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Data Protection Policy

Committed to Protecting your Data


Cullen Hanly family practice wants to ensure the highest standard of medical care of our patients. We understand that confidentiality is a fundamental principle of medical ethics and is central to the trust between patients and doctors. The privacy practices we adopt in our practice are in line the Medical Council guidelines, the privacy principles of Data Protection legislation. We see our patients’ consent as being the key factor in dealing with their health information. This statement is about making consent meaningful by advising you of our policies and practices on dealing with your medical information.

Here in Cullen Hanly family practice, we have set out a summary of this policy in our Data Protection Patient Information Leaflet which was provided to you at the time of registering with the practice. That leaflet should be read in conjunction with this policy.

Managing your information
  • In order to provide for patients care we need to collect and keep information about patients and their health on our records.
  • We commit to retaining patient information securely.
  • We will only ask for and keep information that is necessary. We will attempt to keep it as accurate and up to date as possible. We will explain the need for any information we ask for if a patient is not sure why it is needed.
  • We ask all patients to inform us about any relevant changes that we should know about. This would include such things as any treatments or investigation being carried out that we are not aware of. Patients are asked to inform us of change of address and phone numbers.
  • All persons in the practice (not already covered by a professional confidentiality code) sign a confidentiality agreement that explicitly makes clear their duties in relation to personal health information and the consequences of breaching that duty.
  • Access to patient records is regulated to ensure that they are used only to the extent necessary to enable the employee in question, whether secretary, manager, or healthcare professional perform their tasks for the proper functioning of the practice. In this regard, patients should understand that practice staff may have access to their records for:
  • Identifying and printing repeat prescription for patients. These are then reviewed and signed by the GP.
  • Generating a social welfare certificate for the patient. This is then checked and signed by the GP.
  • Typing referral letters to the hospital consultants or allied health professional such as physiotherapists, occupational therapists, psychologists and dieticians.
  • Opening letters from the hospitals and consultants. The letters could appended to a patient’s paper file or scanned into their electronic patient record.
  • Scanning clinical letters, radiology reports and any other documents not available in electronic format.
  • Downloading laboratory results and out of Hours Coop reports and performing integration of these results into the electronic patient record.
  • Photocopying or printing documents for referral to consultants, attending an antenatal clinic or when a patient is changing GP.
  • Checking for a patient if a hospital or consultant letter is back or if a laboratory or radiology results is back, or in order to schedule a conversation with the GP.
  • When a patient makes contact with a practice, checking if they are due for any preventative services, such as vaccination, antenatal visit, contraceptive pill check, cervical smear tests, etc.
  • Handling, printing, photocopying and postage of medico legal and life assurance reports, and of associated documents.
  • The practice is committed to guarding against accidental disclosures of confidential patient information. Before disclosing identifiable information about patients, the practice:
  • Take into consideration Freedom of Information and Data Protection principles.
  • Be clear about the purpose for disclosure.
  • Have the patient’s consent or other legal basis for disclosing the information.
  • Have considered using anonymised information and be certain it is necessary to use identifiable information.
  • Be satisfied that we are disclosing the minimum information to the minimum amount of people necessary.
  • Be satisfied that the intended recipient is aware the information is confidential and that they have their own duty of confidentiality.

