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Bargate Wellbeing Services Privacy Notice

At Bargate Wellbeing Services, we know that the information you share with us when seeking counselling, training or workplace wellbeing support is personal and often sensitive. This Privacy Notice explains what personal data we collect, why we collect it, how we use it, and the rights you have over it.



This notice is written to meet our obligations under Articles 13 and 14 of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

A note on our different services

Bargate Wellbeing Services operates in three ways, and the data we hold differs slightly between them:

• Standard counselling: we refer you to a self-employed counsellor or psychotherapist, who then holds full clinical and data protection responsibility for your ongoing casework and notes.
• Low-cost counselling: you are seen by one of our counsellor trainees (volunteers), and your records are held by us on our clinical case management system, WriteUpp.
• Employee Assistance Programme (EAP) and workplace training: we provide counselling and training services on behalf of employers, and EAP client records are also held on WriteUpp.

Section 5 below explains how this affects who is responsible for your data.

Contents

• 1. Who we are
• 2. How we collect information about you
• 3. The information we collect and why
• 4. Special category data (health and other sensitive information)
• 5. Who is responsible for your data: Bargate, your counsellor, or both
• 6. Our legal basis for using your information
• 7. Employee Assistance Programme (EAP) and training clients
• 8. Our website, cookies and Google Analytics
• 9. Marketing communications
• 10. Sharing your information
• 11. International transfers
• 12. Keeping your information safe
• 13. How long we keep your information
• 14. Your rights
• 15. Complaints
• 16. Changes to this notice
• 17. Contact us

1. Who we are

Bargate Wellbeing Services is a counselling and wellbeing training business. We connect members of the public with self-employed counsellors and psychotherapists, and provide counselling, training and Employee Assistance Programme (EAP) services to businesses.

For the personal data described in this notice, Bargate Wellbeing Services is a data controller under the Data Protection Act 2018 and UK GDPR. This means we decide why and how certain personal data is collected and used. In some circumstances, described in Section 5, the counsellor you are working with is the controller of your clinical records, and we are not.



Our website is www.bargatewellbeing.co.uk.

2. How we collect information about you

We collect personal data in the following ways:

• Directly from you, when you make an enquiry, complete a contact or referral form on our website, email or call us, or are allocated to a counsellor or trainee.
• From an employer or their EAP scheme, if you are referred to us through a workplace Employee Assistance Programme.
• From our website, through the use of Google Analytics (see Section 8).
• From a counsellor or trainee working with you, where they need to update us on the status of your case (for example, that counselling has ended).

3. The information we collect and why

When you make an enquiry or are referred to us, we typically collect:

• Your name.
• Your contact details (telephone number and/or email address). We do not ask for or hold your postal address.
• Why you are seeking counselling (i.e. a brief description of the issue you would like support with).
• Any mental health diagnoses you tell us about.

We use this information to:

• Understand your needs and match you with an appropriate counsellor or trainee.
• Keep a record of your enquiry and which practitioner you have been allocated to.
• Contact you about your enquiry, appointment or ongoing arrangements with us.
• Handle any concerns or complaints about the service you have received.
• Meet our own legal, insurance and professional obligations.

We do not ask for, and do not hold, any information about criminal convictions or offences.

4. Special category data (health and other sensitive information)

Information about your mental health, and the reason you are seeking counselling, is “special category data” under data protection law which is a type of information the law treats as more sensitive and gives extra protection to.

We only use this information to match you with a suitably experienced counsellor or trainee, to support the safe delivery of the service, and to meet our safeguarding, insurance and professional obligations. We do not use it for any marketing purpose, and we do not share it other than as described in Section 10.

5. Who is responsible for your data: Bargate, your counsellor, or both

How your data is looked after depends on which service you use.

Standard (self-employed practitioner) counselling

Bargate Wellbeing Services is the controller of the initial enquiry information described in Section 3 which includes your name, contact details, the reason you are seeking counselling, and any diagnosis you have told us about. We use this to find and allocate you to a counsellor.

Once you are allocated, the counsellor you work with is self-employed, holds their own professional indemnity insurance, and is individually registered with (or accredited by) their professional body. From that point, they are the controller of the clinical notes, session records and any further personal data they hold about your counselling. Bargate Wellbeing Services does not have access to, and is not responsible for, that ongoing casework record. Your counsellor will be able to give you their own privacy information about how they handle your clinical notes, and we would encourage you to ask them for this at the start of your work together.

