Privacy Policy - Empowerment Pathways

Privacy notice

Last updated: 24 October 2026

1. Who we are

Empowerment Pathways is a group of counsellors, psychotherapists and psychologists. The data controller for your personal information, including clinical records, is Empowerment Pathways Limited (company number 15555659, ICO registration ZB785040), registered office Lifeways Centre, 30 Albany Road, Stratford-Upon-Avon, CV37 6PG. To ask about your data or make any request under section 8, use the contact page on this website or email info@empowermentpathways.net. You can make a request in any form, including by phone or WhatsApp.

2. What we collect

Contact details and the message you send through the contact form, WhatsApp or by phone.
Information you share to help us decide whether we can work with you, which may include health, relationships, sexual thoughts and behaviour, and any arrest, charge, conviction or investigation.
If therapy begins: appointment records, brief clinical notes, agreements, payment records and safeguarding information.
Information from others who refer you, such as a solicitor, probation or offender management, a GP or a family member, where you have agreed or the law allows.

3. Why we use it, and our lawful basis

To reply to you and arrange an appointment: steps at your request before a contract, and our legitimate interests in running a safe service.
To provide therapy and keep records: contract, and for health and criminal offence information, the provision of health or social care and, where needed, your explicit consent.
To keep you and others safe, meet legal duties and defend legal claims: legal obligation, vital interests and legal claims.
Where we rely on consent you can withdraw it at any time.

4. Confidentiality and when we share

Therapy is confidential. We share information only with your agreement, for example a letter to your solicitor that you have asked for, or when we must: where there is a serious risk to you or someone else, a safeguarding duty to a child or vulnerable adult, a court order, or other legal requirement. Where we can, we will tell you first. Your therapist discusses their work in clinical supervision with details minimised.

5. Who else handles your data

Our website host, our email provider, WhatsApp (if you choose to message us there), Zoom or Microsoft Teams for online sessions, and an encrypted private client records system where session notes are held. Online sessions are not recorded and no session content is stored on those video platforms. They act on our instructions under contract. We do not sell your information. If any provider handles information outside the UK, we make sure approved safeguards are in place.

6. How long we keep it

Enquiries that do not lead to therapy are deleted after 12 months. Clinical records are kept for up to seven years after therapy ends, which is the longest we hold them, then securely destroyed. You can ask for your records to be deleted earlier, and we will do so unless we need to keep them for a legal, safeguarding or insurance reason. Routine email and WhatsApp messages are deleted after one month, unless they form part of your clinical record. Accounting records are kept for the period tax law requires.

7. Security

Records are held on an encrypted, private client records system and access is limited to the therapist responsible. No system is completely secure. If a breach puts your rights at risk we will tell you and, where required, the ICO.

8. Your rights

You can ask to see your information, correct it, have it deleted or restricted in some cases, object to its use, and in some cases take a copy to another provider. These rights are not absolute; we may keep information needed for legal, safeguarding or professional reasons.

9. Complaints

Tell us first through our contact page or at info@empowermentpathways.net and we will respond within one month. You can also complain to the Information Commissioner’s Office at ico.org.uk or on 0303 123 1113.

10. Website and cookies

This site uses cookies as set out in our Cookie Policy. Non-essential cookies are used only if you accept them. This site loads its fonts from Google’s servers, so Google receives your IP address when a page loads.