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Privacy Policy – Insomnia Treatment (CBT-I Programme)

Effective Date: [21/10/20025]
Website: [https://www.insomniatreatment.ie/]
Data Controller: Myles Doyle, Summerhill, Co. Meath.
Email: myles@insomniatreatment.ie

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1. Introduction

This Privacy Policy explains how personal information is collected, used, and protected when you engage with the CBT-i (Cognitive Behavioural Therapy for Insomnia) programme, delivered by Myles Doyle, Psychotherapist (APCP).
Your privacy is respected and protected in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and the Data Protection Acts 1988–2018 (Ireland).

2. What Information Is Collected

(a) Personal Identification Information

  • Name

  • Email address

  • Phone number

  • Location (if relevant for scheduling)

(b) Therapy-related Information

  • Sleep logs and sleep efficiency data

  • Questionnaire responses

  • Therapy session notes (securely stored)

  • Progress updates or messages sent through online forms or WhatsApp links

(c) Technical Information (Website Use)

  • IP address and browser information (for security and analytics)

  • Cookies (see section 9)

3. How Information Is Collected

Information is obtained directly from:

  • Online booking or enquiry forms on the Insomnia Treatment website

  • Sleep log submissions through secure forms or WhatsApp links

  • Therapy sessions conducted via Zoom or phone

  • Email or text communications

4. Purpose and Legal Basis for Processing

Your data is processed to:

  • Deliver CBT-i therapy sessions and monitor your progress

  • Communicate regarding appointments and programme updates

  • Maintain clinical records in line with professional and ethical standards

  • Comply with legal obligations and professional codes of conduct

Legal bases: EU GDPR (Regulation (EU) 2016/679)

  • Article 6(1)(b): Performance of a contract (therapy agreement)

  • Article 6(1)(c): Compliance with legal obligations

  • Article 9(2)(h): Provision of health care or treatment by a professional under confidentiality

5. Data Storage and Security

All records are stored securely and confidentially:

  • Electronic records are encrypted and stored on password-protected devices.

  • Sleep logs submitted through online forms are stored in secure, encrypted cloud storage compliant with GDPR.

  • Notes are kept for seven years after therapy ends (as per professional guidelines) and then permanently deleted.

6. Sharing of Information

Information is never shared with third parties for marketing or commercial purposes.
Limited sharing may occur only when:

  • Legally required (e.g. a court order or safeguarding concern)

  • You provide written consent to share information with your GP or another healthcare professional

7. Your Data Protection Rights

Under GDPR you have the right to:

  • Access your personal data

  • Request correction of inaccurate data

  • Request deletion (“right to be forgotten”)

  • Restrict or object to processing

  • Receive a copy of your data in a portable format

Requests can be made by email to mtdpsychotherapy@gmail.com and will be addressed within 30 days.

8. Communication Platforms

  • Zoom sessions use encrypted video links; no recordings are made without explicit consent.

  • WhatsApp sleep logs use end-to-end encryption. You may withdraw from this digital method at any time and switch to a paper or email log.

  • Email correspondence is kept minimal and factual.

9. Cookies and Analytics (Website)

The Insomnia Treatment website may use basic analytics tools (e.g., Google Analytics) to understand website usage.
Cookies are small text files stored on your device to enhance functionality. You can disable cookies through your browser settings.

10. Children and Vulnerable Persons

The Insomnia Treatment programme is designed for adults (18+). 

11. Data Breach Procedure

In the unlikely event of a data breach, affected individuals and the Data Protection Commission (DPC) will be notified within 72 hours in compliance with GDPR Article 33.

12. Updates to This Policy

This Privacy Policy may be updated periodically. The most current version will always be available on the Insomnia Treatment website.

Contact

If you have any concerns or wish to exercise your data rights, please contact:
Myles Doyle, 
Summerhill, Co. Meath, Ireland
Email: myles@insomniatreatment.ie

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