Our Commitment to GDPR

It is important to us that as a candidate or client we have your trust.  In line with the new General Data Protection Regulations (GDPR) we have reviewed and updated our policies and procedures to ensure it is communicated clearly to you at all times how we will use, store and handle your data.

Privacy Notice

As a recruitment business providing work-finding services to it’s client and work-seekers, we must process personal data (including sensitive personal data) so that we can provide such services.  In doing so, we act as data controller.


Purpose of processing and legal basis

You may provide us your personal details directly, such as on an application or registration form or via our website, or we may collect them from another source such as a job board.  We must have a legal basis for processing your personal data.  The legal bases we rely upon to offer these services to you are:

  • Consent
  • Legitimate interest
  • Legal obligation
  • Contractual obligation

Categories of data

The Company may be required to collect the following types of personal data:

  1. Full name and contact details (address, phone, email)
  2. Date of birth
  3. Payroll details (NI number, bank details)
  4. Right to Work ID documentation
  5. Driving licence details and driving history (if applicable)
  6. Employment history
  7. Qualification/accreditation/training details, including copies of certificates
  8. Relevant background checks and referencing details
  9. Next of kin emergency contact details

The Company may be required to collect the following types of sensitive personal data:

  1. Health and accessibility issues (relevant to nature of assignments being undertaken)
  2. Criminal convictions (unspent)

Legitimate interest

Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:

  1. Next of kin emergency contact details – assignments with a Hirer operate within a safety critical environment. Requirement of supply chain for us to hold emergency contact details on each candidate.
  2. Health and accessibility issues – assignments with a Hirer operate within a safety critical, physically demanding environment, with at times limited accessibility. Requirement of supply chain for us to obtain picture of any relevant health or accessibility issues and conduct in partnership with them a risk assessment to ensure the role can be carried out in a safe manner.
  3. Driving licence details and driving history – assignments with a Hirer at times require the movement of vehicles. Legal requirement to be in receipt of a valid, full UK driving licence.  Requirement of supply chain to satisfy contractual and insurer parameters for us to provide a DVLA licence check on each candidate, showing any current endorsements.
  4. Qualification/accreditation/training details – assignments with a Hirer at times require the operation of pieces of light and heavy plant machinery. Requirement of supply chain to ensure candidates have been properly trained and hold the appropriate in date certification.

Recipient/s of data

The Company will process your personal data and/or sensitive personal data with the following recipients:

  1. Hirer for the purpose of supplying a temporary worker
  2. Pathfinder Perks scheme business partners (where consent given)
  3. Port Security to satisfy ISPS Security protocol when working on an assignment within a UK port

Statutory/contractual requirement

Your personal data is required by law and/or a contractual requirement (e.g. our client may require this personal data), and/or a requirement necessary to enter into a contract. You are obliged to provide the personal data.  If such data is not provided, that as a consequence the Company are unable to provide you with temporary work-seeking services.


The Company will retain your personal data only for as long as is necessary. Different laws require us to keep different data for different periods of time.

The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services.

We must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation.

Where the Company has obtained your consent to process your personal and sensitive personal data as described we will do so in line with our retention policy, a copy of which is available on request.  Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal data and sensitive personal data.


Please be aware that you have the following data protection rights:

  1. The right to be informed about the personal data the Company processes on you;
  2. The right of access to the personal data the Company processes on you;
  3. The right to rectification of your personal data;
  4. The right to erasure of your personal data in certain circumstances;
  5. The right to restrict processing of your personal data;
  6. The right to data portability in certain circumstances;
  7. The right to object to the processing of your personal data that was based on a public or legitimate interest;
  8. The right not to be subjected to automated decision making and profiling; and
  9. The right to withdraw consent at any time.

Where you have consented to the Company processing your personal and sensitive personal data you have the right to withdraw that consent at any time by contacting either the Company Data Protection Officer or a management employee, who will be able to provide you with a Consent Withdrawal Declaration.


The Company sourced your personal data/sensitive personal data by the following means:

  1. Company website
  2. Online external Job Board
  3. Social media platform
  4. Networking event
  5. Employability stakeholder


If you wish to complain about this privacy notice or any of the procedures set out in it please contact either the Company Data Protection Officer or a management employee at Pathfinder Personnel Ltd, Pathfinder House, Testwood Park, Salisbury Road, Southampton, Hampshire, SO40 2RW or on 02380 429765 or via info@pathfinderpersonnel.com

You also have the right to raise concerns with Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been adhered to.