Effective Date: November 5th 2025
Data Controller: Castle Craig Hospital Ltd (acting as Data Controller for Smarmore Castle Clinic Ltd)
Contact: Dr Rebecca Apperson
Clinic Address: Smarmore Castle Clinic, Ardee, Co. Louth, Ireland
1. Introduction
Smarmore Castle Clinic (“Smarmore”, “we”, “our”) is operated under the Castle Health Group and managed by Castle Craig Hospital Ltd, which acts as the Data Controller. We are committed to protecting your personal data in accordance with the EU General Data Protection Regulation (GDPR).
2. What We Collect
| Category | Examples |
| Identity and Contact Data | Name, date of birth, address, telephone, email |
| Health Data | Medical history, assessment notes, treatment details |
| Administrative Data | Payment information, billing address, insurance details |
| Technical Data | IP address, browser, device type, usage analytics, cookies |
| Marketing Preferences | Opt-in choices for newsletters or service updates |
3. Purpose and Lawful Basis of Processing
| Purpose | Lawful Basis (GDPR) |
| Provide assessment, treatment, and aftercare | Art. 6(1)(b), Art. 9(2)(h) |
| Respond to enquiries and manage admissions | Art. 6(1)(b) |
| Meet legal and clinical governance duties | Art. 6(1)(c) |
| Marketing (optional) | Art. 6(1)(a) |
4. Data Sharing
We may share your data with:
- Treating clinicians and administrative staff within Castle Health Group
- Referring doctors or insurers (where appropriate)
- External IT, billing, or communication providers under data processing agreements
- Regulators or authorities (if legally required)
All partners are bound by confidentiality and data protection obligations.
5. International Transfers
If data is stored or accessed outside the EU, we use the European Commission’s Standard Contractual Clauses (SCCs) or other recognised safeguards to ensure adequate protection.
6. Retention, Rights & Complaints
Data is retained in accordance with medical and legal requirements.
You may exercise your GDPR rights (access, rectification, erasure, restriction, portability, objection, and consent withdrawal) by emailing r.apperson@castlehealth.com.
If unsatisfied, you may lodge a complaint with the Data Protection Commission (Ireland) at https://www.dataprotection.ie.
7. Security and Confidentiality
Robust security measures, including encryption, restricted access, and staff confidentiality agreements protect your information.
8. Updates
This policy may be updated periodically to reflect regulatory or operational changes. The latest version will be available on our website.
9. Contact
Data Controller: Castle Craig Hospital Ltd (acting as Data Controller for Smarmore Castle Clinic Ltd)
Contact: Dr Rebecca Apperson
Contact Email: r.apperson@castlehealth.com
Clinic Address: Smarmore Castle Clinic, Ardee, Co. Louth, Ireland