More than just a service

Privacy Policy – Bridging Pathways Limited

1. Who We Are and Important Information

This Privacy Policy is provided by Bridging Pathways Limited, a company registered in England and Wales under company number 17170878, with its registered base in King’s Lynn, Norfolk.

Throughout this policy, “we”, “us”, or “our” refers to Bridging Pathways Limited.

We are committed to protecting your personal data and respecting your privacy. This policy explains how we collect, use, store, and share your personal data, as well as your legal rights.

We act as the data controller under the UK General Data Protection Regulation (UK GDPR), meaning we determine how and why your personal data is processed.

Contact Details

• Director / Data Lead: Terri Sharp
• Location: King’s Lynn, Norfolk
• Email: info@bridgingpathwaysltd.org

You have the right to contact us regarding any aspect of this policy or your personal data.

2. What This Policy Applies To

This privacy policy applies to your use of:

• Our website
• Booking forms
• Programme registration or expressions of interest
• Direct communication with us (email or other contact methods)

Our website may include links to third-party services. These services have their own privacy policies, and we are not responsible for their practices.

3. How We Collect Your Personal Data

We collect personal data directly from you when you:

• Complete a booking form
• Register interest in a programme
• Contact us via email or other communication channels

We only process your personal data where lawful under UK GDPR. These lawful bases include:

• Performance of a contract
• Legitimate interests (for example, responding to enquiries or improving services)
• Legal obligations
• Consent (especially for sensitive data such as counselling information)

4. The Personal Data We Collect

The data we collect is limited and relevant to the services we provide.

Identity and Contact Data

• Name
• Email address
• Phone number (if provided)

Used for:

• Responding to enquiries
• Managing bookings
• Delivering services

Lawful basis: Contract and legitimate interests

Programme Registration Data

• Information you provide when expressing interest in programmes

Used for:

• Assessing suitability
• Delivering services

Lawful basis: Contract and legitimate interests

Special Category Data (Health / Counselling Information)

Where counselling services are provided, we may collect sensitive personal data such as:

• Mental health information
• Personal history relevant to counselling

This data is:

• Collected only when necessary
• Processed with your explicit consent
• Handled in accordance with BACP ethical guidelines and UK GDPR

Lawful basis: Explicit consent

5. Counselling Records

Counselling notes are:

• Stored securely
• Managed in line with British Association for Counselling and Psychotherapy (BACP) guidance
• Retained only as long as necessary

You have the right to request access to your counselling records via a Subject Access Request (SAR).

6. If You Fail to Provide Personal Data

If you do not provide required information:

• We may be unable to deliver services
• We may not be able to proceed with bookings or programme participation

7. How We Use Your Data

We use your data to:

• Respond to enquiries
• Manage bookings and programme delivery
• Communicate with you
• Provide counselling services (where applicable)

We do not use your data for:

• Unsolicited marketing
• Selling or sharing with third parties for marketing purposes

8. Cookies

Our website may use cookies to improve functionality.

You can control cookies through your browser settings. Disabling cookies may affect website performance.

9. Marketing

We do not routinely send marketing communications.

If this changes, we will:

• Request your explicit consent
• Provide a clear option to opt out

10. Who We Share Your Personal Data With

We do not sell your data.

We may share your data only where necessary with:

• Professional advisors (e.g. legal or accounting)
• Service providers supporting website or booking systems

All third parties are required to:

• Keep your data secure
• Use it only for agreed purposes

11. How Long We Keep Your Data

We retain personal data:

• For the duration of your engagement with us
• And up to 6 years afterwards where required for legal or regulatory purposes

Counselling records are retained in line with BACP guidance.

After this period, data is securely deleted or anonymised.

12. International Transfers

We do not routinely transfer data outside the UK.

If this becomes necessary, we will ensure:

• Appropriate safeguards are in place
• Compliance with UK GDPR requirements

13. Data Security

We implement appropriate security measures to protect your data, including:

• Restricted access
• Secure storage systems
• Confidentiality obligations

We also have procedures to manage any data breaches.

14. Your Legal Rights

Under UK GDPR, you have the right to:

• Access your personal data
• Request correction of inaccurate data
• Request deletion of your data
• Restrict processing
• Object to processing
• Request data portability
• Withdraw consent at any time

To exercise these rights, contact us at:
info@bridgingpathwaysltd.org

15. Time to Respond

We aim to respond to requests within one month.

If a request is complex, we will inform you of any delay.

16. How to Complain

If you have concerns, please contact us first.

You also have the right to complain to the Information Commissioner's Office (ICO):

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

17. Changes to This Policy

We may update this policy from time to time.