Disclosure with Consent
  • If a patient is capable of making their own decisions about their healthcare, we will get their consent before giving confidential information that identifies them to the patient’s relatives close friends, or for research or to disease registers.
  • If the patient does not consent to disclosure of identifiable information we will respect that decision except where failure to make the disclosure would put the patient or others at risk of serious harm or the disclosure is required by law or in the public interest as outline below.
  • Patients should understand and accept that their healthcare information must be shared within the healthcare team and with support staff to provide effective and safe care. If disclosure of a patient’s information within our practice or to other health care providers is necessary as part of a patient’s treatment and care, we will explain this to the patient and disclose the information to an appropriate person making sure they are aware of their duty of confidentiality. If a patient objects to the transfer of the information we deem necessary we will explain to the patient that we cannot arrange referral or treatment without disclosing the information.
  • We recognise that clinical audit, quality assurance, education and training are essential for providing safe and effective healthcare. If we are providing patient information pursuant to of any of these activities, we understand the information must be anonymised or coded before it is disclosed outside the healthcare team. If that is not possible we will make sure a patient is told about the disclosure in advance and given the opportunity to object. We will respect a patient’s wishes in respect of the disclosure.
Medical Reports
  • We will only prepare a medical report on a patient with a patient’s consent. A report will be specific to the episode for which the report has been requested. We understand that a medical report requested by third party such as an employer, insurance company or legal representative must be factual, accurate and not misleading. We will seek to ensure that the patient understands the scope and purpose of the report and that the GP cannot omit relevant information.
  • We will also seek to ensure the patient is aware of our duty of care to them and to the person/company from whom the report was requested. We will take the patient through the report before we release it so the patient appreciates the extent of the information we are reporting upon.
  • We are committed to ensuring that any audio, visual or photographic recordings of a patient or relative of a patient, in which the person is identifiable, should only be made with express consent of that person. The recordings will be kept confidential as a part of the patient’s record of consent. We will do all we reasonably can to protect confidentiality of the recording. We will get consent before sharing such videos, photos or other images of a patient.
  • We will only take images of patients on a GP’s personal mobile device when necessary for the patient’s care. Such images will not identify a patient and shall only be kept for the minimum time necessary.
Medical Certificates
  • In general, work related Medical Certificates from a GP will only provide a confirmation that a patient is unfit for work with an indication of when the patient will be fit to resume work. Where it is considered necessary to provide additional information we will discuss that with the patient. However, Social Worker Certificates of Incapacity for work must include the medical reasons the patient is unfit to work.
Your Data Protection Rights

Under Data Protection legislation, you have the right to:

  • Withdraw consent to the processing of your personal information.
  • [Note: If you withdraw consent, we may not be able to continue to provide treatment and service to you. We will talk to you about the possible consequences of withdrawing consent. If and when you let us know that you are thinking of this. The withdrawal of consent will not undermine the lawfulness of processing carried out prior to the withdrawal.]
  • Request to access the information we hold about you.
  • Request the correction of inaccuracies in/erasure of the information we hold about you.
  • Request the restriction of processing of the information we hold about you.
  • Exercise your entitlement to data portability.
  • Make a complaint to the Office of the Data Protection Commissioner of Ireland.
  • Please address any rights requests by email to
  • Cullen Hanly family practice registered Data Protection Officers are Edel Higgins & Mary Fitzgerald. Any queries, concerns or requests to exercise your rights under Data Protection legislation may be addressed to:

    Dr. Sarah Clifford,
    15 Pery Square,
Transferring to Another Practice
  • If you decide at any time and for whatever reason to transfer to another practice we will facilitate that decision by making available to your new doctor a copy of your records on receipt of your signed consent from your new doctor. For medico-legal reasons we will also retain a copy of your records in this practice for an appropriate period of time which may exceed eight years.
  • This website does not use cookies.
  • This website uses cookies to better the users experience while visiting the website. Where applicable this website uses a cookie control system allowing the user on their first visit to the website to allow or disallow the use of cookies on their computer/device. This complies with recent legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user’s computer/device.
  • Cookies are small files saved to the user’s computers hard drive that track, save and store information about the user’s interactions and usage of the website. This allows the website, through its server to provide the users with a tailored experience within this website.
    Users are advised that if they wish to deny the use and saving of cookies from this website on to their computers hard drive they should take necessary steps within their web browsers security settings to block all cookies from this website and its external serving vendors.
  • This website uses tracking software to monitor its visitors to better understand how they use it. This software is provided by Google Analytics which uses cookies to track visitor usage. The software will save a cookie to your computers hard drive in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal information. You can read Google’s privacy policy here for further information [ ].
  • Other cookies may be stored on your computers hard drive by external vendors when this website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected.


