1. Who We Are. PALS provides psychological and educational assessment services in Ireland. The Data Controller is PALS (Clinton Greenford), responsible for deciding how and why personal data is processed.

2. What Personal Data We Collect. We collect only what is necessary to respond to enquiries and provide assessment services: names and contact details; information on referral or enquiry forms; questionnaire responses from parents, teachers or clients; assessment notes and test results; reports; and limited technical data such as email correspondence. We do not collect unnecessary information.

3. How Personal Data Is Collected. Data may be collected when you contact us by email, complete a referral or enquiry form, complete questionnaires as part of an assessment, or during the assessment and reporting process. Some questionnaires are completed using secure third-party platforms operated by recognised test publishers (see Section 6).

4. Why We Use Personal Data. We use personal data only for legitimate and necessary purposes: responding to enquiries; assessing suitability for services; conducting psychological or educational assessments; interpreting results; preparing professional reports; and meeting legal, ethical and professional obligations. We do not use personal data for unrelated marketing.

5. Legal Basis for Processing. We process personal data on the lawful bases of contract (to provide the assessment service you have requested) and legal and professional obligations (including record-keeping). The information needed to carry out an assessment includes special category data (health and psychological information), which we process because it is necessary for the provision of health and social care by a professional bound by a duty of professional secrecy, under Article 9(2)(h) of the GDPR. Our psychologists are registered with the Psychological Society of Ireland and bound by professional confidentiality. The tools we use to deliver our service and prepare reports, including the AI support described in Section 6, operate under our control and instruction and never replace professional judgement.

6. Use of Third-Party Services. Some standardised questionnaires are administered using secure platforms provided by recognised test publishers, including WPS (Western Psychological Services) and MHS (Multi-Health Systems). These platforms collect responses directly from clients, parents or teachers and make results available to the clinician for professional interpretation, each under its own privacy and data protection obligations. As part of how we deliver our service, PALS uses secure AI tools, including Claude (developed by Anthropic), to work efficiently and to a consistently high standard, for tasks such as managing and drafting correspondence, preparing draft documents, and quality-checking written work. AI is used only to support our work; all clinical findings, conclusions, diagnoses and recommendations are made solely by our qualified psychologists, and AI makes no clinical decisions. Data processed through these tools is handled by Anthropic as our data processor under a GDPR-compliant Data Processing Agreement and Standard Contractual Clauses, is never used to train AI models, is held only for a limited period and then deleted, and is accessed only by the assessing psychologists. Where data is processed on secure infrastructure outside the EU, this transfer is governed by Standard Contractual Clauses supported by a Transfer Impact Assessment. We are open about our use of AI: it is described here and on our referral form.

7. Data Storage and Security. All personal data is stored using secure systems appropriate for sensitive psychological information, with measures including access controls, encryption where appropriate, and restricted access to authorised users only. Email correspondence is stored securely and accessed only by the clinician.

8. Data Retention. Personal data is retained only for as long as necessary and in line with professional guidance. Paper records are retained for 1 year and then securely destroyed; digital records are archived securely for 7 years after the file is closed. During an active assessment, data may be retained for a period of weeks while the assessment and report are completed; once the file is formally closed, records are either deleted or archived in line with these periods.

9. Sharing of Personal Data. Personal data is shared only where necessary to provide assessment services and only with professionals involved in the assessment. This may include sharing relevant information with external clinicians whose professional input forms part of the assessment, for example sharing relevant information with a Speech and Language Therapist for consultation or collaborative assessment. Any information shared is limited to what is necessary, shared securely, and handled in accordance with professional confidentiality and data protection obligations. Personal data is not sold or shared for unrelated purposes.

10. Your Rights. Under GDPR you have the right to access your personal data, request correction of inaccurate data, request erasure (where applicable), restrict or object to certain processing, and lodge a complaint with the Data Protection Commission. These rights do not override professional, ethical or legal obligations relating to the protection of standardised psychological test materials. Certain assessment materials (for example test questions, items or stimuli from standardised assessments such as the SB5 or Conners) are protected by copyright and publisher restrictions, so it is not always possible to share individual test questions or full test content even where a data access request is made; in such cases findings and results are explained in an appropriate professional format.

11. Contact Details. If you have any questions about this statement or how your data is handled, please contact our Data Protection Officer / Data Controller, Clinton Greenford, at pals@pa-ls.com.

12. Updates to This Statement. This statement may be updated from time to time to reflect changes in law, guidance or practice. The most current version will always be available on our website.