Privacy Policy 

July 2026

Olivia Roe Pathways (“I”, “me”, “my”) provides coaching psychology, wellbeing training and the Pathways Programme to individuals, schools, organisations and community groups. As a Chartered Coaching Psychologist registered with the British Psychological Society (BPS) and a member of the International Coaching Federation (ICF), I take the privacy, confidentiality and security of your information seriously, and this policy explains how I collect, use, store and protect it.

This policy applies to anyone who visits my website, enquires about my services or works with me as a coaching or training client, and is written in line with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations (PECR) — all as amended by the Data (Use and Access) Act 2025 (DUAA).

Who I Am (Data Controller)

• Business name: Olivia Roe Pathways

Company number 16192594

The Buttery Highland Court Farm, Bridge, Canterbury, Kent, England, CT4 5HW

• Contact email: hello@oliviaroepathways.com

ICO exempt

BPS register

ICF membership & ACC credential

I am the data controller for the personal information described in this policy, meaning I decide how and why it’s used.

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The Information I Collect

What I collect depends on how you interact with me — browsing the website is very different from being a client.

Contact and Enquiry Information

• Name, email address, phone number and, where relevant, postal address
• Details you share in enquiry forms, emails or during a free consultation call
• For organisational clients: your employer or organisation’s name, your role, and relevant contact details

Coaching, Training and Programme Information

• Session notes, goals, reflections and progress records
• Pathways Programme assessment data, including PERMA-Profiler and WEMWBS results
• Anything you choose to share about your circumstances, health, relationships or wellbeing in the course of our work together

Some of this is “special category data” under UK GDPR — information about your health (including mental health), which the law treats with extra care. I only collect this with your explicit consent, and only what’s genuinely relevant to supporting you.

Payment Information

Payments are handled through a third-party payment provider. I don’t store full card details myself; the provider processes these securely on my behalf.

Website and Technical Information

• IP address, browser type and general usage data, collected automatically when you visit the site
• Cookies and similar technologies — see the Cookies section below

WordPress, Calendly, Google Analytics, Google Docs, What’s App

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Why I Use Your Information, and My Legal Basis

UK GDPR requires a valid legal basis for every use of personal data. Here’s how that applies to my work:

• To provide coaching, training or programme services: Necessary for the performance of a contract with you or to take steps at your request before entering one.
• To use health-related or special category information: Your explicit consent, given before we begin working together and revisited as needed.
• To safeguard you or others from harm: Vital interests (where there’s an immediate risk to life or safety), or the “recognised legitimate interest” in safeguarding vulnerable individuals introduced by the DUAA, which allows this processing without a full legitimate interests balancing exercise.
• To send you information you’ve asked for, or occasional relevant updates: Consent or legitimate interests where the DUAA’s soft opt-in provisions apply (for example, following up after an enquiry).
• To meet legal, tax, insurance and professional obligations: Legal obligation, and my legitimate interest in running a properly regulated, insured practice.
• To improve the website and understand how it’s used: Consent (for non-essential cookies and analytics) or legitimate interests (for essential, low-privacy-risk functionality).

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Safeguarding and Confidentiality

Confidentiality sits at the heart of coaching and wellbeing work, and I take it seriously as both a professional and an ethical commitment, in line with the BPS Code of Ethics and Conduct and the ICF Code of Ethics, both of which I’m bound by as a Chartered Coaching Psychologist and ICF member.

What you share with me stays private, with these limits, which I’ll always explain at the start of our work together:

• If I believe there’s a serious risk of harm to you or to someone else
• If I become aware of a safeguarding concern involving a child or vulnerable adult
• If disclosure is required by law, for example under a court order

Wherever possible, I’ll discuss any concern with you directly before taking further action, unless doing so would itself increase the risk to you or someone else.

Working With Under-18s

Where the Pathways Programme is delivered to teenagers, in schools or directly, I collect appropriately tailored information, seek parental or guardian consent where required, and apply the same safeguarding principles with extra care given the additional protections the law affords to children’s data.