Where significant changes are made, we will notify you via:

• Our website
• Direct communication where appropriate

 

 

Safeguarding Policy for Bridging Pathways Limited

1. Purpose of This Policy

Bridging Pathways Limited is committed to safeguarding adults who use our services and to acting appropriately where a child, young person, or adult at risk may be experiencing, or at risk of, abuse, neglect, exploitation, or serious harm.

Although Bridging Pathways Limited works primarily with adults, we recognise that information disclosed by an adult may indicate that a child or another adult is at risk. Where this happens, we will take appropriate safeguarding action.

This policy applies to anyone working on behalf of Bridging Pathways Limited, including directors, employees, volunteers, sessional workers, contractors, freelancers, students, and anyone else representing the organisation.

2. Who We Are

Organisation: Bridging Pathways Limited
Company number: 17170878
Registered office: 65 Mariners Way, King’s Lynn, England, PE30 2NY
Director / Safeguarding Lead: Terri Sharp
Email: info@bridgingpathwaysltd.org

3. Safeguarding Statement

Bridging Pathways Limited believes that every person has the right to live free from abuse, neglect, exploitation, discrimination, and avoidable harm.

We are committed to:

• Treating people with dignity, respect, and compassion
• Promoting wellbeing, safety, and personal autonomy
• Taking concerns seriously
• Acting promptly where there is a safeguarding concern
• Working within UK safeguarding legislation, UK GDPR, and relevant professional standards
• Sharing information where necessary to prevent serious harm or meet legal obligations

4. Adults Safeguarding Definition

Under the Care Act 2014, adult safeguarding applies where a local authority has reasonable cause to suspect that an adult:

• Has needs for care and support;
• Is experiencing, or is at risk of, abuse or neglect; and
• Because of those needs, is unable to protect themselves from that abuse, neglect, or the risk of it.

An adult at risk may include someone affected by disability, mental health difficulties, neurodivergence, illness, trauma, coercion, dependency, age-related vulnerability, substance misuse, homelessness, domestic abuse, or other circumstances affecting their ability to protect themselves.

5. Children and Young People

A child is anyone under the age of 18.

Although Bridging Pathways Limited does not primarily provide services to children, safeguarding children remains relevant where:

• An adult discloses that a child may be at risk
• A client’s circumstances indicate possible harm to a child
• There is concern about abuse, neglect, exploitation, domestic abuse, trafficking, grooming, radicalisation, or unsafe care arrangements

The current statutory guidance for England is Working Together to Safeguard Children 2023, which sets out how agencies should work together to safeguard and promote the welfare of children.

6. Types of Abuse and Harm

Safeguarding concerns may include, but are not limited to:

• Physical abuse
• Emotional or psychological abuse
• Sexual abuse
• Domestic abuse
• Neglect or acts of omission
• Financial or material abuse
• Coercive control
• Discriminatory abuse
• Organisational abuse
• Self-neglect
• Modern slavery
• Human trafficking
• Criminal exploitation
• Drug trafficking
• Child sexual exploitation
• Child criminal exploitation
• Grooming
• Online abuse
• Radicalisation or terrorism-related risk
• Honour-based abuse
• Female genital mutilation
• Forced marriage

7. Adult Safeguarding Principles

Bridging Pathways Limited aims to follow the six adult safeguarding principles used within adult safeguarding practice in England:

• Empowerment: supporting people to make their own decisions where possible
• Prevention: acting before harm occurs where possible
• Proportionality: responding in the least intrusive way appropriate to the risk
• Protection: supporting those in greatest need
• Partnership: working with appropriate agencies where necessary
• Accountability: being clear and transparent in safeguarding decisions

8. Confidentiality, GDPR and Mandatory Reporting

Bridging Pathways Limited respects confidentiality and handles personal data in line with UK GDPR and the Data Protection Act 2018.

However, confidentiality is not absolute.

Bridging Pathways Limited has mandatory reporting and safeguarding obligations which may override confidentiality and GDPR where disclosure is necessary, lawful, and proportionate.

We may breach confidentiality and share information without consent where there is a risk of serious harm, a legal obligation, or a public interest duty. This includes, but is not limited to:

• Risk of serious harm to the client or another person
• Risk to a child
• Risk to an adult at risk
• Terrorism or radicalisation concerns
• Money laundering
• Drug trafficking
• Human trafficking
• Modern slavery
• Serious criminal activity
• Court orders or lawful requests from statutory agencies

The Prevent duty under the Counter-Terrorism and Security Act 2015 applies to specified authorities and concerns preventing people from being drawn into terrorism. Even where Bridging Pathways Limited is not itself a specified authority, terrorism-related concerns may still require safeguarding or police referral.

