# How can we invoice employers for EAP or corporate counselling without revealing who attended?

URL: https://tymirahealth.com/resources/faqs/how-can-we-invoice-employers-for-eap-or-corporate-counselling-without-revealing-who-attended
For: Finance | Data protection and privacy | Reviewed by Independent clinical reviewer, Registered mental health clinician, Kenya | Last reviewed 8 November 2026

**Answer:** Invoice on aggregated, de-identified data: number of sessions or hours, service type, period and contract reference, not client names, staff numbers or reasons for attending. Agree this format in the contract before services start, including how the employer can verify invoices, for example through an independent audit of anonymised session logs. Keep the identifiable ledger internally, with access restricted. Under the Data Protection Act, health data is sensitive personal data, so share only what is strictly necessary.

Sources: Kenya Law: https://new.kenyalaw.org/akn/ke/act/2019/24 - Office of the Data Protection Commissioner: https://www.odpc.go.ke/faqs - Office of the Data Protection Commissioner: https://www.odpc.go.ke/wp-content/uploads/2024/03/THE-DATA-PROTECTION-GENERAL-REGULATIONS-2021-1.pdf

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