When you apply for a job with Pathway, we collect and process information about you. This includes:

• details of your qualifications, skills, experience and employment history
• your name, address and contact details, including email address and telephone number
• whether or not you have a disability for which we need to make reasonable adjustments during the recruitment process or employment
• information about your entitlement to work in the UK.

We may also collect personal data about you from third parties, e.g. references supplied by former employers. We will seek information from third parties only once a job offer to you has been made and will inform you that we are doing so.

Data will be stored in a range of different places, including on your application record, other management systems and on other IT systems (including email).

The basis for processing data

Pathway needs to process data prior to and in order to facilitate entering into a contract with you. Pathway has a legitimate interest in processing personal data during the recruitment process and for keeping records in order to manage the process, to assess and confirm a candidate’s suitability for employment and to make decision on job offers.

Access to data

Job applicant personal information may be shared internally for the purposes of the
recruitment exercise. This includes members of the HR and recruitment team, interviewers and managers involved in the recruitment process.

Pathway will not share your data with other third parties, unless your application for employment is successful and it makes you an offer of employment. We will then share your data with former employers to obtain references for you.

Data protection

Pathway takes the security of your data seriously. It has policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties. Recruitment data is kept in a secure location with access restricted to relevant employees only.

Data retention

The Institute will only retain your personal data for as long as necessary to fulfil any legal, accounting, or reporting requirements.

If your job application for employment is unsuccessful, the Institute will hold your data on file for six months after the end of the relevant recruitment process. At the end of that period, or if you object, your data will be deleted or destroyed.

If your application for employment is successful, personal data gathered during the
recruitment process will be transferred to your personnel file and retained during your employment.

Your rights in relation to your personal information

As a data subject, you have rights under data protection laws in relation to your personal data. You have the right to:

• request access to your personal data
• request correction of the personal data that we hold about you
• request erasure of your personal data
• object to processing of your personal data where we are relying on a legitimate
  interest
• request suspension of processing of your personal data
• request the transfer of your personal data to you or to a third party
• withdraw consent at any time where we are relying on consent to process your
  personal data

We may need to request specific information from you to help us confirm your identity and ensure your right to exercise any of your rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

We try to respond to all legitimate requests within one month. It may take longer if your request is par9cularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You will not have to pay a fee to exercise any of these rights. However, we reserve the right to charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

To exercise any of these rights, please contact info@pathway.org.uk. If you believe that Pathway has not complied with your data protec9on rights, you can complain to the Information Commissioner.

July 2026