Money laundering concerns may trigger reporting obligations under the Proceeds of Crime Act 2002.

9. Responding to a Safeguarding Concern

If a safeguarding concern arises, Bridging Pathways Limited will:

1. Listen calmly and take the concern seriously.
2. Avoid promising absolute confidentiality.
3. Record the concern accurately.
4. Consider immediate risk.
5. Contact emergency services if there is immediate danger.
6. Seek advice from the relevant safeguarding authority where appropriate.
7. Make a referral to adult safeguarding, children’s social care, police, or another relevant agency where required.
8. Keep a clear record of actions taken and the reasons for decisions.

In an emergency, call 999.

For non-emergency police concerns, call 101.

10. Safeguarding Records

A written record will be kept of safeguarding concerns. Records should include:

• Date and time of concern or disclosure
• Name of the person involved
• Details of the concern
• Exact words used where relevant
• Any immediate risks identified
• Action taken
• Who was contacted
• Decisions made and reasons for those decisions
• Name of the person completing the record

Safeguarding records will be stored securely and confidentially.

11. Counselling Notes and Subject Access Requests

Where counselling or therapeutic work is provided, notes will be kept in accordance with UK GDPR, the Data Protection Act 2018, and relevant professional standards including BACP expectations.

Clients may request access to their personal data, including counselling records, by making a Subject Access Request.

Requests should be sent to:

info@bridgingpathwaysltd.org

Information may be withheld or redacted where lawful, for example where disclosure would create serious risk of harm or would reveal third-party information.

12. Information Sharing

Information will only be shared where necessary, lawful, and proportionate.

Where possible, Bridging Pathways Limited will seek consent before sharing safeguarding information. However, consent may not be sought, or may be overridden, where doing so could increase risk or prevent appropriate safeguarding action.

Information may be shared with:

• Adult social care
• Children’s social care
• Police
• NHS or mental health crisis services
• Local safeguarding teams
• Professional advisors
• Regulatory or legal bodies where required

13. Safe Practice

Anyone working on behalf of Bridging Pathways Limited must:

• Maintain professional boundaries
• Treat all clients with dignity and respect
• Avoid exploitative, discriminatory, or abusive behaviour
• Record safeguarding concerns promptly
• Report concerns to the Safeguarding Lead
• Follow this policy and any related procedures

14. Training and Awareness

Bridging Pathways Limited will ensure that relevant people working on behalf of the organisation understand:

• What safeguarding is
• How to recognise signs of abuse, neglect, exploitation, or serious harm
• How to respond to disclosures
• When confidentiality may need to be breached
• How to report concerns
• How to record safeguarding information appropriately

15. Online and Digital Safeguarding

Where services are delivered online, Bridging Pathways Limited will take reasonable steps to protect clients by:

• Using appropriate communication channels
• Maintaining professional boundaries
• Protecting confidential information
• Avoiding unnecessary recording of sessions
• Ensuring digital records are stored securely

16. Whistleblowing

Anyone working with or for Bridging Pathways Limited is encouraged to raise concerns about unsafe, unethical, unlawful, or poor safeguarding practice.

Concerns may relate to:

• A client being placed at risk
• Failure to act on safeguarding concerns
• Unsafe professional conduct
• Abuse of power
• Breaches of confidentiality
• Illegal activity

Whistleblowers will be treated fairly and concerns will be taken seriously.

17. Important Contacts

Bridging Pathways Safeguarding Lead
Terri Sharp
Email: info@bridgingpathwaysltd.org

Emergency services: 999
Police non-emergency: 101

Information Commissioner’s Office:
https://ico.org.uk/make-a-complaint
0303 123 1113

18. Policy Review

This policy will be reviewed regularly and updated when legislation, guidance, organisational practice, or safeguarding responsibilities change.

Last updated: May 2026

Equality, Diversity and Inclusion (EDI) Policy – Bridging Pathways Limited

1. Policy Statement

At Bridging Pathways Limited, we are committed to embedding equality, diversity and inclusion (EDI) into all aspects of our work.

We believe that every individual has the right to access safe, respectful, and equitable support. We recognise that people may face systemic barriers, stigma, and marginalisation, particularly those who are neurodivergent, disabled, or have lived experience of the Criminal Justice System (CJS).

Our approach is grounded in:

• Respect for lived experience
• Trauma-informed and person-centred practice
• Reducing stigma and discrimination
• Promoting equity rather than equality alone

We aim to create an environment where all clients, partners, and those working with us feel valued, understood, and supported.