We have a written agreement in place with each self-employed counsellor we work with, which sets out this division of responsibility for your personal data.

Low-cost counselling (trainee counsellors)

If you access our low-cost counselling option, you will be seen by one of our counsellor trainees, who volunteer with us as part of their training. For this service, Bargate Wellbeing Services remains the controller of your personal data throughout, including your session notes. This information is held securely on WriteUpp, a specialist clinical case management system used by counselling and therapy practices, and access is limited to your trainee and, where necessary for supervision or safeguarding, our clinical supervisors and management team.

6. Our legal basis for using your information

Data protection law requires us to have a valid legal basis for processing your personal data. We rely on the following:

• Consent (Article 6(1)(a)) — for special category data such as details of your mental health or the reason for your referral, we rely on your explicit consent (Article 9(2)(a)), which you give when you make contact with us.
• Contract (Article 6(1)(b)) — to take steps at your request before entering into, or in order to perform, an arrangement to provide you with counselling or training services.
• Legitimate interests (Article 6(1)(f)) — for administrative matters such as keeping a record of your enquiry, quality monitoring, and handling complaints, where this does not override your own interests and rights.
• Legal obligation (Article 6(1)(c)) — where we need to keep or disclose information to comply with the law, for example in response to a court order.

You can withdraw consent at any time by contacting us (see Section 17). This will not affect the lawfulness of anything we did with your data before you withdrew consent, but it may mean we are unable to continue offering you a service.

7. Employee Assistance Programme (EAP) and training clients

We provide EAP counselling and workplace training services to businesses. Where an employer refers you to us under an EAP arrangement, we act as controller of your personal data for the purpose of providing you with counselling, in the same way as described for our low-cost service in Section 5 — your records are held securely on WriteUpp.

We only tell your employer that you have made contact with us and, where relevant, general non-identifiable usage statistics about the EAP scheme (for example the number of employees who have used it). We do not share the content of your sessions, your diagnosis, or the reason you sought support with your employer, unless you have given us explicit consent to do so, or we are required to by law (see Section 4 and Section 10).



If you attend training delivered by us on behalf of your employer, we may collect your name and contact details, and details of your attendance and any certification, in order to administer the course and confirm attendance to the commissioning employer.

8. Our website, cookies and Google Analytics

We use Google Analytics on www.bargatewellbeing.co.uk to help us understand how visitors use our website, such as which pages are most visited, so that we can improve it. Google Analytics uses cookies, which are small data files placed on your device.

The information collected through Google Analytics is generally aggregated and does not identify you personally. Where cookies are not strictly necessary for the website to function, we ask for your consent before they are set, through a cookie banner or settings tool on our website, in line with the Privacy and Electronic Communications Regulations (PECR). You can withdraw this consent, or change your cookie preferences, at any time through your browser settings or our cookie settings tool.



Data collected through Google Analytics is processed by Google, which may involve your data being transferred outside the UK (see Section 11).

9. Marketing communications

We do not send marketing communications to people who make contact with us seeking counselling. If, in future, we introduce a newsletter or similar communication for supporters or business clients, we will only do so with your consent, and you will always be able to opt out or unsubscribe at any time.

10. Sharing your information

We do not sell or share your personal information with any organisation for their own marketing purposes.

We may share your information in the following limited circumstances:

• With the counsellor or trainee we allocate you to, so they can provide you with support.
• With our clinical supervisors, where this is necessary to support the safe and effective delivery of the low-cost or EAP service.
• With WriteUpp, our clinical case management system provider. WriteUpp is a case management system designed specifically for UK counsellors and therapists; it processes data on our behalf under a data processing agreement, and is contractually required to keep it secure and use it only as we instruct.
• With Google, through our use of Google Analytics, as described in Section 8.
• Where there is a serious concern about your safety or the safety of someone else.
• Where we are required to do so by law, for example by a court order.
• For the establishment, exercise or defence of legal claims.

Where a self-employed counsellor holds your clinical records independently (see Section 5), any further sharing of that information is a matter for them as an independent data controller, and they will be able to explain their own approach to you.

