1. Introduction

Holistic Health Care is run and owned by Joan McCabe Breen and was opened in December 2015. The business has run successfully for 5 years providing a range of therapies and workshops. The global pandemic COVID-19 has had a profound effect on all society and business and to open back up again we have to identify the risks and put in place policies and procedures to minimize the risk to ourselves and our families and clients and customers.

The HHC COVID-19 Response Plan details the policies and practices necessary for the business to meet the Government’s ‘Return to Work Safely Protocol’ and to prevent the spread of COVID-19 in the workplace. The plan also gives an overview of how Holistic Health Care will ensure compliance with the protocol and to minimise the risk to workers and clients and put in place control measures to reduce the risk of spread of COVID-19.

The following sections will cover key information and actions, which will be backed up by the checklists below. They are as follows:


(see hard folder for Appendix forms, IMTA check sheets, certificates and  screening documents)

Section 1: Introduction

Section 2: Risk assessment (“Be Smart” available only in hard folder)

Section 3: Planning & preparing / Control measures

Section 4: Cleaning and hygiene

Section 5: Contact tracing

Section 6: Payment

Section 7: Certification and COVID 19 related training

  1. Systems to keep up to date with Government Guidelines
  2. Dealing with a suspected case of COVID19
  3. My own self care for COVID 19
  4. High Risk & Very High Risk People
  5. GDPR Statement


  1. Risk Assessment

The risk assessment for HHC was developed through the Government “BeSmart” programme.  This document identifies the risks and hazards for the business both in general and specific to COVID-19 and identifies the measures required to ensure the health & safety of staff and customers. Please see attached Safety Statement developed for full details. (hard folder)


  1. Planning & Preparing / Control Measures

The planning and preparing phase is critical to ensure a safe return to work and covers such items as information and guidance, return-to-work forms, identifying and putting in place control measures and updating our safety statements, risk assessments and emergency plans.

In relation to HHC specifically there were 2 primary areas which needed to be addressed. The risks and control measures for workshops and one-to-one therapy sessions are different and therefore need to be responded to separately. One to one treatments will be given from my home workspace while workshops, when resumed, will take place from a rented space e.g hotel room, holistic centre etc.

Key Areas which were reviewed and changes adopted;

  • Workshops when resumed will be run from rented spaces e.g hotel room etc. so groups will be limited to aprox 8 people. In addition to the cleaning already in place from any such rented location I will insure that all people attending are socially distanced (2m), wear a face cover from entry to exit of workshop, room is well ventilated where possible (windows), hand washing and sanitising gel  are available throughout day, water bottles are supplied to each individual and names must be wrote on bottles at commencement.  And in addition to the facilities own cleaning I will ensure regular disinfection of door handles, seats, pens and surfaces within rented room.
  • HHC will ensure that a pre workshop COVID screen, with temp check on the day of any such workshop, is carried out 36-24hrs prior to any WS attendance. Contact tracing lists will be compiled for any such workshops also.
  • Data collection was previously limited to initial consultation sheet maintained by HHC, now in addition to normal intake form all clients will receive a COVID 19 pre-screen and consent to treat form via phone 24 hrs prior to treatment, to be signed on the day of session by client.
  • End of Day cleaning was previously carried out on all equipment and areas at end of day but now in addition to end of day cleaning there is cleaning and sanitising before and after every client.
  • Treatment room at HHC has been closed to public for 4 months (13th March-20th July 2020). Since the close date the treatment space has been thoroughly deep cleaned and de-cluttered of all items except those necessary for a therapy to be carried out.

All equipment and surfaces were deep cleaned and sanitised (throughout July).

Risk assessments carried out and hazards identified /cleaning procedure developed (June, July 2020)

  • Clients must now arrive exactly on time for their treatment and must follow guidance for entry onto premises.
  • Treatments will for the time being be 60mins each with no facial massage available until further notice.
  • No brochures or business cards will be on display for the time being.
  • In relation to staffing I Joan Mc Cabe Breen am registered as a sole trader and so I work alone at HHC. I do not employ any staff nor do I expect to in the near future.


  1. Cleaning & Hygiene
  • This area will see the most significant change with cleaning being carried out after every client and rigorous sanitization and hand hygiene being put in place.