This privacy statement relates to Hanly Doctors practices in connection with our website ( and is designed to assist you in understanding how we collect, use and safeguard the personal information you provide to us and to assist you in making informed decisions when using our site and our services. Hanly Doctors fully respects your right to privacy. We will not collect personal information/personal data about you when you visit our website unless you choose to provide that information using any of the website forms (i.e. Contact, Appointment, Prescription, Feedback, etc.).

By using this site, you consent to the collection and use of your information under the terms of this privacy statement which is in accordance with the Data Protection Acts 1988 to 2018, the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011 and the EU General Data Protection Regulation (GDPR). Please read the following privacy statement to understand how we use and protect the information that you choose to provide to us.

What Information Do We Collect?

When you visit our website you may provide us with two types of information:

  • Personal information you knowingly choose to disclose that is collected on an individual basis, and
  • Statistical web site use information collected on an aggregate basis as you and others browse through our website. All IP addresses are anonymised which means that data cannot be associated to or affiliated with any website visitor thus ensuring your privacy.

Information, Personal And Non-Personal, You Choose To Provide

When you visit our website you may wish to provide certain information about yourself, such as when you complete any of the website forms (i.e. Contact, Appointment, Prescription, Feedback, etc.), Hanly Doctors does not collect any personal data about you on this website, apart from the information which you volunteer to send us in any of the website forms.

Web Site Use Information

Where you visit our website, certain non-personal data is available to us through our internet service provider. This non-personal data is collected on a statistical, aggregate, non-individual basis. This information may include the type of internet browser used to access our website, the type of operating system used to access our website, the “top-level” domain name used (ie, .com, .org, etc.), the date and time of your visit to our website and the number of pages you visited on our website

How Do We Use The Information That You Provide To Us?

Any information, which you provide using any of the website forms (i.e. Contact, Appointment, Prescription, Feedback, etc.), is not made available to any third parties and is only used by Hanly Doctors in line with the purposes for which you provided it (e.g. to contact you and answer any queries which you have raised in any of the website forms  or to address any other feedback which you send us in the any of the website forms.

Disclosure To Other People

We do not disclose, sell or distribute any personal information which you send to us to any third parties. We may pass aggregate information on the usage of our site to third parties, but this will not include information that can be used to identify you. Your personal data may also be anonymised and used for statistical purposes. Unless required to do so by law, we will not otherwise share, sell or distribute any of the information you provide to us without your consent.


We do not use cookies on this website.


We employ security measures to protect your information from access by unauthorised persons and to guard against unlawful processing, accidental loss, destruction and damage and we will do our best to ensure that all records we hold remain secure in line with our obligations under Data Protection Acts 1988 to 2018. We take our security responsibilities seriously, employing appropriate physical and technical measures. We review our security procedures regularly  


We do not retain your personal data for longer than it is necessary for us to comply with the purpose for which you gave it to us.  Any personal data which you provide to us using this website will be used in line with the purposes for which you provided it (e.g. to contact you and answer any queries which you have raised in any of the website forms (i.e. Contact, Appointment, Prescription, Feedback, etc.) or to address any other feedback which you send us in any of the website forms and after this purpose has been completed, we will delete your personal data.  

Accessing Your Information

You are entitled to see the information we hold about you. On written request, we supply copies of your personal data, which you may have supplied to us using our website.  If you wish to obtain copies of this personal data, you should write to Hanly Doctors ( and ask that it provides you with an Access Request Form. Your request will be dealt with as soon as possible and will not take more than a month to process. If you discover that Hanly Doctors holds inaccurate information about you, you can request that we correct/delete that information.

Websites Linked to our Website

Our website may, from time to time, contain links to and from third party websites. We are not responsible for the practices employed by websites linked to or from our website nor the information or content contained therein. Often links to other websites are provided solely as pointers to information on topics that may be useful to the users of our website

Please remember that when you use a link to go from our website to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including websites which have a link on our website, is subject to that website's own rules and policies. Please read over those rules and policies before proceeding

By using our website you consent to our collection and use of your personal information as described in this Privacy Policy. If we change our privacy policies and procedures, we will post those changes on our website to keep you abreast of any developments

Contacting Us

If you are concerned about how your personal data is processed by our website, please bring your concerns to our attention by emailing us at

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