1 Introduction

1.1  Thank you for your interest in our services and for visiting our website.  Your privacy is important to us, and we want you to understand how we use and share your personal information.

1.2  This policy sets out how we handle your personal information, including when and why it is collected, used and disclosed and how it is kept secure.

1.3  Our contact details are at the end of this policy which you can use if you have any questions or concerns, including how to update your personal information or to make a complaint.

1.4  This policy may change, so please check this page to ensure that you’re happy with any changes.

1.5  This policy was updated on 13th December 2018.

2 Who we are?

2.1  We are Direct Pathways, a partnership, owned by Lucy Bishop and Scott Bange.

2.2  Our address is Direct Pathways, Bracken House, Mill Lane, Brandeston, Woodbridge, IP13 7AP

2.3  Direct Pathways is a ‘Data Controller’, and our clients are the ‘Data Subject’.

2.4  Where this policy refers to “we”, “our” or “us” below, unless it mentions otherwise, it’s referring to Direct Pathways as the controller of your personal information.

What information do we collect?

3.1  We may collect and process the following personal information about you:

– Personal information you give to us.  This is the information about you that you give to us by corresponding with us by email or telephone, or via social media pages and is provided entirely voluntarily.  This information you give to us includes your name, contact details (such as telephone number, email address and postal address) and enquiry details relating to our services.

– Personal information we collect about you.  We may collect the following personal information including your browser and operating system, the pages of our website that you visit, the date of your visit and your IP address, for security reasons, e.g. to identify attacks on our website.   We may also collect any personal information which you allow to be shared that is part of your public profile on a third party social network.

How do we use personal information?

4.1  To update our administrative records.

4.2  To compile information relating to your use of our services.

4.3  To carry out our obligations arising from any contracts entered into between you and us to provide you with the information and services that you require from us.

4.4  To provide you with information about Direct Pathways’ services which may be of interest to you.

– For existing customers, we will only contact you by electronic means with information about services similar to those which were the subject of a previous sale or negotiations of a sale to you.

– For new customers, we will only contact by electronic means if you have consented to this.  You can opt-in or out of such notifications by following the instructions in our communication or at any time after by providing your information to us.

4.5  For internal research and development purposes.

4.6 Inviting you to participate in polls or research surveys.

5  What legal basis do we have for processing your personal data?

5.1 On the basis of your consent.  This can be withdrawn at any time by contacting us using the contact information below.

5.2 On the basis of a contract that we have entered into with you to provide services to you as our customer.

6 When do we share personal data?

6.1  To our business partners, suppliers and subcontractors for the performance of any contract we enter into with you.

6.2  Where we outsource any of our business functions under which we collect or store your data, in which case we will ensure that any such service provider adheres to at least the same obligations of security relating to your data as undertaken by us.

6.3  If we are under a duty to disclose or share your personal data to comply with any legal obligation, to enforce agreements; or to protect our rights, property, or safety of our employees, our customers or others.  This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

7  Where do we store and process personal data?

7.1 We will not sell you data to third parties for the purposes of marketing.

7.2 We will not transfer your data outside the European Economic Area (EEA).

7.3 We will store any paper documentation that includes personal information in a secure metal cabinet.

7.4 We will not use personal information in hard copy or electronic format that links individuals to internal notes for coaching or mentoring sessions.

8  How long do we keep your personal information for?

8.1 If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws.

8.2  We do not hold certain personal information in an identifiable format for longer than is necessary.

8.3  We may need your personal information to establish, bring or defend legal claims, in which case we will retain your personal information for seven years after the last occasion on which we have used your personal information in one of the ways specified in the this section.

8.4  The exceptions are where:

– The law requires us to hold your personal information for a longer period, or delete it sooner

– You exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted under this section, or because we are required under the law

9  Your rights

9.1  To protect the rights you have under data protection law, we may ask you for information to confirm your identity.  Except in rare cases, we will respond to you within 30 days after we receive this information or, where no such information is required, after we have received your request.

9.2  If you wish to change your mailing preferences or opt-out of specific marketing communications sent from Direct Pathways, you may notify us by email to mail@directpathways.co.uk.  Alternatively, you may contact us on 07484624548.

9.3  Our website may occasionally contain links to and from the websites of our partner companies.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.

9.4  You have the right to complain to the Information Commissioner’s Office (ICO) if you are concerned about the way we have processed your personal information.  Please visit the ICO’s website for further details.

10 How to contact us?

If you have any questions, suggestions or complaints about the processing of your personal information please contact using the details below:

Direct Pathways, Bracken House, Mill Lane, Brandeston, Woodbridge, IP13 7AP


07484 624548