Brighter Future A.T. Privacy Statement

Your privacy is important to us. This privacy statement explains about the types of personal data that Brighter Future A.T. processes, how we process it, and for what purposes. Brighter Future A.T. is a consultancy service which offers assessment, advice and/or training in the area of Assistive Technology.

Personal Data We Collect From Clients

Brighter Future A.T. collects personal data as part of conducting a professional service. Personal data collected would fall under the following headings:

1. Healthcare data (e.g. medical diagnoses, details of other healthcare professionals involved)
2. Educational data (e.g. details of educational institution being attended and contact details of key personnel)
3. Employment data (e.g. details of job title and responsibilities in role)
4. Clinical data (data related specifically to your assistive technology assessment and training)
5. Administrative data (e.g. dates of attendance/non-attendance, contact details for client/guardian/carer)
6. Financial data (e.g. receipts, invoices, electronic/paper evidence of bank transfers for fees)

It will be collected in a number of ways:

1. Face-to-face
2. By phone (phone call, voicemail or text message)
3. By email
4. By video call
5. By referral from other agencies (via phone, email or face-to-face)
6. By pre-assessment forms received by either email or post
7. From the Brighter Future A.T. website (by click-through to email or phone from the contact page of the website)
8. From the online banking website/ app of the financial banking institution used by Brighter Future A.T.
9. By taking photographs or videos of clients in face-to-face or video call appointments

The legal basis for collecting the majority of this data is that it is necessary to in order to fulfil the contract of providing an assistive technology assessment and/or training service for you.

However, in some situations data is desirable but not necessary in order to fulfil this contract. At the start of the assessment/ training process, you (or your guardian) will be given a Consent Form which will allow you to opt-in or out of collection and/or sharing of these types of data. You are free to choose which types of data you wish to share or not, and are free to withdraw your consent at any time by contacting Brighter Future A.T.

How and Why We Use and Share Personal Data

Personal data will be used for the purposes of providing assistive technology assessment and/or training and to maintain the general running of the business (e.g. to keep accounts, or to update you or your guardian on any changes in policies or fees).

Brighter Future A.T. will not share personal data with companies, organisations or individuals unless one of the following circumstances applies:

1. Opt-in consent has been obtained from you (or your guardian) using the Brighter Future A.T. Consent form.
2. If particular information is required to be disclosed by law.
3. To meet financial requirements (e.g. disclosing information to a GDPR-compliant tax consultant to meet Revenue tax filing requirements).
4. For processing by GDPR-compliant third parties (e.g. when using web-based appointment scheduling or web-based invoicing). Some of your information being processed by these third parties may be held outside the EU (e.g. Google or Gmail). In these cases every effort will be made to ensure that these data processing companies are GDPR-compliant or have data protection processes in place that are considered adequate by GDPR).
5. To protect Brighter Future A.T. and its staff or clients.

Personal data will be used or shared by phone call, voicemail, text message and email, but always in the most secure method possible to ensure your privacy. Sometimes it may be necessary to share information over third party websites or apps (e.g. if using online invoicing apps or if using Google Maps to locate addresses) but Brighter Future A.T. will always endeavour to use GDPR-compliant websites or apps and if the information used by these websites or apps will be held outside the EU, we will endeavour to ensure that these data processing companies are GDPR-compliant or have data protection processes in place that are considered adequate by GDPR).

Information On Website Cookies

A cookie is a small piece of data that may be stored on your computer or mobile device. Brighter Future A.T.’s website uses a security plug-in called Wordfence which uses cookies for the following functions:

• “Live Traffic” cookie: to determine if someone is a human or a bot, to identify repeat visitors and to display this in the Live Traffic feed.
• Country Blocking cookie: to bypass Country Blocking.
• Session cookie: to remember if someone is a logged in user (confirming which user role they have) to prevent them from getting blocked by accident while working in WordPress admin.

This technical information received via these cookies will be used only by Brighter Future A.T. and only for statistical and other administrative purposes.

How To Access And Control Your Personal Data

If you wish to obtain further details on your personal data that is being processed by Brighter Future A.T., you are entitled to contact Brighter Future A.T. with a Subject Access Request and this will be pursued subject to the regulations of GDPR.

You have the right to Data Portability. This means that you have the right to receive the personal data concerning you which you have provided to Brighter Future A.T. in a structured, commonly used and machine-readable format and have the right to transmit that data to another data controller.

If you wish to exercise your Right to be Forgotten, please contact Brighter Future A.T. and we will advise you as to which data can be lawfully deleted and which data would be required to be retained for 7 years post-completion of work.

You also have the Right to Rectification. If you feel that any personal data that we hold on your case is incorrect, please contact us and we will take whatever measures we can to rectify the mistake.

If you are not happy with any of the personal data that is being processed on your behalf by Brighter Future A.T., you have a Right to Object. Please contact us in this situation and we’d be happy to help in any way we can.

If you are not satisfied with the measures we take to process your personal data or to rectify any mistakes in your personal data, you have a right to lodge a complaint with a supervisory authority (i.e. the Data Protection Commissioner).

How We Protect Your Personal Data

Personal data will be held securely using the following methods:

1. All notes, emails, photo printouts and all data pertaining to client paper files will be stored in a locked filing cabinet.
2. Client electronic files will be stored on encrypted external hard drives. Mobile phones used will also be password-protected.
3. When outside of the office base, paper files and electronic files with your personal details will not be left where individuals not involved in your case could see them.

If there is any breach in the security of your personal data, this breach will be reported to the relevant supervisory authority (i.e. the Data Protection Commissioner) without undue delay and where feasible within 72 hours, according to the regulation of GDPR. You will also be informed of any breach relevant to you if the breach is of a nature that GDPR specifies that the data subject should be notified.

How We Dispose Of Your Personal Data

Your records will be held securely for a period of 8 years after conclusion of treatment or death, or if the person receiving treatment is a child, the records will be retained until her/his 25th birthday or 26th birthday if she/he was 17 at the conclusion of treatment, or 8 years after death (according to the recommendations of the HSE Record Retention Policy). After this, your paper files will be shredded and your electronic files will be deleted.

If you have any concerns at all about using our website or if you are a client of Brighter Future A.T. and you have any concerns about how your personal data is being collected, processed, shared, protected or disposed of, please contact us on hilary@brighterfutureat.ie or 086 1959899 and we will be happy to discuss any questions or concerns. Thank you for reading this Privacy Statement.

21st April 2022