Privacy Notice for Counselling Clients

ACCORD Dublin Catholic Marriage Care Service clg, is a voluntary organisation operating in the Catholic Archdiocese of Dublin.
It  offers individuals and couples a safe, ethical and professional counselling service to support them to address difficulties and challenges in their marriage, relationships and family life.

We work directly with you to offer marriage and relationship counselling services. We respect your privacy and are dedicated to ensuring that the support and services we provide, reflect our commitment to treat all information shared with us with the utmost respect, sensitivity and confidentiality.

  1. What information does ACCORD Dublin collect about me?

Personal data is any information which identifies you, whether directly, (for example, your name), or indirectly, (for example, a case reference number, address, date of birth). All of the personal data which we collect is obtained from you directly, for example in writing by completing a form, making an enquiry or verbally during a session. There are 3 key stages in the assessment and counselling process that are relevant to the collection of your information:-

The personal data which we collect varies as you progress through each stage of the process and may include information which is considered to be ‘special category data’ such as information on your health, sex life, religious beliefs or political opinions.
A general overview of the information which we collect at each stage is set out below.

First Contact, Assessment Process and Counselling

  1. a) First Contact Information at this stage is limited to data which is necessary to make an appointment for you e.g. your name(s), preferred contact number and, possibly, your email address.
    You may also notify us of any disability or special requirement you may have in anticipation of your attendance at one of our Centres

  3. b) Assessment Process

At the commencement of the Assessment Process, your counsellor will  complete a Client/s Index Card which includes a section requiring your  written consent to enable us to process your personal data. The Client/s Index Card also records:

  • Case Reference Number
  • Name, address and contact number/s of client/s.
  • Name and contact number for an emergency contact person
  • Contact number for GP
  • Date of commencement of Assessment
  • Counsellor’s name

Spaces are provided for the following to be added at the end of the counselling work:

  • Number of joint sessions (if applicable)
  • Number of sessions with male only
  • Number of sessions with female only
  • Date counselling finished

A Client Needs Assessment Questionnaire will be completed with each client.

We ask you to share with us why you are seeking couples and relationships counselling and why you are seeking it now.

Following the initial Assessment session, your counsellor will complete and set up a Client File for the case. This file is labelled with the Case Reference Number from the Client/s Index Card.

The assessment phase may be continued for a further session, or sessions,  when each client is seen individually to complete a further questionnaire- based Assessment that gathers information on behaviours within the couple relationship. In some cases this second phase of assessment may take place after counselling has commenced.

  1. c) Counselling

Brief Case Notes are written following each client session in an official ACCORD Dublin Case Notes booklet, which carries the case reference number and does not contain any identifying information relating to the client/s.

At regular intervals during the counselling process you will be invited to complete Review Questions to monitor your relationship satisfaction.

  1. Why does ACCORD Dublin need my information?

Processing personal data is necessary so that we can provide effective counselling services, tailored to the needs of each individual client and each couple. When we process your information, we do so to understand your needs and expectations from counselling, to assist with clinical assessment, and monitor progress as part of a meaningful and holistic service.

We also maintain records to meet safeguarding requirements for children, young people and adults at risk; to supervise and audit our processes; to gather statistical information for research and future service provision; and to implement robust policies and practice within ACCORD Dublin. These tasks are necessary so that we can fulfil our wider legal obligations in terms of corporate governance, company and charity law.

Please note that information which has been gathered for statistical purposes is always anonymised.

  1. What is the legal basis for processing my personal data?

ACCORD Dublin relies upon your explicit consent as the legal basis to process your personal data and as a condition of any processing activities associated with special category data.

This consent is obtained in writing at the assessment stage before counselling begins. We also rely upon our legitimate interests as a charitable organisation, compliance with our legal obligations and in extreme scenarios, to safeguard and protect an individual’s vital interests.

  1. Who has access to my records within ACCORD Dublin?

Your data is treated in the strictest confidence.

We have stringent protocols in place regarding the handling and storage of client records. All counselling records must be stored in the ACCORD Dublin Centre where the case is being handled. Access to client records is controlled and limited to authorised personnel only, (typically the practicing Counsellor responsible for your case or an authorised officer from ACCORD Dublin or in exceptional circumstances those specified in Section 5).

