Privacy Policy

1Who We Are and How to Contact Us

• Legal name: Clearpath HR Solutions Limited
• Trading names: Clearpath UK and Clearpath Legal Solutions
• Company number: 16026971 (registered in England and Wales)
• Registered office: 167-169 Great Portland Street, 5th Floor, London, W1W 5PW
• VAT number: 512701336
• ICO registration number: ZB897751
• Data Protection Officer: dpo [at] clearpathuk.co.uk
• Telephone: 020 3773 0992

Please send all questions, requests and complaints about personal data to our Data Protection Officer. You can also write to us at our registered office, marked “For the attention of the Data Protection Officer”.

2Scope of This Policy

This policy applies to personal data about:

• visitors to www.clearpathuk.co.uk and any related pages (the “website”)
• people who contact us by phone, email, web form, live chat, WhatsApp or social media
• our clients, prospective clients, and their staff and representatives
• suppliers, partners and other people we deal with in the course of our business

It does not apply to third-party websites that we link to. Those websites have their own privacy policies.

3When We Act as a Controller or Processor

When we provide HR, employment law, health and safety or payroll services, our clients often share personal data about their own employees, workers, contractors and job applicants with us.

• Where we process that data only on our client’s instructions (for example, running payroll or maintaining HR records), we act as a data processor. The client is the data controller and is responsible for telling its staff how their data is used. Our processing is governed by our contract with the client, which includes the terms required by Article 28 of the UK GDPR.
• Where we decide for ourselves how and why data is used (for example, when giving professional advice, managing our client relationship, or meeting our own legal obligations), we act as a data controller and this policy applies.

If you are an employee of one of our clients and have questions about how your employer uses your data, please contact your employer first.

4The Personal Data We Collect

Depending on how you interact with us, we may collect:

• Identity and contact data: name, job title, employer, email address, telephone number and postal address
• Enquiry and service data: details of your enquiry, the advice or services you ask for, and our correspondence and call notes
• Client workforce data: information about a client’s employees and workers that is needed to provide our services, such as employment history, contracts, pay, absence, performance, disciplinary and grievance records
• Payroll and financial data: bank details, National Insurance numbers, tax codes, salary, pension and invoicing information
• Documents you send us: contracts, policies, handbooks, correspondence and other files
• Technical and usage data: IP address, browser and device type, pages visited, referring website and similar information collected through cookies and similar technologies (see section 11)
• Marketing data: your marketing preferences and how you interact with our emails

We only collect the data we need for the purposes set out in this policy.

5Special Category and Criminal Offence Data

HR and employment matters can involve more sensitive information, such as health and sickness records, disability, pregnancy, religion or belief, ethnic origin, sexual orientation, trade union membership, or information about criminal allegations and convictions.

We only process this data where it is necessary for our services and where the law allows it. This will usually be because it is necessary for our client to meet its obligations in employment, social security or social protection law, or for the establishment, exercise or defence of legal claims. We apply extra security to this data and restrict access to the people who need it.

Please do not send us sensitive information that we have not asked for.

6How We Collect Your Data

We collect personal data:

• directly from you, when you fill in a form, email, call, chat with us or use our services
• from our clients, about their staff, when we are providing services to them
• automatically, through cookies and similar technologies when you use our website
• from publicly available sources, such as Companies House, company websites and professional networking sites
• from third parties, such as referrers, tribunals, Acas, HMRC and pension providers, where relevant to our services

7How We Use Your Data and Our Lawful Basis

We use personal data for the following purposes, relying on the lawful bases shown:

Where we rely on legitimate interests, we have considered your rights and interests and are satisfied that they are not overridden. You can ask us for more information about this.

If you do not provide data we need to provide a service or meet a legal obligation, we may be unable to provide that service.

8Marketing

We may send you updates about employment law, HR and our services. We will only do so where you have agreed, or where you are a business client or prospective business client and the law allows it.

Every marketing email includes an unsubscribe link. You can also opt out at any time by emailing dpo [at] clearpathuk.co.uk. Opting out of marketing does not affect messages we need to send you about services you have asked for.

We do not sell or rent your personal data to anyone.