11. International transfers

Most of the personal data we hold is stored within the UK. However, some of the third-party services we use, such as Google Analytics, may transfer data outside the UK. Where this happens, we rely on the safeguards required by UK data protection law, such as the UK's international data transfer addendum or a finding that the destination country provides an adequate level of protection, to ensure your information continues to be protected.

12. Keeping your information safe

We take the security of your personal information seriously and have put in place appropriate technical and organisational measures to protect it against unauthorised access, loss, misuse or disclosure. Personal data held for our low-cost and EAP clients is stored on WriteUpp, a system designed for use by counselling and therapy services, with access limited to those who need it.



While we do our best to protect information sent to us over the internet, no method of transmission is completely secure, and we cannot guarantee the security of data you send to us before it reaches us.

13. How long we keep your information

We keep your personal information for no longer than is necessary for the purpose it was collected for, and in line with the guidance of relevant professional bodies for the retention of counselling-related records.

• Enquiry and allocation information held by us: kept for as long as needed to provide our service and deal with any related queries, and then for a further period to meet our insurance, legal and professional obligations, after which it is securely deleted.
• Low-cost and EAP client records on WriteUpp: retained in line with our clinical records retention policy, which reflects the recommendations of relevant professional and regulatory bodies for psychological therapy records.
• 

A copy of our full retention schedule is available on request — please contact us using the details in Section 17.

14. Your rights

Under data protection law, you have the following rights in relation to the personal data we hold about you:

• Access — to ask us for a copy of the personal data we hold about you.
• Rectification — to ask us to correct inaccurate or incomplete data.
• Erasure — to ask us to delete your data, where we no longer need it, you withdraw consent, or we have no lawful basis to keep it.
• Restriction — to ask us to limit how we use your data in certain circumstances.
• Portability — to ask us to provide certain data to you, or to another organisation, in a structured, commonly used format.
• Objection — to object to our use of your data where we rely on legitimate interests.
• Withdrawing consent — to withdraw consent at any time, where we rely on consent as our legal basis.

These rights are not absolute and may not apply in every circumstance. Where your clinical records are held independently by your counsellor (see Section 5), requests about those records should be made to them directly, as they are the controller of that information.



To exercise any of these rights, please contact us using the details in Section 17. We will normally respond within one calendar month.

15. Complaints

If you have any concerns about how we have handled your personal data, please contact us in the first instance so we can try to resolve the issue. You also have the right to complain to the UK's data protection regulator, the Information Commissioner's Office (ICO):

https://ico.org.uk  |  Telephone: 0303 123 1113

16. Changes to this notice

We may update this Privacy Notice from time to time, for example to reflect changes in the law or in how we operate. The latest version will always be available on our website, www.bargatewellbeing.co.uk, along with the date it was last updated.

This is version 1.1, last updated 15.07.2026.

17. Contact us

If you have any questions about this Privacy Notice or how we handle your personal data, please contact:

Melanie Cross — Data Protection Lead

Bargate Wellbeing Services

Email: support@bargatewellbeing.co.uk

Telephone: 023 8155 0343

Website: www.bargatewellbeing.co.uk

Rebecca Webb

I am a qualified relational, humanistic counsellor and psychotherapist with a degree based in Transactional Analysis.

Transactional Analysis is a model which focuses on how we interact with others as well as how we see ourselves, others and the world. By reflecting on our thinking, feeling and behaviours we can address those aspects which are blocking us from being able to address current difficulties or perhaps from achieving our potential. I will share this knowledge with you where it would be helpful, to enable you to develop tools that you can use in everyday life beyond the completion of our work. My approach is collaborative, based in my belief that each person has their own inner knowing and wisdom. However sometimes we need an independently trained person to assist us.

I work in a relational way, which means I value the relationship we build. I will aim to build a strong, honest and trusting relationship with you, so together we might find some new ways for you to manage, or change the difficulties that have led you to seek help and support. I am trained and experienced in addiction, gambling, substance misuse, depression, anxiety, self-harm, grief/loss, OCD, isolation, anger, trauma, developmental/early relational trauma, working relationships, abusive and coercive relationships. 

You can trust that whoever you work with at Thrive Wellbeing is there to offer a safe, confidential, and respectful space.

Thrive Wellbeing offers face to face and online counselling and psychotherapy for individuals and couples. We take the time to understand what you are looking for and match you with the right counsellor, so you do not have to figure it out alone.