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Recruitment Privacy Notice

1. Introduction

At Pathway we are committed to protecting and respecting your privacy. This Recruitment Privacy Notice explains how we collect, use, share, and protect your personal data in connection with your application for employment with [Your Company Name] (the "Company", "we", "us", "our"). This Notice is provided to you in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

This Notice applies to all job applicants, whether you apply directly to us or through an employment agency, head-hunter, or other third party. It does not form part of any employment contract.

2. Who We Are

We Are Pathway Limited ("Pathway") is the data controller in respect of the personal data we collect from you during the recruitment process. For any questions regarding this notice or your data, you can contact us at:

Email: [email protected] Address: 97 Alderley Road, Wilmslow, SK9 1PT

3. What Data We Collect

We collect and process the following categories of personal data in order to manage the recruitment process:

a. Identity and Contact Information

  • Full name
  • Address
  • Telephone number
  • Email address

b. Application Details

  • CV, covering letter, and application form
  • Qualifications, work history, skills, and experience
  • Interview notes and assessment outcomes

c. Right to Work and Pre-Employment Checks

  • Proof of identity and right to work in the UK
  • References and background checks where applicable

d. Equal Opportunities Monitoring (where provided)

  • Age, gender, ethnicity, and disability information (voluntary)

e. Special Category Data

Where provided or required for the purpose of reasonable adjustments (e.g. health or disability information), such data will be processed in accordance with UK GDPR rules on special category data.

4. How We Collect Your Data

We collect your personal data in the following ways:

  • Directly from you: Through applications, CVs, forms, emails, or interviews.
  • From third parties: Such as recruitment agencies or referees (with your consent where required).

5. Legal Basis for Processing

We only process your personal data where we have a lawful basis to do so. The table below sets out the purposes for which we process your data and the corresponding legal basis under UK GDPR:

  • Assessing and progressing your job application — Processing necessary to take steps at your request prior to entering a contract (Article 6(1)(b)).
  • Complying with legal obligations (e.g. right to work checks) — Legal obligation (Article 6(1)(c)).
  • Managing the recruitment process fairly — Legitimate interests (Article 6(1)(f)).

Where we process special category data, we will do so under the appropriate UK GDPR condition — for example, explicit consent or processing necessary for employment reasons as permitted under the Data Protection Act 2018.

6. How We Share Your Data

We do not sell or rent your personal data. However, we may share your data with:

  • Recruitment agencies and head-hunters assisting with the process.
  • HR or recruitment system providers acting as data processors on our behalf.
  • Other third parties where necessary for recruitment and compliance purposes.

We require all third parties to implement appropriate technical and organisational safeguards to protect your personal data.

7. International Transfers

If any personal data is transferred outside the UK, we will ensure appropriate safeguards are in place in line with UK GDPR requirements. You can request details of these safeguards by contacting us at the address above.

8. Data Retention

We retain your personal data only for as long as necessary for the recruitment purposes and in line with our data retention policy:

  • Application data is retained for up to 6–24 months after the recruitment exercise ends, to allow us to respond to queries and meet legal obligations.
  • Longer retention may apply where necessary — for example, for equalities monitoring, legal claims, or compliance with statutory obligations.

Once the retention period expires, we securely delete or anonymise your data.

9. Your Rights

Under UK data protection law, you have the following rights regarding your personal data:

  • Access: Request a copy of the data we hold about you.
  • Rectification: Correct inaccurate or incomplete data.
  • Erasure: Request the deletion of your data (subject to certain conditions).
  • Restriction: Request limited use of your data.
  • Data Portability: Receive your data in a structured, machine-readable format (in limited circumstances).
  • Objection: Object to processing based on legitimate interests.

To exercise any of these rights, please contact us at [email protected].

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.

10. Data Security

We take appropriate technical and organisational measures to protect your data from unauthorised access, alteration, disclosure, or destruction. All third parties with whom we share your data are required to do the same.

11. Changes to This Notice

We may update this Notice from time to time to reflect changes in our practices or legal requirements. The latest version will be published on our website or provided to you on request.

Last Updated: 28/02/2026