Who We Are
Bryce Psychology Services Ltd provides independent psychological services led by Dr Carl Bryce, Registered Health Psychologist.
Dr Carl Bryce is registered with the Health and Care Professions Council (HCPC) as a Practitioner Psychologist (registration number PYL042334) and is a Chartered member of the British Psychological Society (BPS) (membership number 414186).
Bryce Psychology Services Ltd is registered with the Information Commissioner’s Office (ICO) (registration number ZB833278).
Professional practice is regulated by the HCPC and informed by relevant professional and ethical standards, including those of the BPS.
Further information about these organisations can be found at:
Data Controller
Bryce Psychology Services Ltd is responsible for determining how personal information collected through the private practice is processed and protected. Dr Carl Bryce is responsible for data protection within the practice.
For the purposes of UK data protection legislation, Bryce Psychology Services Ltd acts as the data controller for personal information processed in connection with the provision of psychological services.
Your Data Protection Rights
Under UK data protection law, you have a number of rights in relation to your personal information. Depending on the circumstances, these may include:
the right to be informed about how your personal information is used;
the right of access to personal information held about you;
the right to rectification of inaccurate or incomplete information;
the right to erasure of personal information in certain circumstances;
the right to restrict processing in certain circumstances;
the right to object to certain types of processing;
the right to data portability where this applies; and
the right to withdraw consent where consent is specifically being relied upon as the lawful basis for processing.
These rights are not absolute and may be limited where there is a lawful or professional reason for information to continue to be retained or processed. For example, it may be necessary to retain clinical records following the end of therapy in accordance with professional, legal, insurance or regulatory requirements.
Requests relating to your personal information can be made directly to Bryce Psychology Services Ltd.
Our Legal Reasons for Processing Your Information
In order to provide psychological services, it is necessary to collect and process personal information.
Depending on the particular purpose, the lawful basis for processing personal information under the UK General Data Protection Regulation (UK GDPR) may include:
Contract – where processing is necessary to provide psychological services that you have requested or to take steps at your request before providing those services;
Legitimate interests – where processing is necessary for the legitimate operation of the psychological practice, provided these interests are not overridden by your rights and interests;
Legal obligation – where information must be processed or retained in order to comply with a legal requirement; and
Vital interests – in exceptional circumstances where processing is necessary to protect somebody’s life.
Psychological services necessarily involve processing information about health and wellbeing. Health information and some other information collected during therapy are classed as special category personal data.
Where special category health information is processed for the purpose of providing psychological assessment, treatment or healthcare, we generally rely upon Article 9(2)(h) of the UK GDPR, which permits processing that is necessary for the provision of health or social care or treatment, together with the relevant provisions of the Data Protection Act 2018.
Other lawful conditions may apply in particular circumstances, for example where information is required in connection with legal claims or where it is necessary to protect vital interests.
Consent to psychological treatment and the lawful basis for processing personal information under data protection law are separate matters. We do not therefore rely upon consent as the legal basis for all routine processing of clinical information.
What Personal Information We Collect
The information collected will depend upon the services you receive but may include:
your name, date of birth and contact details;
address and demographic information;
GP and other healthcare professional details where relevant;
emergency contact information where appropriate;
referral information;
physical and psychological health information;
relevant medical and medication information;
personal, family, social, occupational and relationship information discussed during assessment or therapy;
psychological assessment information and questionnaire responses;
clinical notes and treatment plans;
information relating to risk or safeguarding;
correspondence, including emails, letters and reports;
appointment and attendance information;
payment, invoice and accounting information; and
health insurance information, including membership, claim and treatment-authorisation details where applicable.
Information will normally be obtained directly from you. Information may also be received from a referrer, healthcare professional, health insurer or another relevant third party where you have authorised this or where there is another appropriate lawful basis for receiving the information.
Clinical Notes and Records
During psychological assessment and therapy, clinical notes will be created in order to provide safe and effective psychological care and to meet professional requirements.
Clinical records may include information discussed during appointments, assessment findings, psychological formulations, treatment plans, interventions, relevant correspondence, risk assessments and progress through therapy.
Clinical notes are confidential and access is restricted to those who have an appropriate reason to access them.
Audio or Video Recordings
On occasion, an audio or video recording of a therapy session may be helpful for clinical supervision, training or another specific therapeutic purpose.
A session will not be recorded without discussing this with you in advance and obtaining your agreement.