2. Our Commitments

Bridging Pathways Limited will:

• Treat all individuals with dignity, respect, and fairness
• Recognise and value diversity in identity, background, and lived experience
• Challenge discrimination, stigma, and exclusionary practices
• Actively reduce barriers to accessing counselling and support services
• Provide reasonable adjustments tailored to individual needs
• Promote inclusive, trauma-informed, and culturally aware practice
• Ensure services are accessible to neurodivergent individuals and those impacted by the CJS
• Support individuals who may experience multiple and intersecting disadvantages
• Continuously reflect on and improve our practice through feedback and learning

3. Scope of This Policy

This policy applies to:

• The Director and anyone working on behalf of Bridging Pathways Limited
• Clients accessing counselling or group services
• Participants in programmes, including women’s groups and ADHD-focused support
• Individuals with lived experience of the Criminal Justice System
• Partners, collaborators, and stakeholders

It applies across all services, including:

• Counselling and therapeutic work
• Group programmes (including women’s and ADHD groups)
• CJS-related support and engagement
• Workshops, training, and community-based work

4. Legal Framework

This policy is informed by UK legislation and guidance, including:

• The Equality Act 2010
• The Human Rights Act 1998
• The UN Convention on the Rights of Persons with Disabilities
• The Data Protection Act 2018 and UK GDPR

Under the Equality Act 2010, we recognise the following protected characteristics:

• Age
• Disability
• Gender reassignment
• Marriage and civil partnership
• Pregnancy and maternity
• Race
• Religion or belief
• Sex
• Sexual orientation

In addition, we explicitly recognise and prioritise inclusion for:

• Neurodivergent individuals (including ADHD, autism, dyslexia and related differences)
• People with mental health conditions
• Individuals with lived experience of the Criminal Justice System
• Survivors of trauma, abuse, or systemic disadvantage
• Individuals facing socioeconomic barriers

5. Inclusive Practice in Our Work

5.1 Counselling and Therapeutic Practice

Our counselling work is:

• Person-centred and trauma-informed
• Neurodiversity-affirming
• Non-judgemental and anti-stigmatising
• Responsive to individual communication styles and processing needs

We aim to:

• Create psychologically safe spaces
• Adapt session structure and pace where needed
• Recognise the impact of trauma, marginalisation, and systemic inequality
• Support clients in ways that respect autonomy, identity, and lived experience

5.2 Neurodivergence and ADHD Support

In our work with neurodivergent individuals and ADHD groups, we:

• Use strengths-based, affirming approaches
• Avoid deficit-based or pathologising language
• Provide flexible structures and expectations
• Recognise sensory, executive functioning, and communication differences
• Support self-understanding, identity, and empowerment

5.3 Women’s Group Work

In women’s spaces, we aim to:

• Provide safe, inclusive, and supportive environments
• Recognise the impact of gender-based inequality, trauma, and societal expectations
• Support diverse experiences of womanhood, including intersectional identities
• Ensure respect, confidentiality, and psychological safety

5.4 Criminal Justice System (CJS) Work

In our work with individuals affected by the CJS, we:

• Take a non-judgemental, rehabilitative, and strengths-based approach
• Recognise the impact of stigma, systemic inequality, and trauma
• Support reintegration, identity rebuilding, and personal development
• Challenge discrimination and barriers to accessing services
• Promote dignity, respect, and opportunity

5.5 Accessibility and Adjustments

We will:

• Offer flexible appointment formats where possible
• Adapt communication styles and materials
• Provide clear, accessible information
• Make reasonable adjustments based on individual needs

Examples may include:

• Adjusted session pacing
• Alternative communication methods
• Sensory considerations
• Flexible engagement expectations

6. Challenging Discrimination

Bridging Pathways Limited has zero tolerance for:

• Discrimination
• Harassment
• Victimisation
• Stigmatising or exclusionary behaviour

This applies to all interactions within our services.

Where concerns arise, we will:

• Take them seriously
• Respond promptly and appropriately
• Take action where necessary

7. Reporting and Accountability

Anyone who experiences or witnesses discrimination or exclusion is encouraged to raise concerns.

All concerns will be handled:

• Confidentially
• Sensitively
• Without fear of negative consequences

Contact

Terri Sharp (Director)
Email: info@bridgingpathwaysltd.org

8. Monitoring and Continuous Improvement

We are committed to ongoing reflection and improvement.

We will:

• Seek feedback from clients and participants
• Review accessibility and inclusivity of our services
• Reflect on gaps in provision or barriers to access
• Update practices in response to lived experience and emerging needs

Where appropriate, monitoring may include anonymised insights to improve equity and access.

