1. Introduction

At Reflective Pathways Counselling & Wellbeing, your privacy and the confidentiality of our work together sit at the heart of our practice. This notice explains how your personal information is collected, stored, and used in line with the UK GDPR, the Data Protection Act 2018, and the ethical framework of the British Association for Counselling and Psychotherapy (BACP). We are registered as the Data Controller with the Information Commissioner’s Office (ICO) under registration number C1975530.

2. What Information We Collect

To support our work together safely and responsibly, we may hold:

• Contact details: your name, phone number, email address, and date of birth

• Emergency contacts: your GP’s details and a next‑of‑kin

• Clinical records: brief, anonymised notes and your signed therapy agreement

• Communication records: emails, messages, or invoices exchanged between us

3. Why We Collect and Use Your Data

We process your information under the legal basis of Legitimate Interests, which allows us to provide safe, ethical counselling and coaching. Therapy involves health‑related information and is classed as Special Category Data. it is processed under Article 9(2)(h) of the GDPR, which covers health and social care.

4. How Your Data is Secured

All client information is password‑protected and stored securely.

Online sessions take place through end‑to‑end encrypted platforms to ensure your privacy.

Emails, notes and any digital records are kept in secure, encrypted systems, and recordings are never made or stored.

Your data is protected in line with GDPR, meaning your information stays confidential and remains between us.

5. Website Hosting & Squarespace

This website is hosted on Squarespace, which acts as a Data Processor. Squarespace may collect basic technical information when you visit the site (such as IP address, browser type, and essential cookies). If you use the contact form, Squarespace securely passes your message to us. Squarespace does not have access to any therapy notes or communications.

6. Confidentiality and its Exceptions

Everything you share in therapy and coaching is treated with care and confidentiality. There are a few situations where we may need to break confidentiality:

• if we believe you or someone else is at risk of serious harm

• if we are required to do so by law

• if safeguarding duties apply

Wherever possible, we will talk with you before taking any action.

7. Data Retention

Clinical notes are retained for 7 years after our final session, in line with professional insurance requirements. After this time, digital files are permanently deleted and paper records securely destroyed.

8. Your Legal Rights

You have the right to:

• request a copy of the information we hold about you

• ask for corrections to inaccurate information

• request deletion or raise concerns about how your data is used within legal and insurance limits.

9. Complaints Procedure

If you ever have concerns about the counselling service you have received, or about how your information has been handled, you are welcome to raise these with us directly at hello@reflectivepathwayscounselling.co.uk.

We will acknowledge your complaint within 7 working days and aim to provide a full response within 30 days.

Complaints about Data Protection

If your concern relates to how your personal information has been processed and you feel it has not been resolved satisfactorily, you have the right to contact the Information Commissioner's Office (ICO):

Information Commissioner's Office (ICO)
Visit the ICO website
Telephone: 0303 123 1113

The Data (Use and Access) Act 2025 also gives you the right to request an independent review of unresolved concerns regarding the use of your personal data.

Complaints about Professional Practice

If your complaint relates to the counselling service provided and you feel that it has not been resolved through our complaints process, you may contact the British Association for Counselling and Psychotherapy (BACP), which oversees the professional standards and ethical practice of its members:

British Association for Counselling and Psychotherapy (BACP)
https://www.bacp.co.uk/about-us/protecting-the-public/professional-conduct/

Please note that the BACP can only consider complaints about counsellors who are registered or accredited members of the BACP.