Introduction

Thérapie Fertility is committed to protecting the privacy of your personal data and to handling your personal data in a transparent and responsible manner in accordance with the General Data Protection Regulation (GDPR, EU – 2016/679) and with the Irish Data Protection Act 2018.

This Privacy Notice explains how and why we collect, process and disclose your personal data. It also outlines your rights in relation to your personal data. Please read the following carefully.

This Privacy Notice is current from 14/03/2022. From time to time we may make changes to our policy, processes and systems in relation to how we handle your personal data. We will update this Privacy Notice to reflect any changes. Those changes will be available on our website and in the clinic.

Controller contact details

Thérapie Fertility is a trading name for Thérapie Fertility Limited.  (Company Registration Number: 507410) who is the controller for the personal data we process unless otherwise stated. Thérapie Fertility is part of the Thérapie Medical Group as a subsidiary of Thérapie Medical Ltd.

Data Protection Officer’s contact details

Our Data Protection Officer is Cyrille Kuster. You can contact him at dpo@therapiefertility.com or via our postal address. Please address the envelope to ‘Data Protection Officer’.

The type of personal data we collect

Personal data refers to information relating to an identified or identifiable person. It does not include data that has been anonymised and cannot be traced to an identified or identifiable person.

We currently collect and/or process the following personal data:

• Identifying and Demographic Information: Full name, Date of Birth, gender, address, PPS number, DPS number, insurance information, phone number(s) and email address.
• Medical and Health Information (Special Categories Personal Data): physical and mental health, test results, disabilities, family or individual health history, medical information relevant to your treatment at the clinic, blood type, ultrasound pictures, drugs prescriptions.
• Relationship and Sexual Information (Special Categories Personal Data): Sex life information, information regarding sexual orientation and relationship
• Financial Information: Payment preference, bank account details, credit cards information
• Digital Images: Photograph used to perform visual confirmation of identification, CCTV images (also ultrasound or hysteroscopy images, images of your eggs, embryos or sperm.
• Communication: Record of interaction between patients and clinic such as consultations, emails, phone calls and posts; Phone call recordings; voicemails; emails.
• Patient Preferences and Feedback: opinions and intentions disclosed during communication with clinic, satisfaction survey responses, complaints
• Electronic Device Information: IP Address and Cookies Information when visiting our website (for more information please see our Cookies Policy)

How we get your personal information

Most of the personal information we process is provided to us directly by you from the following sources:

• Website Contact Form
• Website visits through cookies (See our Cookies Policy for more details)
• Phone or email queries
• Information you sent us on the Patient Registration Form and Health Questionnaires
• Information communicated to and by you throughout your treatment
• Information collected from testing and scanning you have throughout your treatment

In some occasions we will also receive personal information indirectly from third parties such as:

• GP or other specialist referral
• Test results related to you performed by a third party healthcare provider or laboratory

Special Categories Personal Data

As part of your treatment with Thérapie Fertility, we will need to collect and process information concerning your health and concerning your sex life or sexual orientation. On some occasions, if required for treatment, we may also need to process information regarding your ethnicity and genetic data.

These information are considered Special Categories Personal Data under GDPR. As such we will only process your Special Categories Personal Data after you have given explicit consent to the processing of those personal data for the purpose of your treatment with us.

How we store your personal information

Your information is securely stored within our Patient Electronic Database System which also include the integration of our Web Patient Portal.

The number of paper records processed at Therapie Fertility will be very limited and will be stored internally in our secure facility at Thérapie Fertility Facilities.

All personal information necessary for traceability purposes in relation to the gametes and embryos processed at Thérapie Fertility will be kept for 30 years after clinical use as per EU Directive 2004/23/EC and Irish Regulation S.I. No. 158/2006.

Phone call recordings will be securely stored onsite in Thérapie Fertility and will be deleted after 3 months.

CCTV recordings will also be securely stored onsite in Thérapie Fertility and will be deleted after 28 days.

Who we share your personal data with

In order to provide you with best quality of care as well as ensuring the compliance with legal obligation, some of your personal data will be shared on the need to know basis with the following third parties:

• Testing laboratories or other healthcare providers that require your personal data as part of the provision of medical treatment;
• Service providers, and other third party advisors (i.e. legal advisor, insurance) that have access to your personal data as a necessary and controlled part of the provision of service;
• Other companies of the Thérapie Medical Group (Thérapie Medical Ltd) that have access to some of your personal data as a necessary and controlled part of the provision of service and clinic operation (i.e. IT Services, Marketing services, Financial services).

Regulatory bodies and Accreditation bodies such as HPRA and JCI.

If you wish to obtain more information on third parties with whom your data may be shared, please contact our Data Protection Officer (dpo@therapiefertility.com).

We will not share your personal data outside the European Union or European Economic Area without your prior consent and we would ensure appropriate safeguards are in place to protect your personal data as per GDPR Article 46.

Your data protection rights

Under data protection law, you have rights including:

• Your right of access – You have the right to ask us for copies of your personal information.
• Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances. This right is not absolute as some data must be kept following other legal obligations such as EU Tissue and Cell Directive 2004/23/EC.
• Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
• Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances.
• Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at dpo@therapiefertility.com if you wish to make a request.

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us at dpo@therapiefertility.com.

You can also complain to the Data Protection Commission (DPC) if you are unhappy with how we have used your data.

Data Protection Commission Details:

Telephone: +353 (0)761 104 800 or Lo Call Number 1890 252 231

Email: info@dataprotections.ie

For further information please visit www.dataprotection.ie