This is precisely the sort of loophole that conversion therapists in the United States use to get around existing state bans, which implicitly or explicitly exempt religious counselors.
The effect of that, according to several studies, including one by the Williams Institute, is that conversion therapy in states with bans has not decreased on the ground, and in some instances has actually increased.
It makes perfect sense if you think about it. Pretty much the only people interested in doing conversion therapy are conservative religious people.
So when you exempt them from bans, you accomplish nothing or in some cases less than nothing.
New Zealand and Canada both within the past few years have outlawed conversion therapy and in no uncertain terms let religious counselors know that they were NOT exempt. Religious people howled and screamed, but the world did not end. Queer kids in religious families could breathe sighs of relief.
So, real conversion therapy bans are possible if politicians can find the moral courage to enact them.
It doesn't sound like Labour leaders have that courage.