Patient Privacy Policy

Who we are

We are Core Education Limited, a company registered in the Republic of Ireland under the number 628132 at 25 Coote Street, Portlaoise, Co Laois, trading under the name Core College (“Core College”, “we”, “us”, “ours”). We are an educational and herbal medicine establishment providing consultations to the members of the public in our natural healing clinic in Portlaoise (“Clinic”).

We respect your privacy and are committed to protecting your personal data. This privacy statement will inform you as to what data in relation to you we may collect and use in connection with your treatment in the Clinic, and tell you about your privacy rights.

Core College is the controller of your personal data.

Personal Data that we collect about you

“Personal data” means any information about an individual from which that individual can be identified. It does not include data where the identity has been removed, i.e. anonymous data.

In order to conduct a consultation with you in our Clinic and provide you with an advice and appropriate treatment we need to collect, use and store the following categories of personal data about you:

Identity Data including your name and date of birth.
Contact Data including your home address, email address and telephone number.
Transaction Data includes details about payments from you and other details of products and services you have purchased from us.
Health Data including your symptoms, past and present medical conditions and medication, clinical notes. We would like to draw your attention to the fact hat Health Data is a special category of personal data under the existing data protection legislation, and we may not collect or use it without your express consent.
A photograph of your iris. An iris picture is an assessment tool used in our Clinic that points to the key areas of the emotional and physical health of a person that may need attention.

If you fail to provide to us your personal data

If you fail to provide to us any personal data listed above, we may not be able to provide our services to you. In this case, we may have to cancel a service you have requested from us but we will notify you if this is the case at the time.

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

How we collect your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful purpose and have more than one lawful basis for processing.

Type of data	Purpose of use	Lawful basis for processing
Identity Data and Contact Data	To register your as a new patient	Performance of our contract with you
	To contact you in relation to your consultation or treatment
	To deliver our herbal remedies to you
	To manage our relationship with you which, e.g. notifying you about changes to our terms or privacy statement
	To satisfy legal, regulatory, tax, accounting or reporting requirements	Compliance with our legal obligation
	To process your payment for our products and services	Our legitimate interests (to collect payment for our products/services).
	To make suggestions and recommendations to you about goods or services that may be of interest to you	Our legitimate interests (to develop our products/services and grow our business).
Contact Data	To register you as a new patient	Performance of our contract with you
	To contact you in relation to your consultation or treatment
	To deliver our herbal remedies to you
	To manage our relationship with you which, e.g. notifying you about changes to our terms or privacy statement
	To satisfy legal, regulatory, tax, accounting or reporting requirements	Compliance with our legal obligation
	To process your payment for our products and services.	Our legitimate interests (to collect payment for our products/services)
	To make suggestions and recommendations to you about goods or services that may be of interest to you	Our legitimate interests (to develop our products/services and grow our business)
Transaction Data	To process your payment for our products and services	Our legitimate interests (to collect payment for our products/services)
	To satisfy legal, regulatory, tax, accounting or reporting requirements	Compliance with our legal obligation
	Understanding your health conditions;
	Suggesting a particular diet, herbal remedy and healing regime;
Health Data	Understanding your health conditions;	Your consent
	Suggesting a particular diet, herbal remedy and healing regime;
	To respond to your queries in relation to your treatment or remedies;
	To use it as a clinical example for the students attending your consultation
Iris picture	Conducting consultation with you in our Clinic;	Your consent
	Understanding your health conditions;
	Suggesting a particular diet, herbal remedy and healing regime.
	To respond to your queries in relation to your treatment or remedies.
	To use it as a clinical example for the students attending your consultation

Research & Publication

We may use your Health Data and Iris picture for research and publication purposes to promote herbalism and natural healing, on an anonymous basis (so that it can no longer be associated with you) in the format such as “60 years old female with osteoporosis”.

Education

Private Consultations. If you chose to have a private consultation with a Herbalist, he or she will be assisted by a senior student to ask you initial questions and may be instructed by the Herbalist to give you a diet advice, however, the assistant will not be involved in the actual consultation.
Group Consultation. If you chose to have a group consultation there will be a group of students observing the consultation. The actual consultation is carried out by a Herbalist assisted by a senior student.

All our students are mature adults, trained to respect our Clients’ confidentially and protect their personal data.

Your consent

We do rely on your consent as a legal basis for processing of your Health Data and your Iris picture. You have the right to withdraw consent to our processing of your Health Data at any time by contacting us. Please be aware that if you chose to withdraw your consent then we will not be able to have any subsequent consultations with you or advise you on any specific methods of treatment.

Marketing

We may use your Identity and Contact Data to inform you about the products, services and course offers that may be of interest to you.
You may receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We will not share your personal data with anyone other than the persons listed below for the purposes specified above.

Students attending your consultation;
Clinic staff;
Third-party service providers such as mail couriers, software providers, our accountant;
State, government or regulatory bodies that control our compliance with the legislation.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our students, staff or the third parties to use your personal data for their own purposes and only permit them to process your personal data for specified purposes outlined above and in accordance with our instructions.

International transfers

We do not transfer your personal data outside the European Economic Area (EEA) except when your data is stored in our electronic system and the software is located on the server outside the EEA but we always ensure that the software provider has protection measures required by the legislation in place.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those students, staff and other third parties who have a need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and the Irish Data Protection Commission of a breach where we are legally required to do so.

How long will we retain your personal data for?

We will only retain your personal data for the duration of your relationship with us and for such period of time thereafter as is necessary to comply with our legal obligations or where we are expressly allowed to do so by law.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

Right to Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Right to Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Right to Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Right to Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at +353 57 8682567.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Complaints

If you have any queries or complaints in connection with our processing of your personal data, you can contact us at +353 57 8682567. You also have a right to lodge a complaint with the Irish Data Protection Commission if you are not happy with the way we have used your information or addressed your rights. Details of how to lodge a complaint can be found at https://www.dataprotection.ie/ or you can call the Data Protection Commission at 353 (0)761 1048000.

Updates

We may update this Privacy Statement from time to time. When we change this Privacy Statement in any material way, a notice will be posted on our website http://www.corecollege.com along with the updated privacy statement.