Where a recording is made, you will be informed about its purpose and how it will be used. Recordings will be stored securely, access will be restricted and they will be deleted securely when they are no longer required for the purpose for which they were created.
Recordings made solely for supervision or training will not ordinarily form part of your permanent clinical record unless there is a specific reason for this.
Health Insurance and Healthcode
Where your treatment is funded wholly or partly through private health insurance, it will be necessary to process information relating to your insurance policy and treatment authorisation.
Relevant information may be shared with your insurer and/or an authorised electronic billing provider, such as Healthcode, for the purposes of:
confirming eligibility or treatment authorisation;
administering your insurance claim;
submitting invoices for treatment;
confirming dates and types of treatment provided;
dealing with excesses, co-payments or benefit limits;
responding to legitimate queries concerning a claim; and
meeting applicable contractual, audit or regulatory requirements.
Information shared for routine claims administration will normally be limited to what is reasonably necessary for those purposes. This may include your name, date of birth, membership number, authorisation or claim number, treatment dates, treatment type and fees.
An insurer may occasionally request further information relating to treatment. Any request for additional clinical information will be considered in accordance with professional confidentiality obligations, data protection law and the applicable insurer agreement. Where appropriate and possible, this will be discussed with you before additional clinical information is disclosed.
Your insurer will also process your personal information in accordance with its own privacy policy.
How We Use Your Personal Information
Personal information may be processed for purposes including:
responding to enquiries and referrals;
arranging and managing appointments;
providing psychological assessment and treatment;
maintaining appropriate clinical records;
monitoring progress and treatment outcomes;
communicating with you about your care;
communicating with other healthcare professionals where appropriate;
managing clinical risk and safeguarding concerns;
clinical supervision;
processing payments, invoices and insurance claims;
maintaining financial and accounting records;
meeting legal, regulatory, professional and insurance requirements;
responding to complaints, legal claims or regulatory enquiries; and
monitoring and improving the operation of the service.
Where information is used for service evaluation or statistical purposes, it will wherever reasonably possible be anonymised or aggregated so that individuals are not identifiable.
We will not sell your personal information.
Sharing Your Personal Information
Your personal information will normally remain confidential.
Information may be shared where:
you have asked or agreed for information to be shared;
this is necessary for your direct care;
information is required to administer health insurance or payment arrangements;
there is a serious concern about your safety or the safety of another person;
safeguarding responsibilities require information to be shared;
disclosure is required by law, court order or another legal obligation;
information is required in connection with a legal claim or regulatory process; or
another lawful and professionally justified reason applies.
Wherever reasonably possible and appropriate, significant disclosures of confidential clinical information will be discussed with you beforehand.
Only information that is reasonably necessary for the relevant purpose will be shared.
Clinical Supervision
Clinical supervision is an important part of safe and ethical psychological practice.
Dr Carl Bryce may discuss clinical work with an appropriately qualified supervisor or professional peer for the purposes of supervision, reflection and maintaining high standards of care.
Supervision is itself subject to professional confidentiality. Identifying information will be minimised wherever reasonably possible.
Website and Online Enquiries
When you use the Bryce Psychology Services Ltd website or submit an online contact form, certain information may be collected automatically by the website or hosting provider. This may include information such as your internet protocol (IP) address, browser information and basic information about how the website is accessed.
Information submitted through an online contact or enquiry form will be used to respond to your enquiry and, where appropriate, to arrange psychological services.
Our website may use cookies and similar technologies.
Some cookies may be strictly necessary for the website to operate. Where non-essential cookies, such as analytics or similar technologies, are used and consent is required, they will only be activated after appropriate consent has been obtained.
You can manage your cookie preferences through the website's cookie controls and, where applicable, through your browser settings.
Video Consultations
Psychological appointments are normally provided remotely using Microsoft Teams, or another agreed method where appropriate.
Microsoft Teams uses encryption to protect information in transit and at rest. A unique meeting link will normally be provided for appointments.
Standard Microsoft Teams consultations should not be assumed to use end-to-end encryption unless this has specifically been enabled.
Clients are responsible for choosing a private location for remote appointments wherever possible and for taking reasonable steps to protect their own privacy at their location.
Therapy sessions conducted through Microsoft Teams will not be routinely recorded.
Email and Electronic Communication
Email and other electronic communication may be used for appointment administration and, where appropriate, the exchange of information relevant to your care.