9Who We Share Your Data With

We only share personal data where necessary, and with organisations that are required to keep it secure and use it only for the purposes we specify. These include:

• Service providers who support our business, such as IT, cloud hosting, email, website, CRM, payroll software, telephony, anti-spam and analytics providers
• Professional advisers, such as solicitors, barristers, accountants, auditors and insurers
• Third parties connected with your matter, where you or our client have asked us to deal with them, such as Acas, employment tribunals, HMRC, pension providers and other parties to a dispute
• Regulators, courts, law enforcement and government bodies, where we are required or permitted to do so by law
• A buyer or successor of all or part of our business, under an obligation to use the data only in line with this policy

10International Transfers

We aim to store personal data in the UK or the European Economic Area. Some of our service providers may process data outside the UK. Where this happens, we make sure the transfer is protected, for example because the country has been found to provide adequate protection under UK law, or because we use the International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses.

11Cookies and Similar Technologies

Our website uses cookies and similar technologies. These are small files or code placed on your device.

• Strictly necessary: needed for the website to work and to protect it from spam and abuse (for example, our anti-spam service). These do not need your consent.
• Analytics: help us understand how visitors use the website so we can improve it (for example, Google Analytics and Ahrefs).
• Advertising: help us measure the effectiveness of our advertising (for example, Google Ads).

We will only set analytics and advertising cookies with your consent. You can withdraw consent or block cookies through your browser settings at any time. Blocking some cookies may affect how the website works.

If you use the chat or WhatsApp links on our website, the provider of that service will process your data under its own privacy policy.

12How Long We Keep Your Data

We keep personal data only for as long as we need it for the purposes it was collected for, including to meet legal, accounting and reporting requirements. As a guide:

• Enquiries that do not become clients: up to 2 years from our last contact
• Client records and advice files: 6 years after our services end, in line with the time limits for legal claims
• Payroll and financial records: at least 6 years from the end of the tax year they relate to
• Marketing data: until you unsubscribe or withdraw consent, after which we keep a suppression record so we do not contact you again
• Website analytics data: in line with the settings of the relevant analytics tool, usually no longer than 14 months

Where we act as a processor, we keep or return client data in line with our contract with the client. When data is no longer needed, we securely delete or anonymise it.

13How We Protect Your Data

We use appropriate technical and organisational measures to protect personal data against loss, misuse and unauthorised access. These include encryption, access controls, secure passwords and multi-factor authentication, firewalls and security monitoring, staff confidentiality obligations and training.

Access to personal data is restricted to people who need it for their work. No method of transmission over the internet is completely secure, so please use care when sending sensitive information by email.

If a personal data breach occurs that is likely to result in a risk to your rights, we will notify the Information Commissioner’s Office and, where required, you, within the time limits set by law.

14Your Rights

Under UK data protection law you have the right to:

• access the personal data we hold about you
• have inaccurate data corrected
• have your data deleted in certain circumstances
• restrict how we use your data in certain circumstances
• object to our use of your data where we rely on legitimate interests, and to direct marketing at any time
• data portability, where we process data by automated means on the basis of consent or contract
• withdraw consent at any time, where we rely on consent
• not be subject to decisions based solely on automated processing that have legal or similarly significant effects. We do not make decisions of this kind.

To exercise any of these rights, contact our Data Protection Officer at dpo [at] clearpathuk.co.uk. We may need to confirm your identity before responding. There is usually no charge, and we will respond within one month. This can be extended by up to two further months for complex requests, in which case we will tell you why.

Where we act as a processor for one of our clients, we will pass your request to the client and help them respond.

15Complaints

If you are unhappy with how we have handled your personal data, please contact our Data Protection Officer at dpo [at] clearpathuk.co.uk first so we can try to put things right. We will acknowledge your complaint within 30 days and investigate it without undue delay.

You also have the right to complain to the Information Commissioner’s Office (ICO), the UK regulator for data protection: ico.org.uk, telephone 0303 123 1113.

16Children

Our website and services are intended for businesses and are not aimed at children. We do not knowingly collect personal data from children through our website.

17Changes to This Policy

We may update this policy from time to time, for example to reflect changes in the law or in how we work. The latest version will always be on this page, with the effective date shown at the top. Where changes are significant, we will take reasonable steps to let you know.

18Contact Us

For any question about this policy or your personal data, please contact:

• Data Protection Officer: dpo [at] clearpathuk.co.uk
• Post: Data Protection Officer, Clearpath HR Solutions Limited, 167-169 Great Portland Street, 5th Floor, London, W1W 5PW
• Telephone: 020 3773 0992