Privacy Policy

ReflectivE3.com

Last Updated: 16 June 2026

Introduction

ReflectivE3 is committed to protecting and respecting your privacy.

This Privacy Policy explains how we collect, use, store, share and protect your personal information when you use ReflectivE3.com, contact us through our website, book appointments, or engage with our counselling, psychotherapy and wellbeing services.

We process personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, the Privacy and Electronic Communications Regulations (PECR), and other applicable UK data protection legislation.

ReflectivE3 is operated by Ellen Rowland-Callanan, Sole Trader, and is registered with the UK Information Commissioner's Office (ICO).

1. Who We Are

Data Controller: Ellen Rowland-Callanan (Sole Trader), trading as ReflectivE3

ICO Registration Reference: ZB827554

ReflectivE3 provides counselling, psychotherapy and wellbeing services to individuals seeking therapeutic support.

Professional Memberships

ReflectivE3 works in accordance with the ethical frameworks, professional standards and guidance published by:

• National Counselling and Psychotherapy Society (NCPS)
• British Association for Counselling and Psychotherapy (BACP)

Where applicable, services are delivered in accordance with the professional and ethical requirements of these organisations.

Contacting Us

If you have any questions about this Privacy Policy, wish to exercise your data protection rights, or have concerns regarding how your information is handled, please contact us using the contact form available on ReflectivE3.com.

2. Information We Collect

Depending on the services you use, we may collect and process the following information:

Identity Information

• Full name
• Date of birth
• Emergency contact details

Contact Information

• Email address
• Telephone number
• Postal address (where provided)

Therapy Information

• Information provided during enquiries
• Assessment information
• Counselling and psychotherapy session notes
• Treatment goals and progress information
• Correspondence relating to your care
• Relevant health and wellbeing information disclosed during therapy

This information may include special category personal data relating to physical or mental health.

Technical Information

• IP address
• Browser type and version
• Device information
• Website usage data
• Cookie and analytics information

Marketing Information

• Communication preferences
• Newsletter subscription details (where applicable)

3. How We Collect Information

We collect information when you:

• Submit an enquiry through our website
• Complete website forms
• Contact us using the website contact form
• Arrange appointments
• Participate in counselling or psychotherapy sessions
• Subscribe to updates or newsletters
• Visit and interact with our website

4. How We Use Your Information

We may use your information to:

• Respond to enquiries
• Arrange and manage appointments
• Deliver counselling and psychotherapy services
• Maintain professional client records
• Meet legal, safeguarding, insurance and professional obligations
• Manage administration and business operations
• Improve our website and services
• Communicate with you regarding services you have requested
• Send marketing communications where consent has been provided

5. Legal Basis for Processing

Under UK GDPR, we rely on one or more of the following lawful bases:

Contract

To provide counselling and psychotherapy services requested by you.

Legitimate Interests

To operate, improve and protect our services and website.

Legal Obligation

To comply with legal, regulatory, safeguarding, insurance and professional requirements.

Consent

Where consent is required, including certain marketing communications and non-essential website cookies.

Special Category Data

Where health and wellbeing information is processed, ReflectivE3 relies upon the relevant conditions under Article 9 UK GDPR relating to the provision of counselling, psychotherapy and associated support services.

6. Confidentiality and Therapy Records

Information shared during counselling and psychotherapy sessions is treated confidentially and stored securely.

Confidentiality may only be limited where:

• There is a serious risk of harm to yourself or another person;
• Safeguarding concerns arise involving a child or vulnerable adult;
• Disclosure is required by law;
• A court order or legal obligation applies;
• Information is required for professional supervision in accordance with NCPS and BACP ethical requirements.

Where information is discussed during supervision, identifying details will be minimised wherever reasonably possible.

7. Sharing Information

ReflectivE3 does not sell personal information.

Information may be shared where necessary with:

• Professional supervisors
• Professional advisers and insurers
• Secure website, hosting and technology providers
• Payment processing providers where applicable
• Emergency services
• Safeguarding authorities
• Healthcare professionals where necessary and appropriate
• Regulatory authorities where legally required

Any sharing of personal information will be limited to what is necessary, proportionate and lawful.

