Privacy Policy

Clear Path Consultants (“we”, “us”, “our”) is committed to protecting your personal information. This Privacy Policy explains how we collect, use, store, and share your personal data when you use our website, contact us, or use our Personal Budgeting & Administrative Support (PBAS) services.

This policy is intended to meet the transparency requirements of the UK General Data Protection Regulation (UK GDPR).

1. Who we are

2. The personal data we collect

We may collect and process the following categories of personal data:

a) Identity and contact data

• Name
• Date of birth
• Address history
• Email address
• Telephone number

b) Service and financial organisation data (PBAS)

• Information about your income, expenditure, household circumstances, and financial commitments
• Information about your creditors (creditor names, reference numbers, balances, account status)
• Factual notes from conversations with you

c) Communications data

• Emails, messages, and call notes
• Call recordings for training, monitoring, and quality purposes (where applicable)

d) Website data

• IP address
• Device and browser information
• Pages visited and analytics data
• Enquiry form submissions

e) Special category data

In limited cases, you may disclose health or vulnerability information. We process this data only where necessary and with appropriate safeguards and explicit consent.

3. How we use your data

• Provide PBAS services including budgeting support and administrative assistance
• Communicate with you during enquiry, onboarding, and ongoing service delivery
• Request factual information from creditors with a signed Letter of Authority
• Take and manage payments for our services
• Maintain records for audit, complaint handling, and service quality
• Protect our business and clients through fraud prevention and security controls

4. Our lawful bases for processing

• Contract – processing necessary to provide our services
• Legitimate interests – operating, improving, and protecting our business
• Legal obligation – compliance with legal and regulatory requirements
• Consent – where required, including special category data

Where health-related or vulnerability data is provided, we generally rely on explicit consent, which may be withdrawn at any time.

5. Payments and card data

6. Who we share your data with

We do not sell your personal data.

• Payment and merchant service providers
• IT, CRM, and communication service providers
• Professional advisers such as accountants or solicitors
• Debt advice providers or charities where you request referral or consent
• Creditors, only with your written authority and for factual information requests

7. International transfers

Some service providers may process data outside the UK. Where this occurs, appropriate safeguards are applied to protect your data in line with UK data protection law.

8. How long we keep your data

• Client records: up to 6 years after our relationship ends
• Call recordings: typically up to 6 years
• Enquiry records: typically retained for 12 months

9. Security

We use appropriate technical and organisational security measures including secure systems, access controls, staff training, and data minimisation practices.

10. Your data protection rights

• Right of access
• Right to rectification
• Right to erasure (in certain circumstances)
• Right to restrict processing
• Right to data portability
• Right to object to processing
• Right to withdraw consent

11. Marketing preferences

You may opt out of marketing communications at any time. You always have the right to object to direct marketing.

12. Cookies

• Essential cookies required for website functionality
• Non-essential cookies used only where consent is provided

13. Complaints

If you have concerns about how your data is handled, please contact us first. You also have the right to complain to the UK Information Commissioner’s Office (ICO).

14. Changes to this policy

This Privacy Policy may be updated from time to time. The latest version will always be available on our website.