(Detailed breakdown of cleaning schedule and checklist available in Appendix 1)

  • In addition, during workshops and treatments no physical contact will be permitted between client and therapist, students, or students and teacher (such as hand shaking or hugging) to minimise the risk of OCVID -19 spread. Respect for social distancing rules on the premises and outside the premises will be required.
  • Clients will be required to use provided hand sanitizer entering, throughout treatment when necessary and leaving the building.
  • Paper towels will be placed into downstairs ablution area and client will be instructed to turn off tap with the paper used to dry hands then place in bin provided. Client must also open/ close doors with clean paper towel provided.
  • Cleaning will be rigorous going forward; the treatment room and all actual and potential surfaces either myself or the client has or may have touched will be cleaned, and room ventilated between clients as well as designated toilet facilities( downstairs toilet in home workspace).
  • Clients will enter and leave the premises one at a time. They will be instructed to ring me when they arrive for treatment and I will open all doors and escort them in.
  • Shoes will be removed and left in the hall way on disposable paper.
  • Clients will arrive wearing their masks and will keep them on until they have left the premises. Therapist will do same.
  • Clients will be instructed not to touch anything unless absolutely necessary e.g banisters, upon entry and on route to therapy room.
  • Clients will place ALL belongings into plastic box, which will be then sealed until treatment ends.
  • Paperwork will be signed and pens/clipboards will be disinfected at end of session.
  • Gloves may be worn my either therapist or client if desired but hand washing and hand gel remain the recommended means of cleaning hands.
  • Chatting within the therapy room will be limited to essential info only.
  • Upon completion of session plinth sheets will be carefully removed and placed into linen bin with sealed lid. All linen will be gathered together and washed at end of day at 60 degrees, dried and placed in cupboard ready for next day. (following guidelines from IMTA and ANMPT) Any plinth roll will be placed in the bin also.
  • Uniforms will be either changed between clients or a disposable apron will be worn for each client.
  • The plinth and pillows are covered with plastic protectors which will be disinfected between clients.
  • All other surfaces inside and outside of therapy room will be then disinfected as per cleaning sheet in appendix 1.
  • There will be a gap of 30-60 minutes now between clients to allow for adequate cleaning and ventilation.
  • All treatments will be for the hour at this point, this may be reviewed at a later date depending on guidance form IMTA and HSE.
  • Sanitiser will be available for use at the front door, in the toilet and treatment room for clients and therapist.
  • Water will be provided in plastic bottled form for clients and will be taken away by each client after treatment.
  • Laundry and waste bins will be emptied at end of each workday.
  • High risk people are requested to follow the advice of the HSE and to refrain from coming for treatment for time being. If client is adamant they want a treatment a GP referral letter or client waiver form must be supplied. Otherwise all clients are instructed to stay home if feeling unwell.
  • CODVID 19 signs are placed in the treatment room and a diffuser is also present to aid air disinfection using natural essential oils and to promote relaxation.


  1. Contact Tracing
  • I ( J MC C B) will at the end of each work day, fill out on a pre-prepared daily contact list with client details (see Contact Tracing Daily Sheet) name, number and address (see appendix 1) .


  1. Payment
  • For the immediate future clients will be given the option to prepay, pay by card on the day or supply the exact amount a treatment costs, no change will be given and any monies received will be placed into zip lock bag and stored in locked money safety box until it is lodged into bank.


  1. Certification & COVID19 related training
  • Certificate of Completion – COVID-19 Infection Prevention and Control (Essentials Holistic Centre)
  • CE Quiz for Back to Practice Guidelines
  • As a member of the Irish Massage Therapist Association I have also taken part in a number of online training sessions and Zoom meetings focused on building knowledge and understanding and preparing to re-open.