8. Online Sessions

ReflectivE3 may provide counselling and psychotherapy sessions online using Google Meet.

Where online sessions are provided:

• Clients are encouraged to use a private and secure environment;
• Reasonable measures are taken to maintain confidentiality and security;
• Session information is managed in accordance with this Privacy Policy;
• Sessions are not routinely recorded;
• Any recording would only take place with the prior written agreement of all relevant parties.

Although Google Meet incorporates security measures, no internet-based communication system can be guaranteed to be completely secure.

9. Data Storage and Security

Client information may be stored electronically, in paper format, or both.

Appropriate technical and organisational measures are used to protect personal information, including:

• Password-protected electronic systems
• Secure storage of paper records
• Restricted access to personal information
• Secure disposal procedures
• Regular software and security updates

While every effort is made to protect personal information, no system can be guaranteed entirely secure.

10. Data Retention

Personal information is retained only for as long as necessary to fulfil the purposes for which it was collected and to meet legal, professional and insurance requirements.

ReflectivE3 typically retains:

General enquiries - Up to 12 months

Client records and session notes - 7 years after the final session

Financial records - Minimum 6 years

Marketing consent records - Until consent is withdrawn

At the end of the retention period, records are securely destroyed or permanently deleted.

11. Cookies and Website Analytics

ReflectivE3.com uses cookies and similar technologies to ensure the website functions correctly and to understand how visitors use the website.

Cookies may include:

Essential Cookies

Required for website functionality, security and accessibility.

Analytics Cookies

Used to understand website performance and visitor behaviour.

Website analytics may be provided through tools made available via the WebHealer platform and associated website management services.

Preference Cookies

Used to remember user settings and preferences.

Non-essential cookies are only placed after consent has been provided through the website's cookie consent mechanism.

You may change your cookie preferences at any time using the website's cookie settings tools.

A separate Cookie Policy should be read alongside this Privacy Policy.

12. Marketing Communications

Where marketing communications are offered, they will only be sent where:

• You have provided consent; or
• We are otherwise permitted to do so under applicable law.

You may withdraw consent and unsubscribe at any time.

13. Your Rights

Under UK data protection law, you may have the right to:

• Access your personal information;
• Request correction of inaccurate information;
• Request deletion of information where appropriate;
• Restrict processing;
• Object to processing;
• Request transfer of your personal information;
• Withdraw consent where processing relies on consent;
• Raise concerns regarding the handling of your personal information.

Requests may be submitted using the contact form available on ReflectivE3.com.

14. Data Protection Complaints Procedure

If you have concerns regarding how ReflectivE3 handles your personal information, you may submit a complaint using the contact form available on ReflectivE3.com.

Please indicate that your enquiry relates to a Data Protection Complaint and provide sufficient information for us to investigate the matter.

ReflectivE3 will:

• Acknowledge receipt of the complaint;
• Investigate the matter fairly and impartially;
• Respond without undue delay;
• Inform you of the outcome and any actions taken.

15. Complaints About Services

If you are dissatisfied with any aspect of the counselling or psychotherapy services provided by ReflectivE3, you are encouraged to raise your concerns using the website contact form so that they can be addressed promptly and fairly.

This complaints process is separate from complaints relating specifically to data protection matters.

16. Information Commissioner's Office

If you remain dissatisfied following our response to a data protection concern, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's independent authority responsible for data protection and privacy regulation.

Further information is available from the ICO website.

17. Related Policies

The following policies should be read alongside this Privacy Policy where applicable:

• Cookie Policy
• Safeguarding Policy
• Confidentiality Policy
• Website Terms of Use
• Accessibility Statement

18. Changes to This Policy

ReflectivE3 may update this Privacy Policy from time to time to reflect changes in legal requirements, professional guidance or business practices.

The most current version will always be published on ReflectivE3.com and will display the date of the latest revision.

ReflectivE3

Counselling, Psychotherapy and Wellbeing Services

Operated by Ellen Rowland-Callanan (Sole Trader)

ICO Registration Reference: ZB827554