PATHWAY RISK MANAGEMENT LTD
Pathway Risk Management Ltd (ICO registration ZA828517) takes your privacy very seriously. This Privacy Notice is intended to set out your rights and answer any queries you may have about your personal data. If you need more information, please contact email@example.com
If you have entered into a contract with us the controller of your data will be Pathway Risk Management Ltd.
Our personal information handling policy and procedures have been developed in line with the requirements of the 1995 European Union Data Protection Directive (Directive 95/46/EC) and the General Data Protection Regulation (in force from 25 May 2018) and applicable national law.
We collect and process personal data about you when you interact with us and our services and when you purchase services from us. The personal data we process includes:
- Your name
- Your username
- Your work address, email address and/or phone number
- CV if applicable
- Your job title
- Your payment and delivery details, including billing and site addresses
- Information related to the browser or device you use to access our website
- Any other information you provide.
INFORMATION USE & LEGAL BASIS
We process the personal data listed in paragraph 1 above for the following purposes:
- As required to establish and fulfil a contract with you (You enter into an agreement to provide or receive services. This may include verifying your identity, taking payments, communicating with you, providing customer services and arranging the provision of services. We require this information to enter into a contract with you and are unable to do so without it.
- To make recruitment decisions.
- To comply with applicable law and regulation.
- In accordance with our legitimate interests in protecting Pathway Risk Managements legitimate business interests and legal rights, including but not limited to, use in connection with legal claims, compliance, regulatory and investigative purposes (including disclosure of such information in connection with legal process or litigation);
- To respond to any comments or complaints we may receive from you, and/or in accordance with our legitimate interests including to investigate any complaints received from you or from others, about our services;
- We may use information you provide to personalise (i) our communications to you; (ii) our website; and (iii) products or services for you, in accordance with our legitimate interests;
- To monitor use of our websites and online services. We may use your information to help us check, improve and protect our products, content, services and websites, both online and offline, in accordance with our legitimate interests;
- We may monitor any customer account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law and our legitimate interests;
- In circumstances where you contact us by telephone, calls may be recorded for quality, training and security purposes, in accordance with our legitimate interests; and
- We may use your information to invite you to take part in our customer satisfaction surveys.
We may also send you direct marketing in relation to relevant services. Electronic direct marketing will only be sent where you have given your consent to receive it, or (where this is allowed) you have been given an opportunity to opt-out. You will continue to be able to opt-out of electronic direct marketing at any time by following the instructions in the relevant communication.
PERSONAL DATA SHARING
We may share your personal data with the third parties detailed below:
- Our professional advisors such as our auditors and external legal and financial advisors;
- Our suppliers, business partners and sub-contractors; and/or
- Search engine and web analytics.
Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if needed for the legal protection of our legitimate interests in compliance with applicable laws. Personal data may also be shared with third party service providers who will process it on behalf of Pathway Risk Management Ltd for the purposes above. Such third parties include, but are not limited to, providers of website hosting, maintenance and due diligence activities.
If our business or any part of it is sold or integrated with another business, your details will be disclosed to our advisers and those of any prospective purchaser and will be passed to the new owners of the business.
PERSONAL DATA – RETENTION
We will not keep your personal information for any purpose for longer than is necessary and will only retain the personal information that is necessary in relation to the purpose. We are also required to retain certain information as required by law or for as long as is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.
Where you are a customer, we will keep your information for the length of any contractual relationship you have with us and after that for a period of 6 years in accordance with HMRC requirements.
Where you are a prospective customer we will only retain your data (a) until you unsubscribe from our communications; or, if you have not unsubscribed, (b) while you interact with us and our content; or (c) for 12 months from when you last interacted with us or our content.
In the case of any contact you may have with our Business Development Team or Operational Administration, we will retain those details for as long as is necessary to resolve your query and for two weeks after the query is closed.
We will retain your data for a short time beyond the specified retention period, to allow for information to be reviewed and any deletion to take place. In some instances, laws may require Pathway Risk Management Ltd to hold certain information for specific periods other than those listed above.
PERSONAL DATA STORAGE
We are committed to ensuring that your information is secure. To prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect. The personal data that we collect from you is not transferred or stored outside the European Economic Area (“EEA”).
PERSONAL DATA RIGHTS
You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data, clicking the unsubscribe button on any communication we have sent to you or by contacting us.
Where you have agreed to us using your personal data, you can withdraw that consent at any time. If the information we hold about you is inaccurate or incomplete, you can notify us and ask us to correct or supplement it. You also have the right, with some exceptions and qualifications, to ask us to provide a copy of any personal data we hold about you.
Where you have provided your data to us and it is processed by automated means, you may be able to request that we provide it to you in a structured, machine readable format.
If you have a complaint about how we have handled your personal data, you may be able to ask us to restrict how we use your personal data while your complaint is resolved. In some circumstances you can ask us to erase your personal data (a) by withdrawing your consent for us to use it; (b) if it is no longer necessary for us to use your personal data; (c) if you object to the use of your personal data and we don’t have a good reason to continue to use it; or (d) if we haven’t handled your personal data in accordance with our obligations.
DATA HANDLING – MORE INFORMATION
Should you have any queries regarding this Privacy Notice, about Pathway Risk Managements processing of your personal data or wish to exercise your rights you can contact Pathway Risk Management using this email address: firstname.lastname@example.org If you are not happy with our response, you can contact the Information Commissioner’s Office: https://ico.org.uk/