top of page

Privacy Policy & Safeguarding Policy 

We have always taken data protection and confidentiality seriously at PAUL GREGORY ASSOCIATES LTD and with the changing regulations regarding data protection, PAUL GREGORY ASSOCIATES LTD has further developed it's privacy policy to help protect all users and members. The privacy policy is pretty long and wordy (we apologise!). It is designed so that there is clarity and reassurance for all involved. By continuing to use our services on or after 25th May 2018, you acknowledge our updated digital Privacy Policy below. Please feel free to contact us if you have any questions. Thank you in advance.

Privacy Policy


The General Data Protection Regulation (GDPR) is concerned with the personal information about you and how it is collected, stored and shared. This is the GDPR statement of by Paul Gregory Associates Ltd, a psychotherapy company offering in person and online therapies. This form gives information on how we collect, store, and share the information collected. Please note that information collected varies according to how Paul Gregory Associates Ltd are assisting you.

Web access and collection of information online

When you contact us to request any services, we collect information about you. Information about you is also collected when you book a consultation, complete contact forms and/or use free online resources. Information is also collected about you when you visit our website www.paulgregory by using cookies. We aim to minimise personal information collected when providing a specific service or accessing a specific feature of the website. Storing pre-consultation information (collected when booking a consultation online or occasionally by telephone). When you book assessment or treatment you are asked to provide some personal details and what you are looking for via an Initial Assessment form.

Cookies “Cookies” are small pieces of text that get entered into the memory of your browser by a website. They allow the website to store information on a user's machine and later retrieve it. PAUL GREGORY ASSOCIATES LTD uses cookies so that we can better serve you when you return to the Site. Cookies also enable us to track and target the interests of our users to enhance the onsite experience. Cookies are in not linked to any personally identifiable information. If a user rejects the cookie, they may still use the Site, although some areas may be functionally limited.

Links Our website contains links to other sites. Please be aware that we are not responsible for the content or for the privacy practices of those sites that we link to. We encourage our users to be aware when they leave our site, and to read the privacy policy of other sites that collect personal data. This privacy policy applies to personal data collected by PAUL GREGORY ASSOCIATES LTD and our associated companies.

Health record collection and confidentiality (for the use of therapeutic work only)

Your health record is kept confidential within the service and all information is stored securely. We follow the ethical guidelines of the BRITISH ASSOCIATION FOR COUNSELLORS & PSYCHOTHERAPISTS (BACP) and ICO to ensure that your information about you is collected, stored and managed securely and sensitively.

When you contact us to access psychological therapy, we collect your personal information including: your name, date of birth, address, phone number, email address, occupation, involvement with criminal justice, previous psychological therapy, medical history, and medication. We keep records of your appointments, brief notes on the topics covered during the sessions and your concerns, and any letters and/or psychometric testing completed.

Assessment and treatment related information and topics covered in the sessions will be initially stored electronically without identifying details and protected by a coding system and transferred to the office computer filing system. Your personal details and any information collected during in person sessions (including possible referral letters, questionnaires) are stored in paper format in a locked cabinet in the office. Client information is stored securely and indefinitely by Paul Gregory Associates Ltd all the time the company is registered with Companies House. Where the company ceases trading, all records will be securely destroyed.

As part of the assessment process, we collect information about whether you are happy for your GP to be informed about your contact with me and if additional support is required from them. At times we may seek further consent for sharing information if necessary.

Working with private medical insurance companies: we share your attendance with the referring insurance company. If we need to request further sessions for you, we will share some details of your sessions such the focus, progress, and need for further sessions with the insurance company. You may request to see reports or letters if you wish to do so.

Storage Methods for clinical services:

•Paper written documents as described above

•Electronic storage: de-identified, brief session notes covering the topics covered are held stored electronically and protected with a password. Paper documents are placed in your hard copy file which are stored in a locked cabinet.

•SMS is not used for in depth communication but rather as an additional medium of communication if more convenient to you.

•Smartphone is used for contact detail storage, electronic diary and client calls. Smartphone is password protected and runs the latest, regularly updated security software.

•Email: I use Outlook based email. Your email address and our correspondence will be stored in my email account.

•Website: your personal information is not stored on my website, other than to momentarily collect & send it to my Outlook account for the purposes of our initial contact, and most onward contact thereafter.

Sharing information

Supervision As part of ethical practice, I am required to seek regular supervision with another experienced psychological therapist who is qualified in this process. This is to ensure that I am able to work within optimal effectiveness thresholds and offer a consistently ethical service that is helpful to you. The supervision process is also protected by confidentiality and my consultant will not know you personally or professionally. It takes place verbally and I refer to you by your first name. This process is to ensure my professional development as well as my ethical practice. Any written communications are similarly de-identified.

