ICO as “information relating to natural persons who: can be identified or who are identifiable, directly from the information in question; or who can be indirectly identified from that information in combination with other information.”
Special Category Data is defined by the GDPR as personal data considered to be “sensitive,” which include racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, biometric data, health-related data and information concerning a person’s sex life or sexual orientation.
Processing of Personal Data is explained by the European Commission in relation to the GDPR as covering “a wide range of operations performed on personal data, including by manual or automated means. It includes the collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of personal data.”
Data Controller is defined by the ICO as a person who “determines the purposes and means of processing personal data.”
Throughout the document, “we” and “us” refer to the Bath Couples Therapy Practice and its owner, Dr Eric Ryden, who is the designated Data Controller. “You”, “your” and “clients” refer to individuals using the service and the website, and who choose(-s) to disclose personal data.
If you have any questions about this notice, please contact us:
The Bath Couples Therapy Practice and Dr Ryden as a Clinical Psychologist have a legitimate interest in collecting and processing Personal Data to provide psychological services. Data collection is also a requirement of the BPS Practice Guidelines in accordance with best practice. It is necessary to provide an efficient and safe service.
When a person contacts us via telephone, email or by any other means, a bare minimum of information will be collected, such as name, date and time of communication, method of communication and an outline of the subject matter and our response. If relevant and agreeable to the person, we will also collect contact details.
If we have the pleasure of being of service to you, the lawful basis for collecting and processing Personal Data will be discussed and a written consent thereof will be sought before any service can be rendered. Any Personal Data stored as part of our service contract is only done for the purpose of carrying out the work requested by you.
A minimal set of Personal Data is stored to carry out the work effectively and safely. This includes: name, home address, your contact details (eg telephone number and e-mail address), contact details of your General Practitioner (GP), information about fee payments (see How is the information collected for further details) and an outline of the matters for which a service is sought and session-by-session progress notes about the process and content of assessment/therapy.
Please note that as an independent practitioner, we do not contact or disclose information to your GP or any other organisation, unless you ask us to or in the rare situation we are bound to do so by UK law or professional guidance, such as medical emergencies or duty of care (see Confidentiality for further information).
The Bath Couples Therapy Practice does not ask for or store payment card details.
Unless it is directly relevant to the contracted service agreed by you and you have given us your explicit consent to do so, we do not ask for, store or process Special Category Data. If you are unsure or it is not directly relevant to our work, we will kindly ask you not to disclose it.
We do not ask for, store or process information about criminal offences, unless there is a legal obligation to do so, such as in case divulged information gives us reason to believe that a person is at risk of serious harm.
We will not collect or accept any information submitted by a third party in writing or by any other means, unless required to do so for legal reasons (such as duty of care).
Apart from exceptional circumstances, all information collected by us has been volunteered directly by you in face-to-face interviews, video calls, voice calls, e-mail, bank transfer, online payment or questionnaires/forms.
An exceptional circumstance refers to the rare occasion when a third-party individual or organisation discloses information to the Bath Couples Therapy Practice that we are legally obliged to store and process, such as safeguarding.
In order to maximise the security of financial Personal Data, the Bath Couples Therapy Practice does not store or handle any financial transactions. Client payments are made either online or via bank transfer. Online transactions are handled independently by stripe, see Third Party Storage and processing for further information. From Stripe and our bank statements, we collect information about the amount paid to us, payment reference, name of payer and date of payment.
The Bath Couples Therapy Practice does not use information from cookies or any other methods of tracking or storing information of visitors to our website. Please note that third parties (including our web-host or websites accessed via external links from our website) may use cookies over which we have no control.
You can block cookies by activating the cookie setting that is available on most common browsers. Because we do not use cookies, it will not have any effect on the functionality of our website.
In accordance with best practice and the BPS Practice Guidelines, information shared with us is confidential unless a client (or both clients when Co-active Couples Therapy is provided) request(-s) disclosure to a third party, professional supervision requirement or in exceptional circumstances to comply with UK legislation. These limitations to confidentiality are further explained here:
Please note that for Co-active Couples Therapy to be conducted effectively and safely, the therapist cannot keep information disclosed by one partner hidden from their co-active partner, unless in the exceptional circumstance of serious and imminent risk of harm to someone. In Co-active Couples Therapy, confidentiality pertains to the non-divulgence of information shared in assessment and therapy to anyone outside the confidentiality group, namely the two partners and the therapist. Please note that this Privacy Notice only binds the therapist to confidentiality and we cannot be held responsible for breaches of confidentiality brought about by our clients about themselves.
All data collected by the Bath Couples Therapy Practice are stored electronically and encrypted with a Strong AES-256 encryption. We do not store any Personal Data on paper or any other physical means of storage.
Online financial transactions via the booking system are handled by stripe, a global online payment processor trusted by millions of small and large companies worldwide, including google, amazon and National Geographic. All common debit or credit cards can be used. The operations of stripe involve by their nature the collection, storage and processing of Personal Data. Stripe has its own Privacy Policy (stripe), which we encourage you to read.
As part of our service, there may be opportunities to benefit from supplementary third-party assessment and therapy tools and services. Those opportunities are optional. Some of those services may involve the collection and processing of Personal Data. The use of those services is at your own risk and we recommend that you read their Privacy Notices/Policies.
If you choose to communicate with us via electronic means, including voice/video phone and e-mail, you need to be aware that most of those third party services collect Personal Data. The safety, storage and processing of Personal Data collected by them are outside our control and not covered by this Privacy Notice. This also applies to use of optional third party links on our website. We endeavour only to make use of technologies and web links that offer high levels of data protection. However, we cannot accept any responsibility or liability for third party operations and encourage you to read their Privacy Polices/Notices before submitting any Personal Data, or if unsure, not use those third party services and links.
The Bath Couples Therapy Practice website is hosted by krystal, an award winning UK located company. In 2018, they won the Best Host "price for protecting their customers from emerging threats, including DDoS protection, but also for their charitable efforts.” The company is also “powered by 100% renewable energy.”
When working with us, we will aim to agree on the use of the most secure technology to which we have access, such as encrypted messaging. If you require a more secure service than Skype and Gmail, the feasibility of using alternatives will happily be explored. We offer an encrypted email option operated by ProtonMail.
Please note that any information disclosed by electronic means, such as e-mail and voice/video calls, are alas by their nature not completely secure. We cannot be held responsible for any breaches to data protection due to the use of electronic means of communication. We encourage you to not disclose any personal data via electronic means unless you are aware of the risks.
Information collected and stored as detailed in this notice are retained for a period of seven years as specified by the guidelines and requirements for record keeping by The British Psychological Society. After this time, the data is deleted.
Information collected and stored as part of general enquiries and not part of contracted therapy programme is not required to be kept for seven years and may be deleted earlier.
Under UK data protection law, you have the following rights:
If you have any questions or concerns about how we use your data, please do not hesitate to contact us by sending an e-mail to totnescouplestherapy@gmail.com. We will endeavour to resolve any concerns of yours as quickly as possible, and if relevant, make any reasonable changes that are legally and practically possible within our practice guidelines. If you are not content with our response, please contact Information Commissioner’s Office (ICO; Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF), helpline number: 0303 123 1113.
The Bath Couples Therapy Practice may modify or update this Privacy Notice when necessary to reflect changes in our services, changes in applicable legislation, regulations or guidelines, or in response to feedback from you. Any changes we make will be posted on this page. Please return periodically to check for changes.
Last updated 5th February 2024.