Who we are / Data Controller
Function First Rehab is the Data Controller for the personal data described in this policy.
Function First Rehab — gym-based rehabilitation coaching. Contact us any time through the contact form or WhatsApp.
Data protection contact email: [ADD EMAIL ADDRESS HERE] — to be completed by Function First Rehab.
What we collect
- Personal details: name, date of birth, email address, and WhatsApp / mobile number.
- Emergency contact: name and phone number.
- Health information: medical history, existing conditions, current medications, injury history and presenting complaint.
- Clinical records: assessment findings, treatment and session notes, rehabilitation programmes, progress measures and check-in responses.
- Consent records: the consent wording you agreed to, your digital signature, and the date and time of signing.
- Website data: only what is strictly necessary to operate the site, plus anything you consent to via the cookie banner.
Why we collect it and our legal basis
We collect this information so that we can assess you safely, plan and deliver your treatment, keep an accurate clinical record, and meet our professional and legal obligations.
- Provision of healthcare: health data is processed for the purposes of preventive or occupational medicine, medical diagnosis, and the provision of health treatment and care under Article 9(2)(h) GDPR, with the general processing relying on Article 6(1)(b) (performance of a contract) where applicable.
- Legal obligation: Article 6(1)(c), where we are required to retain records or comply with regulatory or insurance requirements.
- Consent: Article 6(1)(a), for anything optional such as non-essential cookies or marketing communications, which you may withdraw at any time.
Withdrawing consent for optional things does not affect the lawfulness of processing already carried out, and does not remove our obligation to retain clinical records.
How long we keep your records
Adult health records are securely retained for a minimum of 8 years following the date of last treatment, in line with health record retention guidelines.
This obligation means clinical records cannot simply be deleted on request during that period.
Records relating to a person under 18 are retained for longer — until the person reaches at least 25 — in line with the same guidelines.
Your rights
- Access: you can request a copy of your clinical records.
- Rectification: you can ask us to correct inaccurate information.
- Restriction or objection: you can ask us to restrict or object to certain processing.
- Portability: you can ask for your data in a portable format where applicable.
- Withdraw consent: you can withdraw consent for optional processing at any time.
- Erasure: you can request deletion of your data. Please note this right is limited while the retention obligation described above applies to your clinical records.
Making a complaint
Please contact us first — we would like the chance to put things right. You also have the right to lodge a complaint with the Data Protection Commission (DPC), 21 Fitzwilliam Square South, Dublin 2, D02 RD28, dataprotection.ie.
Security
Records are held in an access-controlled database. Signatures are stored in private storage and are only accessible to your therapist. Access is restricted to Riona Devlin.
Sharing
We do not sell your data or share it for marketing. Data is only shared where you ask us to — for example with your GP or consultant — or where we are legally required to.