You are asked to sign a consent form if your information is necessary to share with a third party. I ask you about sharing information with your GP during assessment. As discussed above, the exceptions to sharing information about you may take place if there was a danger to yourself or others.

In case of emergency: If I have a reason to believe that you are at risk to you self, to someone else or there are child protection issues, I am required to act upon these concerns. In that case I am obliged to breach confidentiality by speaking to e.g. a crisis team (harm to self) or the police (harm to others / an organisation e.g. in case of terrorism) or child protection services / Multi-agency Safeguarding Hub (MASH). If I have to breach confidentiality, where ever possible, I aim to discuss this with you first.

If I was to encounter an emergency myself and was unable to contact you myself, your name and contact details might be shared with a trusted person to inform you about the changes in our meetings. No other personal information would be shared.


Complaints should be addressed to Paul Gregory Associates Ltd first. There could be something we could offer to resolve a situation quickly, and without judgement. I hope we can establish a therapeutic relationship, which includes open communication and you are able to raise any concerns in the session. If you were still feeling unsatisfied, I can offer an appointment with my supervisor present. Alternatively, BACP have a complaints procedure that you would be welcome to use. I also hold a Professional Indemnity Insurance, Professional Liability Insurance and Employer’s Insurance.

You have the following rights…

•To see the information I hold about you

•To rectify any inaccurate or incomplete personal information

•To withdraw consent to me using your personal information

•To request your personal information be erased, or to “be forgotten,” (although if the information is needed for me to practice lawfully and ethically I may decline).

Notification of changes

This privacy policy was last updated on 27th May 2022. We reserve the right to amend or vary this policy at any time and the revised policy will apply from the date posted on this Site. You accept that by doing this, PAUL GREGORY ASSOCIATES LTD has provided you with sufficient notice of the amendment or variation.

Thank you, from all at PAUL GREGORY ASSOCIATES LTD

Client agreement

A copy of this privacy policy will always be sent to new clients. 

Safeguarding Policy

PGA Safeguarding Policy Last Reviewed September 2022

Purpose: Therapeutic rather than Administrative

The purpose of this policy is to protect adults, vulnerable adults and children from any harm that may be caused due to their coming into contact with any of our services. This includes harm arising from:

•The conduct of staff or personnel associated with PGA

•The design and implementation of PGA’s programmes and activities

The policy lays out the commitments made by PGA, and informs staff and associated personnel of their responsibilities in relation to safeguarding.

This policy does not cover:

•Sexual harassment in the workplace – this is dealt with under PGA’s Anti Bullying and Harassment Policy

•Safeguarding concerns in the wider community not perpetrated by PGA or associated personnel

What is safeguarding?

In the UK, safeguarding means protecting peoples' health, wellbeing and human rights, and enabling them to live free from harm, abuse and neglect.

In our sector, we understand it to mean protecting people, including children and at risk adults, from harm that arises from coming into contact with our staff or programmes.

Further definitions relating to safeguarding are provided in the glossary below.


•All staff contracted by PGA

•Associated personnel whilst engaged with work or visits related to PGA, including but not limited to the following: consultants; volunteers; contractors; programme visitors including journalists, celebrities and politicians

Policy Statement

PGA believes that everyone we come into contact with, regardless of age, gender identity, disability, sexual orientation or ethnic origin has the right to be protected from all forms of harm, abuse, neglect and exploitation. PGA will not tolerate abuse and exploitation by staff or associated personnel.

This policy will address the following areas of safeguarding: child safeguarding, adult safeguarding, and vulnerable adult safeguarding incl. protection from sexual exploitation and abuse.

PGA commits to addressing safeguarding throughout its work, through the three pillars of prevention, reporting and response.


PGA responsibilities

PGA will:

•Ensure all staff and volunteers have a copy or access to a copy, and are familiar with, and know their responsibilities within this policy and have a current DBS certificate. As a minimum standard, staff will be familiar with the latest version of this policy and own a copy. Service users will be made aware of, and offered a copy of, the policy via the Initial Assessment process.

•Design and undertake all its programmes and activities in a way that protects people from any risk of harm that may arise from their coming into contact with PGA. This includes the way in which information about individuals in our programmes is gathered and communicated.

