Last updated: August 2026

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New Pathways Programme respects your privacy and is committed to protecting your personal information.

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This Privacy Policy explains what information we collect, why we collect it, how we use and protect it, who we may share it with, how long we retain it and your rights under UK data protection law.

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1. Who We Are

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New Pathways Programme is operated by Steve Fawdry, who is the data controller for the personal information described in this policy.

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New Pathways Programme
38 The Moorings
St Dogmaels
Cardigan
Pembrokeshire
SA43 3LJ

Email: hello@newpathwaysprogramme.co.uk

Website: www.newpathwaysprogramme.co.uk

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2. Information We May Collect

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Depending on how you interact with us, we may collect:

• your name;

• email address;

• telephone number;

• information you provide through enquiry or contact forms;

• appointment and booking information;

• communications between you and New Pathways Programme;

• information necessary to administer and provide our services;

• payment and transaction information;

• website usage and analytics information; and

• where relevant to our work with you, information concerning your health, symptoms, medical history, wellbeing and circumstances.

 

We only collect information that is reasonably necessary for the purposes for which it is being used.

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3. Health Information

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Information concerning your health is classed as special category personal data under UK data protection law and receives additional protection.

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Where health information is necessary to provide our services, we generally rely on Article 6(1)(b) of the UK GDPR (contract) as our lawful basis for processing your personal information, and Article 9(2)(a) (explicit consent) as our condition for processing health information.

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We obtain your explicit consent to process relevant health information as part of our client assessment process.

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You may withdraw this consent at any time. This will not affect the lawfulness of any processing that took place before consent was withdrawn. However, where processing relevant health information is necessary for us to provide our services, withdrawing consent may mean that we are unable to continue providing those services.

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We take particular care to protect the confidentiality and security of health-related information.

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4. How We Use Your Information

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We may use your personal information to:

• respond to enquiries;

• arrange consultations and appointments;

• assess whether our services may be appropriate for you;

• provide coaching, therapeutic support and programme services;

• maintain appropriate client and administrative records;

• communicate with you about appointments and services;

• process and maintain records of payments;

• comply with legal, regulatory and professional obligations;

• maintain the security and operation of our website;

• understand how our website is being used; and

• send marketing communications where we have an appropriate lawful basis to do so.

 

5. Our Lawful Bases

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Depending upon the circumstances and purpose, we may process personal information on the following lawful bases:

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Contract – where processing is necessary to take steps at your request before entering into a contract or to provide services you have asked us to provide.

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Legal obligation – where we need to process or retain information to comply with a legal requirement.

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Legitimate interests – where processing is reasonably necessary for the operation and administration of New Pathways Programme, provided those interests are not overridden by your rights and interests.

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Consent – where we have specifically asked for and received your consent, for example for certain marketing activities or where consent is the appropriate basis for a particular use of your information.

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Where we process health information or other special category data, we also identify an appropriate condition under Article 9 of the UK GDPR.

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6. Email Communications & Marketing

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If you sign up to receive emails, articles, information packs, resources or other updates from New Pathways Programme, we may use Mailchimp to manage and send those communications.

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Mailchimp may therefore process information such as your name, email address and information relating to the emails we send you.

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Where consent is required, we will only send marketing communications where you have given the appropriate consent. You can unsubscribe at any time using the unsubscribe link included in our emails.

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7. Appointment Booking

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We use Calendly to facilitate the booking and management of appointments.

If you use Calendly to arrange an appointment, information you provide during the booking process may be processed by Calendly in order to provide the booking service.

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Please avoid including unnecessary sensitive or medical information in appointment booking fields unless specifically requested.

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8. Website, Analytics and Advertising

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Our website is hosted using Wix.

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We may use services including Google Analytics to understand how visitors use our website and Google Ads to measure and improve our advertising.

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Where these services involve non-essential cookies or similar technologies, they are used subject to the consent choices available through our cookie management system.

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Further information is available in our Cookie Policy.

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9. Sharing Your Information

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We do not sell your personal information.

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We may share information with trusted service providers where reasonably necessary to operate our website, communicate with you or provide our services.

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These may include providers such as:

• Wix;

• Mailchimp;

• Calendly;

• Google; and

• providers of administrative, payment, IT or professional services used by New Pathways Programme.

 

We only share information that is reasonably necessary for the relevant purpose.

We may also disclose information where required by law or where reasonably necessary to establish, exercise or defend legal claims.

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10. International Data Transfers

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Some of the service providers we use may process personal information outside the United Kingdom.

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Where personal information is transferred internationally, we take reasonable steps to ensure that appropriate protections and safeguards required by UK data protection law are in place.

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11. How Long We Keep Your Information

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We keep personal information only for as long as reasonably necessary for the purpose for which it was collected and to meet applicable legal, regulatory, professional, insurance and record-keeping requirements.

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Certain client and business records may normally be retained for up to seven years after the end of our professional relationship where this is appropriate.

Information that is no longer required will be securely deleted or anonymised where reasonably practicable.

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12. Security

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We take reasonable technical and organisational measures to protect personal information against unauthorised access, disclosure, alteration, loss or misuse.

Because no method of electronic transmission or storage is completely secure, absolute security cannot be guaranteed.

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13. Your Rights

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Depending on the circumstances, UK data protection law gives you rights which may include the right to:

• obtain access to your personal information;

• ask us to correct inaccurate information;

• ask us to erase your information;

• restrict certain processing;

• object to certain processing;

• receive certain information in a portable format; and

• withdraw consent where processing is based on consent.

 

These rights are subject to certain legal conditions and exemptions.

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To exercise your rights, please contact:

hello@newpathwaysprogramme.co.uk

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14. Complaints

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If you have a concern about how we use your personal information, please contact us first so that we have an opportunity to address it.

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You also have the right to complain to the Information Commissioner's Office (ICO), the UK's independent data protection regulator.

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15. Cookies

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We use cookies and similar technologies on our website.

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Please see our separate Cookie Policy for information about the cookies we use and how you can manage your preferences.

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16. Changes to This Policy

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We may update this Privacy Policy from time to time to reflect changes in our services, technology, service providers or legal requirements.

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The latest version will be published on this website and the date at the top of this policy will show when it was last updated.

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17. Contact Us

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For questions about this Privacy Policy or the way we handle your personal information, please contact:

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Steve Fawdry
New Pathways Programme
38 The Moorings
St Dogmaels
Cardigan
Pembrokeshire
SA43 3LJ

Email: hello@newpathwaysprogramme.co.uk