Privacy Policy

Last Updated 4th October 2024

 Path Commercial Consultancy customer privacy notice

This privacy notice tells you what to expect us to do with your personal information.

·    Contact details

·    What information we collect, use, and why

·    Lawful bases and data protection rights

·    Where we get personal information from

·    How long we keep information

·    How to complain

Contact details

Telephone

07787686210

Email

rob@pathcommercial.co.uk

What information we collect, use, and why

We collect or use the following information to provide and improve products and services for clients:

·    Names and contact details

·    Website user information

We collect or use the following personal information for the operation of client or customer accounts:

·    Names and contact details

·    Addresses

·    Account information, including registration details

·    Marketing preferences

We collect or use the following personal information for information updates or marketing purposes:

·    Names and contact details

·    Addresses

·    Profile information

·    Marketing preferences

·    Purchase or account history

·    Website and app user journey information

We collect or use the following personal information for recruitment purposes:

·    Contact details (eg name, address, telephone number or personal email address)

·    Date of birth

·    National Insurance number

·    Copies of passports or other photo ID

·    Employment history (eg job application, employment references or secondary employment)

·    Education history (eg qualifications)

·    Right to work information

·    Details of any criminal convictions (eg Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks )

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

·    Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here.

·    Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.

·    Your right to erasure - You have the right to ask us to delete your personal information. You can read more about this right here.

·    Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. You can read more about this right here.

·    Your right to object to processing - You have the right to object to the processing of your personal data. You can read more about this right here.

·    Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here.

·    Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data

Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:

·    Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:

·    Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Our lawful bases for collecting or using personal information for information updates or marketing purposes are:

·    Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Our lawful bases for collecting or using personal information for recruitment purposes are:

·    Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

Where we get personal information from

·    Directly from you

·    Publicly available sources

·    Market research organisations

·    Providers of marketing lists and other personal information

·    Suppliers and service providers

How long we keep information

  1. Customer/Client Data:

    1. Retention Period: 6 years after the end of the relationship (to align with limitation periods for contract law).

    2. Legal Justification: Allows for defense against potential legal claims and tax audits.

  2. Employee Data:

    1. Retention Period: 6 years after employment ends for tax and payroll records, 3 years for health and safety records.

    2. Legal Justification: Compliance with employment law and regulations, such as HMRC requirements.

  3. Marketing Data (Opt-in/Opt-out Consent):

    1. Retention Period: Until the consent is withdrawn, or for up to 2 years if no interaction occurs

    2. Legal Justification: GDPR requires explicit consent for direct marketing, and organizations must be able to show when and how consent was given.

  4. Financial Records:

    1. Retention Period: 6 years for records related to financial transactions.

    2. Legal Justification: Complies with HMRC tax requirements.

  5. Job Applicant Data:

    1. Retention Period: 6 months to 1 year for unsuccessful applicants, unless consent is given to retain for longer.

    2. Legal Justification: Allows for compliance with UK employment laws and to address any legal claims.

  6. Health Records (for Employees):

    1. Retention Period: 40 years for health and safety-related records (e.g., asbestos exposure), or as per specific health legislation.

    2. Legal Justification: Required by health and safety regulations.

  7. Supplier and Vendor Data:

    1. Retention Period: 6 years after the contract ends.

    2. Legal Justification: Contractual obligations, plus compliance with commercial law.

 

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:           

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

Last updated

4 October 2024