  1. Systems to keep up to date with Government Guidelines
  • I will continue to, through membership groups, keep updated with current legislation and regulations to ensure my own safety and that of clients and community. Weekly Check in with and and to keep informed and update documents and practice as appropriate


  1. Dealing with a suspected case of COVID19
  • In the case of a client becoming ill with a suspected case of COVID-19 J MC C Breen is the dedicated person appointed to respond and co-ordinate the matter. See pre- treatment screening check for clients and myself.(appendix 1)
  • The designated area for a person to go will be outside of the building – through the hallway and out the main door – a seat will be available here for the person to wait and client will be masked – no other person will have contact at this time and Joan Mc Cabe Breen will remain a strict 2 metres from the person
  • A first aid bag will be prepared and ready on site for use in this situation – The first aid bag will include and will be checked and updated as required;

« sealed pack of tissues

« plastic bag for disposal

« mask

« gloves

« container of hand sanitiser

« bottle of water

  • I am aware that should I/ client be deemed a close contact that we should immediately self –isolate for 14 days and contact our GP for test. GP Contact will be made by me to my gp and client advised to do same. Advice on how to respond / proceed taken from health care professionals from here.
  • NSAI (national standards authority of Ireland) Guidelines will be followed for deep cleaning and preparation for the building to be re-opened to clients.
  • Contact Tracing log sheet will be provided to health care professionals as required. (see appendix 1)
  • After the event an incident report will be completed and a file prepared outlining event and contact tracing and this will be available as required by contact tracing teams.
  • Steps to be undertaken for suspected case whilst on site;

« Request client or student to move to the designated area outside of the building (Bench provided).

« Remain 2 metres from student / client at all times.

« Provide client or student with the first aid bag.

« Contact GP or HSE for advice on how to respond.

« If the person can travel home, encourage them to self-isolate and seek to be tested.

« Arrange for deep clean and ventilation of building.

« Complete incident report and contact trace form if required.


  1. My own self care for COVID 19
  • The Therapist Joan McCabe Breen will self -monitor for signs and symptoms of COVID-19 every day. I will take my temperature every day (36-37 degrees normal) before the workday begins and again in the afternoon (when virus tends to spike in temperature)
  • J Mc C Breen will be vigilant for the wide range of symptoms including most common symptoms are mild cold or flu-like symptoms, especially a cough, sore throat, and shortness of breath, loss of taste or smell. Should the practitioner develop a temperature or symptoms of illness, I will cancel all appointments or workshops and self-isolate for 14 day or seek to obtain COVID-19 testing so they can be cleared of infection and return to work. Should I test positive a contact trace will be supplied to HSE. All clients have agreed to their data being released to HSE under GDPR legislation on the consent to treat form solely for tracing purposes.( see appendix 1)
  • I will comply with at all times comply with the wearing of my own PPE e.g mask, face shield/ goggles, apron and gloves. Please note that if a client will not or can not wear a mask than unfortunately I will not be in a position to treat them at this current time due to inability to social distance. Outside of the work environment  J Mc C Breen will also be vigilant in social distancing and hygiene.


11.High Risk & Very High Risk Groups (according to


VERY HIGH RISK GROUPS (extremely vulnerable)

  • are over 70 years of age – even if you’re fit and well
  • have had an organ transplant
  • are undergoing active chemotherapy for cancer
  • are having radical radiotherapy for lung cancer
  • have cancers of the blood or bone marrow such as leukaemia, lymphoma or myeloma who are at any stage of treatment
  • are having immunotherapy or other continuing antibody treatments for cancer
  • are having other targeted cancer treatments which can affect the immune system, such as protein kinase inhibitors or PARP inhibitors
  • have had bone marrow or stem cell transplants in the last 6 months, or who are still taking immunosuppression drugs
  • severe respiratory conditions including cystic fibrosis, Alpha-1 antitrypsin deficiencysevere asthma, pulmonary fibrosis, lung fibrosis, interstitial lung disease and severe COPD
  • have a condition that means you have a very high risk of getting infections (such as SCID, homozygous sickle cell)
  • are taking medicine that makes you much more likely to get infections (such as high doses of steroids or immunosuppression therapies)
  • have a serious heart condition and you’re pregnant



  1. GDPR Statement for HHC


Joan Mc Cabe Breen trading as Holistic Health Care

IMTA Membership Number: 1748
Date Created/Updated: 07/07/2020

The GDPR (General Data Protection Regulation) May 2018 is the legal regulation that has been put in place to safeguard an individual’s personal information. The following privacy policy details the lawful basis for Holistic Health Care to hold information, the type of information that HHC holds about her clients, why that information is required, who it is shared with, how that information is used and protected and details the rights an individual has in terms of access to that information or, requests for information held to be amended or deleted.


