissions and technical website information may therefore be processed through Squarespace's systems.
The website also uses Google Analytics to understand, in aggregate, how visitors find and use the site. Google Analytics is treated as non-essential and is not activated unless you consent through the cookie banner. It is not used by Shoreline to create clinical profiles or for remarketing.
Other providers may be used for business email, secure record storage, accounting, appointment management, payments or online sessions. They will only receive information needed for their role and will be selected and managed with appropriate data-protection and confidentiality safeguards. If a new provider materially changes how your information is processed, this notice will be updated and, where appropriate, you will be informed before use.
9. International transfers
Some technology providers, including Squarespace and Google, operate internationally. This means that personal information may be processed outside Ireland or the European Economic Area. Where a transfer is made to a country that has not been recognised as providing an adequate level of protection, the provider must use an approved transfer mechanism, such as the European Commission's Standard Contractual Clauses, together with appropriate safeguards.
You may contact me if you would like further information about the safeguards relevant to a particular provider.
10. Couples, families and information about other people
Couple and family therapy can involve information about more than one person. A shared therapeutic record may therefore contain information provided by different participants as well as my professional observations. Each person's privacy and confidentiality will be considered when information is recorded, used, disclosed or accessed.
A request for access to a shared record does not automatically entitle one participant to receive another person's confidential information. Information may need to be withheld or redacted where disclosure would adversely affect another person's rights and freedoms or breach a duty of confidentiality.
If you provide information about someone else, please avoid sharing more than is reasonably necessary. Information discussed as part of therapy may still be recorded where it is relevant to understanding or providing the service.
11. Children and young people
I work with young people aged 10 and over. Their personal information receives the same legal protection as an adult's information, with additional care taken to explain privacy and confidentiality in language appropriate to their age and understanding.
Before therapy begins, I will explain what information may be shared with a parent or guardian and what can remain private. I will take account of the young person's age, understanding, wishes, safety and best interests, together with the rights and responsibilities of parents or guardians and any applicable legal or safeguarding obligations.
Confidentiality may need to be limited where there is a safeguarding concern, a serious risk of harm, or another legal reason to disclose information. I will explain these limits as clearly as possible before therapy begins.
12. Website forms and communications
You do not need to include detailed clinical information in an initial website enquiry. Please provide only what is needed for me to understand the general nature of your enquiry and respond safely. Website forms and ordinary email should not be used for emergencies or urgent safeguarding concerns.
I will use the contact method you provide and will take account of any preferences you communicate about voicemail, text messages or email. No method of electronic communication can be guaranteed to be completely secure, so particularly sensitive information may need to be discussed through a more appropriate channel.
13. Cookies and analytics
The Shoreline website uses cookies and similar technologies. Strictly necessary cookies support essential functions and do not require consent. Squarespace Analytics and Google Analytics are non-essential analytics tools and are used only if you choose to accept them.
Analytics information helps me understand matters such as visitor numbers, traffic sources, device type and which pages are useful. It is not intended to reveal why a particular person may be seeking therapy, and Shoreline does not intentionally send form contents or clinical information to analytics services.
You can accept, reject or manage non-essential cookies through the website's cookie banner. You can change or withdraw your choice at any time through the Cookie Settings option on the website. Withdrawing consent does not affect processing that took place before withdrawal.
Further information about the cookies used, their providers, purposes and duration is provided in Shoreline's Cookie Policy.
14. How long is information kept?
I do not keep personal information indefinitely. Retention depends on the type of record, the purpose for which it was created, the age of the client, professional and insurance requirements, safeguarding considerations and any legal or regulatory obligation.
· Enquiries that do not lead to therapy are normally retained for up to 12 months after the last meaningful contact, unless there is a safeguarding, complaint or legal reason to keep them longer.
· Adult therapy records are normally retained for seven years after the last date on which the service was provided.
· Records relating to children and young people are normally retained until the client reaches 25 years of age, or 26 if the client was 17 when therapy ended. A longer period may apply where required by law, safeguarding considerations, a professional body or professional indemnity insurance.
· Accounting and tax records are normally retained for six years, or longer where required by Revenue, an enquiry, investigation or legal process.
· Complaints, safeguarding records and material relevant to legal claims may be retained for longer where necessary and proportionate.
· Cookie and analytics information is retained according to the relevant provider settings and the periods described in the Cookie Policy.
When information is no longer required, it will be securely deleted, destroyed or anonymised. Retention periods may be suspended where records are needed for a complaint, safeguarding matter, investigation, legal claim or another lawful purpose.
15. How is information protected?
I use reasonable technical and organisational measures appropriate to the sensitivity of the information held. These include limiting access, using access controls and secure devices, applying data minimisation, maintaining secure storage and disposal arrangements, and selecting service providers with appropriate contractual and security safeguards.
No storage or communication system can remove every risk. If a personal-data breach occurs, I will assess it promptly and notify the Data Protection Commission and affected individuals where the law requires this.
16. Is information required?
You are not required to provide information merely to browse the website. If you make an enquiry or wish to begin therapy, some identity, contact, administrative and relevant clinical information will be needed to consider your request, communicate safely, enter into the therapeutic agreement and provide an appropriate service. If necessary information is not provided, I may be unable to offer or continue the service.
Analytics cookies are optional. Refusing them will not prevent you from using the main functions of the website or contacting Shoreline.
17. Automated decisions
Shoreline does not use automated decision-making or profiling to decide whether therapy will be offered or how therapy will be provided.
18. Your data-protection rights
Depending on the circumstances and legal basis, you may have the right to:
· ask whether I hold personal information about you and request a copy;
· ask for inaccurate or incomplete information to be corrected;
· ask for information to be erased;
· ask for processing to be restricted;
· object to processing based on legitimate interests;
· receive certain information in a portable format or have it sent to another controller;
· withdraw consent where processing is based on consent; and
· complain to the Data Protection Commission.
These rights are not absolute. For example, information may need to be retained to comply with a legal or professional obligation, protect another person's rights, maintain the integrity of a shared record, or establish, exercise or defend a legal claim.
To exercise a right, contact me using the details at the beginning of this notice. I may need to verify your identity before releasing information. I will normally respond within one month, although the GDPR permits an extension for particularly complex or numerous requests.
19. Complaints
If you have a concern about how your information is used, please contact me first so that I can try to address it. You also have the right to make a complaint to the Irish Data Protection Commission.
Data Protection Commission: 21 Fitzwilliam Square South, Dublin 2, D02 RD28
Website: www.dataprotection.ie
Telephone: +353 1 765 0100 or 1800 437 737
20. Changes to this notice
I may update this notice when Shoreline's services, providers or legal obligations change. The current version will be published on the website with its effective date. If a change materially affects existing clients, I will take reasonable steps to bring it to their attention.
Shoreline Counselling & Psychotherapy | Ana Planas Domínguez, sole trader | Version 1.0