Privacy Policy

Privacy Notice

Pathways to Independence appreciates the importance that users of our services place on the confidentiality and security of their personal information. You can be assured that we will take all measures possible to keep this as safe and secure as possible.


Information Collection

Information is collected from you to enable Pathways to process your application for accommodation and related matters thereafter. Information about you may also be collected from third parties, such as the National Probation Service or Community Rehabilitation Company, to assist in your accommodation application and support.

We collect information including sensitive information such as medical and offending history as this data enables us to identify your housing related needs, make assessments of risk and safety and plan the best support for you.

Please get in touch if you need to amend any information, so that our records are as accurate and up to date as possible.


Legal Basis and Legitimate Interests

When we collect and use your personal information, we will ensure this is only done in accordance with at least one of the legal grounds available to us under Data Protection law.

One of these is where we have obtained your specific consent to use your information for a previously notified purpose, such as to provide you with accommodation, information or support, at your request.

Another is where we have a legal obligation to use or disclose information about you – for instance where we are ordered by a court or regulatory authority, or relating to a safeguarding concern.

In all cases, we balance our legitimate interests against your rights as an individual and make sure we only use personal information in a way or for a purpose that you would reasonably expect.



We may disclose your information to third parties who provide a service to us, or we to them in the nature of dealing with accommodation applications and related support.  These may include, but is not restricted to, the following data controllers and data processors:  Medway Council, Kent County Council, Housing Benefit departments, Hyde, Riverside, Optivo and the Ministry of Housing, Communities and Local Government.

Where appropriate clients may authorise third parties e.g. health professionals to contact us on their behalf using the Permission to Disclose Information to a Third Party Form. These third parties must comply with any applicable data protection laws and we will make sure that appropriate controls are in place.

We enter into contracts with all our data processors and interrogate them on their activities to ensure that they can demonstrate compliance with our policies and procedures.

We never rent or sell any information to third parties.

Where we are under a duty to disclose your personal information in order to comply with any legal obligation (for example to government bodies and law enforcement agencies) or in order to protect our organisation, for example in case of suspected fraud or defamation.


International Transfers

We do not routinely use suppliers outside the European Economic Area (EEA), or transfer any data beyond UK borders.  If we were to, we would take steps to put in place suitable safeguards to protect your personal information by using European Commission approved standard contractual clauses.


Retention of your personal information

We retain your personal information only for as long as required to operate the service in accordance with legal and contractual requirements and tax and accounting laws.  This will be for no longer than seven years after you stop using our service.  Your information will be disposed of in a secure manner.


Your rights to your personal information

You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected.  You also have the right to request us to erase your personal information, request us to restrict our processing of it, or to object to our processing your personal information.  However, this is subject to the retention conditions above and may mean that we are unable to provide or continue providing a service to you.

You can ask for a Subject Access Request Form from the Head of Resources, providing two forms of ID.  We will send you the information requested within a month of receiving your form.

If you need to know anything further about how your information is being used, or to make a complaint, please write to the Head of Resources, Pathways to Independence, 25 Victoria Street, Rochester, Kent, ME1 1XJ.

In the event that this cannot be satisfactorily resolved, you may contact the Information Commissioner’s Office via their website



Like many other websites, Pathways uses cookies on our website. ‘Cookies’ are small pieces of information sent by an organisation to your computer and stored on your hard drive to allow that website to recognise you when you visit. They collect statistical data about your browsing actions and patterns and do not identify you as an individual.  This helps us to improve our website and deliver a better more personalised service. Please see our Cookie Policy on our website.


Changes to this privacy statement

We may need to update the terms of this policy at any time, so please do check it from time to time.  We will notify you about significant changes in the way we treat personal information by giving a notice to you or by placing a prominent notice on our noticeboards and website.


[May 2018]