9. Policy Review

This policy will be reviewed regularly and updated in line with:

• Changes in legislation
• Professional guidance
• Organisational development
• Feedback from those we support

Last reviewed: May 2026

Code of Conduct – Bridging Pathways Limited

1. Applicability

This Code of Conduct applies to:

• The Director of Bridging Pathways Limited
• Any future employees, associates, contractors, volunteers, or representatives
• Anyone delivering services on behalf of Bridging Pathways Limited

This Code underpins all professional conduct, service delivery, and relationships within the organisation.

It should be read alongside safeguarding, confidentiality, and privacy policies.

2. Professional and Ethical Framework

All work delivered by Bridging Pathways Limited aligns with the ethical principles of the British Association for Counselling and Psychotherapy (BACP) Ethical Framework.

These principles include:

• Being Trustworthy
• Autonomy (respecting the client’s right to choose)
• Beneficence (working in the client’s best interests)
• Non-maleficence (avoiding harm)
• Justice (fair and equitable treatment)
• Self-respect (maintaining professional integrity and wellbeing)

These principles guide all decisions, behaviours, and professional boundaries.

3. Core Conduct Expectations

Anyone working on behalf of Bridging Pathways Limited must:

• Act with honesty, integrity, and professionalism
• Work within legal, ethical, and professional boundaries
• Maintain appropriate professional relationships at all times
• Respect the dignity, identity, and lived experience of all individuals
• Provide services in a non-judgemental and inclusive manner
• Be accountable for their actions and decisions
• Recognise limits of competence and seek supervision or support where required

4. Safe and Respectful Practice

We will:

• Create environments that are physically and psychologically safe
• Maintain clear professional boundaries at all times
• Avoid dual relationships that could impair professional judgement
• Use appropriate, respectful, and inclusive language
• Be mindful of power dynamics within therapeutic and support relationships

We will not:

• Engage in exploitative, coercive, or harmful behaviour
• Form inappropriate personal relationships with clients
• Use our position for personal gain
• Act in ways that could be perceived as abusive, discriminatory, or unsafe

5. Safeguarding and Duty of Care

All individuals working on behalf of Bridging Pathways Limited must:

• Understand safeguarding responsibilities
• Recognise signs of abuse, neglect, or risk
• Act promptly on safeguarding concerns
• Follow the Safeguarding Policy

Safeguarding responsibilities override confidentiality where there is risk of harm or legal obligation.

6. Confidentiality and Information Handling

We will:

• Respect client confidentiality in line with UK GDPR and professional standards
• Store and handle personal data securely
• Share information only where lawful, necessary, and proportionate

We will not:

• Share confidential information without a valid legal or safeguarding reason
• Misuse personal or sensitive data

7. Professional Boundaries and Communication

To maintain safe and ethical practice:

• Communication with clients will remain professional at all times
• Personal contact details or social media accounts will not be used for client relationships
• Contact outside agreed professional channels will be avoided unless necessary and appropriate
• Clear expectations around communication will be established with clients

8. Equality, Diversity and Inclusion

All conduct must align with the organisation’s EDI Policy.

We will:

• Treat all individuals fairly and without discrimination
• Respect difference and lived experience
• Challenge stigma and exclusion
• Make reasonable adjustments where needed

9. Accountability and Raising Concerns

Concerns about conduct, safety, or ethical practice must not be ignored.

Anyone working with Bridging Pathways Limited must:

• Raise concerns promptly
• Act in the best interests of client safety and wellbeing
• Report safeguarding concerns in line with policy

As a sole practitioner, the Director retains responsibility for:

• Ethical decision-making
• Seeking supervision where appropriate
• Ensuring accountability through professional standards

10. Supervision and Professional Responsibility

As part of ethical practice:

• Clinical supervision will be maintained in line with BACP expectations
• Ongoing professional development will be undertaken
• Reflective practice will inform service delivery

11. Future Staff and Associates

As Bridging Pathways Limited grows:

• This Code of Conduct will apply equally to all staff and associates
• Expectations will be embedded in contracts, onboarding, and training
• All individuals will be required to uphold the same ethical and professional standards

12. Policy Distribution and Review

This Code of Conduct will:

• Be reviewed regularly
• Be updated in line with legal, ethical, and organisational changes
• Be shared with anyone working on behalf of Bridging Pathways Limited

Last reviewed: May 2026

Fully Insured with Holistic Insurance

Member of the British Association for Counselling and Psychotherapy (BACP)

ICO Registered