The lawful basis by which I hold this information is held under Special Category Data: Health In order to provide an effective and safe massage therapy treatment/ reflexology treatment/  energy therapy such as reiki treatment, other treatments I am qualified to carry out or workshop. I require information about your current health and your medical history. This information is used only to provide you with the best possible course of treatment and advice. I also require your contact details to arrange appointment times with you. As a registered massage/ holistic therapist with the IMTA (Irish Massage Therapist Association) I abide by these associations codes of conduct and confidentiality requirements.


Holistic Health Care may collect personal information from: Email or Text messages sent from individuals to HHC, discussions with clients during the consultation process and during subsequent treatments and through all consultation forms and client record keeping forms




Holistic Health Care may collect the following personal information:

  • Name, title and date of birth.
  • Contact information including email address, telephone numbers and home address.
  • Emergency contact or next of kin details.
  • Medical history and other health related information provided on the consultation form and discussed during the first and subsequent treatments and classes
  • Treatment detail and assessment notes which will be recorded after each massage session.
  • Follow up information which may be discussed with you by phone email or text after your treatment.
  • Diarised records of appointment times and through website appointment page.


Holistic Health Care requires this information to assess your massage/ holistic treatment requirements and provide you with a safe and effective massage/ reflexology/ holistic therapy or workshop. Additionally the information is used to refer to at subsequent treatments in order to assess levels of improvement. The information may be shared with another Massage Therapist or with another health practitioner should you be referred to one of these by HHC. This will only be done with your consent. Your information will not be shared with anyone else (other than required for legal process) without explaining the reason why this is necessary and obtaining your explicit consent. The contact information you provide may be used by HHC to contact you in relation to appointment times or dialogue regarding your treatment plan.




Holistic Health Care is required to keep your information for a period of 7 years after your last treatment for insurance purposes. Your data will not be transferred without your consent. Disposal of Data: Once per year, HHC will review all client records and destroy any records that are no longer bound by the regulated legal timescale for such records to be held.


Holistic Health Care is committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, suitable physical, electronic and managerial procedures have been put in place to safeguard and secure the information that is collected both online and on paper. The health information gathered is held on paper Consultation forms and treatment notes and is stored securely in a locked filing cabinet. None of this information other than your name, phone number and/or email address as per website booking inquiry form is held electronically(when data is stored electronically HHC will update GDPR Statement) and only for the period email is present in my inbox.


A back up document is currently being compiled of client names and contact details (name, email and telephone number). In the event of a data breach which consists of a breach of security leading to destruction, loss, alteration, unauthorised disclosure of or access to personal data, HHC understands ICO have to be notified where it is likely to result in a risk to the rights and freedoms of individuals. In the event of such a breach, HHC will notify those concerned directly and without delay. Records of personal data breaches will be maintained in any case.



The GDPR May 18 gives an individual: –

  • The right to be informed as to how personal information will be both used and held. This is contained within this document.
  • The right to access your personal information so individuals know what is held about them and they can confirm it.
  • The right to rectification if there is something incorrect or incomplete.
  • The right to have information deleted
  • The right to limit how the information is used or shared
  • The right to portability. Under certain circumstances a copy of electronically held information can be requested so it can be reused in other systems
  • The right to object if there are certain parts of an individual’s information that they do not want used or to be used only for certain purposes
  • Rights in relation to automated decision-making and profiling
  • The right to lodge a complaint with the Dublin Office
  • You can contact the Office of the Data Protection Commission by emailing or by telephone at 1890 252 231. Further information is also available on the dedicated website GDPR and You.
  • Should an individual wish to exercise these rights, the contact details at the start of the document should be used. In the event that an individual is dissatisfied with the response, then a complaint can be made to the


If an individual does not agree to Holistic Health Care keeping records of information about an individual and treatment records then it may not be possible to provide the therapy. Additionally, massage/ holistic therapists have to keep records of treatment for a specific period of time as described above which may mean that even if you ask for information to be erased, they might be bound to keep these details until the period has elapsed.