All reasonable security measures are taken to prevent unauthorised access or disclosure including a general prohibition against removing client records and case notes from the centre.

All of our Counsellors attend routine supervision; however, the Supervisor does not have access to any client records.

  1. How long does ACCORD Dublin store my information?

Client/s Index Cards are retained for 7 years. All case notes are shredded by the counsellor, or where circumstances prevent this, by our Privacy Officer (see section 9) and a member of the Centre Committee. All case notes are securely destroyed on expiry of 1 year from the end of your counselling sessions, unless a safeguarding issue has arisen, in which case the notes are sealed and retained indefinitely marked “Not to be shredded”. Case files are stored in date order for efficient and secure disposal.

  1. Does ACCORD Dublin share my information with outside third parties?

We collaborate with our affiliated companies in the Republic of Ireland and Northern Ireland, (Accord CLG and Accord NI CLG) on issues of service delivery, quality assurance and pastoral care. We do not share your personal data with any third parties unless one of the following conditions apply:

(i)  you have provided your explicit consent;

(ii)  a disclosure is required in accordance with the law to a third party such as a Court or Tribunal, a government department or agency, the Police/ An Garda Síochána is required, for example: in pursuit of justice in the prosecution of a criminal offence;

(iii)  intervention is necessary for matters of life or death or for the prevention of harm to you or any individual or child; or

(iv)  when it is necessary to report an allegation, concern or suspicion of abuse to the relevant Church authority.

(v)  In the Republic of Ireland, as mandated persons ACCORD Dublin counsellors are legally obliged, under the Children First Act 2015, to report child protection concerns and retrospective disclosure of abuse (including (iv) above) to Tusla, Child and Family Agency. Mandatory reporting is done jointly by the ACCORD Dublin counsellor and the ACCORD Dublin Designated Liaison Person. If you have concerns in relation to mandatory reporting, your counsellor will provide you with information and support in relation to this legal obligation.

In most instances, a request of this nature will not involve direct access to your case file and will instead seek confirmation of your attendance at counselling.

A request made by a third party acting on your behalf, such as your solicitor, must be accompanied by a signed form of consent before any disclosure will be made.

Every request will be considered carefully by ACCORD Dublin. The information furnished may be redacted if it would interfere with the rights of another individual including,
but not limited to your spouse, child or other family member.

  1. Is my personal data transferred outside of the European Economic Area?

ACCORD Dublin does not transfer any personal data information outside of the European Economic Area (“EEA”). Anonymised research material may be available to third level institutions outside the EEA including, but not limited to, the USA and Canada.

  1. What legal rights do I have in relation to the personal data held about me by ACCORD Dublin?

You have the right to view the personal information which we hold about you, including your case notes. You can contact us by telephone, letter or email if you wish to examine what we hold about you. We will require written verification of your request and identity. As explained above, every request will be considered carefully by ACCORD Dublin. The information furnished may be redacted if it would interfere with the rights of another individual including, but not limited to your spouse, child or other family member. You can also contact us if you believe that any information we have collected is incorrect or incomplete. Steps will be taken to correct any inaccurate information that we hold.

There is no charge to access this information and a response will be provided within one calendar month.

If you have provided us with consent to process your data, you can withdraw that consent at any time. If we are processing your information in accordance with our legitimate interests, you can object to further processing.

  1. How can I contact ACCORD Dublin if I have any questions about how it handles my personal data?

Legal responsibility for all decisions regarding the purpose and means of processing personal data rests with the ‘Data Controller’. ACCORD Dublin is the Data Controller.

If you require any further information on this notice or data protection within ACCORD Dublin please contact:-

Privacy Officer
ACCORD Dublin Catholic Marriage Care Service clg

Holy Cross Diocesan Centre
Clonliffe Road
Dublin D03 P2E7

  1. What can I do if I wish to make a complaint?

We are committed to finding a fair and lawful resolution to any problems or complaints which arise in the course of data processing. Please report any concerns you have to the Privacy Officer within ACCORD Dublin using the above contact details.

If your complaint cannot be resolved by ACCORD Dublin or if you feel that it has not been resolved to your satisfaction, you have the right to complain to the Data Protection Commission.

Further information can be found online via