•Implement stringent safeguarding procedures when recruiting, managing and deploying any staff and associated personnel

•Ensure any staff receive training on safeguarding at a level commensurate with their role in the organization

•Follow up on reports of safeguarding concerns promptly and according to due process

Staff responsibilities

Child safeguarding (under 18 years)

PGA staff and associated personnel must not:

•Engage in sexual activity with anyone

•Sexually abuse or exploit children

•Subject a child to physical, emotional or psychological abuse, or neglect

•Engage in any commercially exploitative activities with children including child labour or trafficking

Adult safeguarding

PGA staff and associated personnel must not:

•Sexually abuse or exploit at adults

•Subject an adult to physical, emotional or psychological abuse, or neglect

Vulnerable Adult safeguarding

PGA staff and associated personnel must not:

•Sexually abuse or exploit at risk adults

•Subject an at risk adult to physical, emotional or psychological abuse, or neglect

Protection from sexual exploitation and abuse

PGA staff and associated personnel must not:

•Exchange money, employment, goods or services for sexual activity. This includes any exchange of assistance that is due to beneficiaries of assistance

•Engage in any sexual relationships with beneficiaries of assistance, since they are based on inherently unequal power dynamics

Additionally, PGA staff and associated personnel are obliged to:

•Contribute to creating and maintaining an environment that prevents safeguarding violations and promotes the implementation of the Safeguarding Policy

•Report any concerns or suspicions regarding safeguarding violations to a PGA director

Enabling reports

PGA will ensure that safe, appropriate, accessible means of reporting safeguarding concerns are made available to staff and the communities we work with.

Any staff reporting concerns or complaints through formal whistleblowing channels (or if they request it) will be protected by PGA’s Disclosure of Malpractice in the Workplace (Whistleblowing) Policy.

PGA will also accept complaints from external sources such as members of the public, partners and official bodies.

How to report a safeguarding concern

Staff members who have a complaint or concern relating to safeguarding should report it immediately to their Safeguarding Focal Point (PGA director). If the staff member does not feel comfortable reporting to their Safeguarding Focal Point or line manager (for example if they feel that the report will not be taken seriously for any reason) they may report to any other appropriate member of staff. For example, this could be an other director or BACP (Regulatory body).


15 St John’s Business Park, Lutterworth, Leics. LE17 4HB Tel. 01455 883300


PGA will follow up safeguarding reports and concerns according to policy and procedure, and legal and statutory obligations.

PGA will apply appropriate disciplinary measures to staff found in breach of policy.

PGA will offer support to survivors of harm caused by staff or associated personnel, regardless of whether a formal internal response is carried out (such as an internal investigation). Decisions regarding support will be led by the survivor.


It is essential that confidentiality in maintained at all stages of the process when dealing with safeguarding concerns. Information relating to the concern and subsequent case management should be shared on a need to know basis only, and should be kept secure at all times.

Glossary of Terms

Beneficiary of Assistance

Someone who directly receives goods or services from PGA’s programme. Note that misuse of power can also apply to the wider community that the organization serves, and also can include exploitation by giving the perception of being in a position of power.


A person below the age of 18


Psychological, physical and any other infringement of an individual’s rights

Psychological harm

Emotional or psychological abuse, including (but not limited to) humiliating and degrading treatment such as bad name calling, constant criticism, belittling, persistent shaming, solitary confinement and isolation

Protection from Sexual Exploitation and Abuse (PSEA)

The term used by the humanitarian and development community to refer to the prevention of sexual exploitation and abuse of affected populations by staff or associated personnel. The term derives from the United Nations Secretary General’s Bulletin on Special Measures for Protection from Sexual Exploitation and Abuse (ST/SGB/2003/13)


In the UK, safeguarding means protecting peoples' health, wellbeing and human rights, and enabling them to live free from harm, abuse and neglect

In our sector, we understand it to mean protecting people, including children and at risk adults, from harm that arises from coming into contact with our staff or programmes. One donor definition is as follows:

Safeguarding means taking all reasonable steps to prevent harm, particularly sexual exploitation, abuse and harassment from occurring; to protect people, especially vulnerable adults and children, from that harm; and to respond appropriately when harm does occur.

This definition draws from our values and principles and shapes our culture. It pays specific attention to preventing and responding to harm from any potential, actual or attempted abuse of power, trust, or vulnerability, especially for sexual purposes.

Safeguarding applies consistently and without exception across our programmes, partners and staff. It requires proactively identifying, preventing and guarding against all risks of harm, exploitation and abuse and having mature, accountable and transparent systems for response, reporting and learning when risks materialise. Those systems must be survivor-centred and also protect those accused until proven guilty.

Safeguarding puts beneficiaries and affected persons at the centre of all we do.

Sexual abuse

The term ‘sexual abuse’ means the actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions.

Sexual exploitation

The term ‘sexual exploitation’ means any actual or attempted abuse of a position of vulnerability, differential power, or trust, for sexual purposes, including, but not limited to, profiting monetarily, socially or politically from the sexual exploitation of another. This definition incudes human trafficking and modern slavery.


The person who has been abused or exploited. The term ‘survivor’ is often used in preference to ‘victim’ as it implies strength, resilience and the capacity to survive, however it is the individual’s choice how they wish to identify themselves.

At risk adult

Sometimes also referred to as vulnerable adult. A person who is or may be in need of care by reason of mental or other disability, age or illness; and who is or may be unable to take care of him or herself, or unable to protect him or herself against significant harm or exploitation.


bottom of page