Reasonable security measures are used when transmitting sensitive information. Where appropriate, sensitive documents may be password protected or another secure method of communication may be used.
Although reasonable precautions are taken, no method of electronic communication can be guaranteed to be completely secure.
You are encouraged to consider the privacy and security of the email address and devices you use when communicating with the practice.
How Your Personal Information Is Stored
Clinical information is stored securely and access is restricted.
Records are primarily maintained electronically using appropriate systems and security controls.
Where paper records are temporarily created, they will be stored securely and, where appropriate, transferred to the electronic clinical record or securely destroyed when no longer required.
Reasonable technical and organisational measures are used to protect personal information. These may include access controls, passwords, encryption, secure systems, appropriate backups and restrictions on who can access information.
Third-party organisations that process information on behalf of Bryce Psychology Services Ltd are selected with consideration of their security and data protection arrangements and, where required, appropriate contractual arrangements are put in place.
International Processing and Data Transfers
Where reasonably possible, services are selected with appropriate privacy and security protections.
Some technology, communications, payment, website, insurance or other service providers may process or make personal information accessible from locations outside the United Kingdom.
Where personal information is transferred outside the UK and UK data protection rules on international transfers apply, appropriate safeguards will be used as required by law. These may include transfers to countries covered by UK adequacy regulations or the use of approved contractual safeguards or other lawful transfer mechanisms.
We therefore do not guarantee that all information will at all times be physically stored only within the United Kingdom.
Personal Data Breaches
We take reasonable measures to prevent unauthorised access to, loss of or disclosure of personal information.
If a personal data breach occurs, the circumstances and potential risks will be assessed and documented and appropriate steps will be taken to contain and address the breach.
Where a breach is required to be reported to the Information Commissioner’s Office, this will be done without undue delay and, where feasible, within 72 hours of becoming aware of the breach.
Where a personal data breach is likely to result in a high risk to your rights and freedoms, you will also be informed without undue delay where required by law.
How Long We Keep Your Information
Personal information will only be retained for as long as there is an appropriate professional, legal, regulatory, insurance or business reason for doing so.
As a general practice policy, clinical records relating to adult clients will normally be retained for 7 years following the end of treatment.
Records relating to children and young people may need to be retained for longer, taking account of their age when treatment ends and relevant professional, legal and insurance requirements.
Financial and business records may be retained for different periods where this is required for accounting, tax or other legal purposes.
Where there is a specific reason to retain information for longer, for example, an ongoing complaint, legal claim, safeguarding matter or regulatory requirement, the relevant information may be retained until that matter has been appropriately concluded.
At the end of the applicable retention period, records will be securely deleted or destroyed unless there is a lawful reason for their continued retention.
Requests for Access to Your Information
You may request access to personal information held about you.
Requests can be made verbally or in writing, although providing the request in writing may help us understand exactly what information you require.
We will respond in accordance with the time limits and requirements set by applicable data protection legislation.
In some circumstances, information may need to be withheld or redacted, for example where disclosure would adversely affect the rights and freedoms of another person or where another lawful exemption applies.
Concerns and Complaints
If you have a question or concern about how your personal information has been handled, please contact Bryce Psychology Services Ltd in the first instance so that the matter can be considered.
If you believe that your personal information has not been handled in accordance with data protection law, you also have the right to raise a concern with the Information Commissioner’s Office (ICO).
Concerns about the professional practice of a Registered Practitioner Psychologist may be raised with the Health and Care Professions Council (HCPC).
Dr Carl Bryce is also a Chartered member of the British Psychological Society (BPS) and works in accordance with relevant professional and ethical standards.
Changes to This Privacy Policy
This Privacy Policy may be updated periodically to reflect changes to the services provided, professional requirements, technology or data protection legislation.
The most current version will be made available on the Bryce Psychology Services Ltd website.
Questions
This Privacy Policy is provided so that you understand how your personal information is collected, used, stored and protected.
It is not necessary for consent to be the legal basis for all processing described in this policy, and attending an appointment does not change the legal basis upon which information is processed.
If you have any questions about this Privacy Policy or how your personal information is handled, please contact Bryce Psychology Services Ltd before or during your involvement with the service.
ICO Registration: ZB833278
©Copyright Dr Carl Bryce - All Rights Reserved
Company Number: 16012656