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How I Store and Protect Your Information

• Secure storage: Client and programme records are held in encrypted, password-protected digital systems, not on paper wherever possible e.g. Practice Better

• Access: As a sole practitioner, I’m the only person with routine access to your records. I discuss cases in professional supervision, as required by BPS and ICF standards, but always anonymised or with identifying details minimised.
• Devices and accounts: Password-protected devices and accounts, with two-factor authentication used wherever available.
• Third-party processors: Where I use external services (booking, email, payment, hosting), each is bound by a data processing agreement requiring them to protect your information to UK GDPR standards.
• International transfers: Where any service I use stores data outside the UK, I only work with providers offering appropriate safeguards, in line with the UK’s international transfer requirements.
• If something goes wrong: In the unlikely event of a data breach affecting your information, I’ll assess the risk and, where required, notify both you and the ICO within the legal timeframes.

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How Long I Keep Your Information

• Client and session records: Kept for a minimum of seven years from the end of our work together, in line with British Psychological Society record-keeping guidance and standard professional liability limitation periods.
• Records relating to clients under 18 at the time of our work: Kept until the client’s 25th birthday, reflecting standard safeguarding and professional record-keeping practice for work with minors.
• Financial and invoicing records: Kept for six years, in line with HMRC requirements.
• Marketing and mailing list data: Kept until you unsubscribe or ask me to remove you, and reviewed periodically.
• Website enquiry data that doesn’t lead to further contact: Kept for a shorter period, then securely deleted.

After the relevant period, information is securely deleted or destroyed.

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Who I Share Your Information With

I don’t sell your information, and I share it only where genuinely necessary:

• My clinical/coaching supervisor, in anonymised or minimally identifying form, as part of standard professional practice
• Professional bodies (BPS, ICF), where required for accreditation, complaints or regulatory purposes
• My professional liability insurer and legal advisors, if ever needed in connection with a claim or dispute
• Trusted service providers who help run my practice (booking, payment, email, hosting), each under a data processing agreement
• Authorities such as the police, social services or a court, where I’m legally required to share information, including in the safeguarding circumstances described above

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Cookies and Website Analytics

My website may use cookies and similar technologies to help it run properly and to understand how it’s used. Since February 2026, UK rules no longer require consent for cookies considered low-privacy-risk (such as those needed for basic site functionality), but I still ask for your consent for any analytics or marketing cookies via a cookie banner when you first visit e.g. Google Analytics, Meta Pixel.

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Your Rights

Under UK GDPR, you have the right to:

• Access: Ask what personal information I hold about you, and receive a copy.
• Rectification: Ask me to correct inaccurate or incomplete information.
• Erasure: Ask me to delete your information, where there’s no legal or professional reason I need to keep it.
• Restriction: Ask me to limit how I use your information in certain circumstances.
• Portability: Ask for certain information in a portable format, to transfer elsewhere.
• Objection: Object to processing based on legitimate interests, or to direct marketing at any time.
• Withdraw consent: Where I rely on your consent, withdraw it at any time, without affecting anything already done.

To exercise any of these, just get in touch at hello@oliviaroepathways.com. I’ll respond within one month, as required by law.

How to Complain

I hope you’d never need to, but if you’re unhappy with how I’ve handled your information, you can complain to me directly first:

• Email: hello@oliviaroepathways.com with “Data Protection Complaint” in the subject line or click here for my contact form where you can log your complaint.

I’ll acknowledge your complaint within 30 days and respond in full without undue delay.

You also have the right to complain directly to the Information Commissioner’s Office (ICO) at any time, particularly if you’re not satisfied with my response:

• Website: ico.org.uk/make-a-complaint
• Helpline: 0303 123 1113

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Professional Standards and Insurance

As a Chartered Coaching Psychologist with the British Psychological Society and a member of the International Coaching Federation, I work within their codes of ethics and conduct, covering confidentiality, professional competence and client welfare.

I hold professional liability (indemnity) insurance, which covers my coaching, training and Pathways Programme work.

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Changes to This Policy

I review this policy periodically, and will update it here as my practice, the services I offer, or data protection law changes. The “last updated” date at the top of this page will always reflect the most recent version.

Contact Me

If you have any questions about this policy or how your information is used, please get in touch:

• Email: hello@oliviaroepathways.com