1. Purpose of This Policy

1.1 This privacy policy sets out how Britannia Pathways Limited collects, uses, shares, and protects personal data in line with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and other applicable data protection laws.

1.2 This policy applies to personal data relating to candidates, clients, employees, suppliers, and contractors.

2. Who We Are

Britannia Pathways Limited is a recruitment agency offering professional staffing and employment services.

• Registered Address: 454 Chester Rd North, Sutton Coldfield, Birmingham, B73 6RG, United Kingdom.
• Company Registration Number: 16272222.
• Data Controller: For the purposes of data protection law, we act as the primary data controller for the personal data we process.

3. What Data We Collect

We collect and process the following types of personal data to provide work-finding and recruitment services:

• Contact Information: Name, address, telephone number, and personal email.
• Professional Profile: CVs, career history, education, certifications, and salary expectations.
• Verification Data: Right to work documentation, identity documents, and National Insurance number.
• Assessment Data: Interview notes, feedback, and references.
• Financial Data: Bank details and payroll information (for PAYE or placed candidates).
• Special Category Data: Health or criminal record information, processed only with explicit consent and where legally required for specific sectors (e.g., Healthcare).

4. How We Collect Data

We collect data directly from you and from trusted third-party sources:

• Job applications, CV submissions, and online registration.
• Direct interviews, phone calls, and email correspondence.
• Referrals and professional recommendations.
• Publicly available professional networks (e.g., LinkedIn) and job board databases where you have made your details available for recruiters.

5. Why We Collect Your Data (Purpose of Processing)

We process your personal data for the following legitimate business purposes:

• To match your profile with suitable job opportunities.
• To contact you regarding roles, applications, and market insights.
• To carry out essential pre-employment and compliance checks.
• To share your profile with prospective employers (Note: We will only do this with your explicit consent after informing you who the employer is).
• To manage contracts, onboarding, and PAYE payroll services.

6. Lawful Basis for Processing

Under UK GDPR, we rely on the following legal bases:

• Legitimate Interest: Necessary for our business to provide recruitment services to you and our clients.
• Contract: Necessary to take steps at your request before entering into an employment contract.
• Legal Obligation: To comply with UK law (e.g., checking Right to Work).
• Consent: Where you have given clear approval for a specific purpose (e.g., processing sensitive medical data).

7. Sharing Your Data

7.1 We may share your data with:

• Prospective Clients: For specific job opportunities.
• Service Providers: Background check providers, IT/software partners (ATS), and payroll/umbrella companies.
• Regulatory Bodies: HMRC or law enforcement if required by law.

7.2 We will never sell your data to third parties.

8. Data Retention

8.1 We retain data only for as long as necessary:

• Unplaced Candidates: Two years after the last “meaningful contact,” after which data is securely deleted unless you request otherwise.
• Placed Candidates: Six years following a placement to satisfy financial, tax, and legal audit requirements.

9. Your Rights

You have the following rights under data protection law:

• Access: Request a copy of the data we hold about you.
• Correction: Ask us to fix inaccurate or incomplete information.
• Erasure: Request that we delete your data (“The right to be forgotten”).
• Withdraw Consent: At any time where we rely on your consent.
• Lodge a Complaint: You have the right to contact the Information Commissioner’s Office (ICO) at www.ico.org.uk.

10. Contact Us

For any data protection queries or to exercise your rights, please contact:

Nishi Kanta Singha 

Founder & CEO / Data Protection Lead 

Email: nishi@britanniapathways.co.uk 

Phone: +44 7917 954935