Your client information

Client retention supplement · BP-CLIENT-RETENTION-2026-11-06-v1 · 6 November 2026

Bina Pathways Ltd controls the personal information it uses to register organisations, manage client access, supply workers, handle enquiries and administer bookings and payments. This supplements our company privacy notice.

What we use and why

We use business contact details, verified company information, account and location permissions, signatures and accepted terms, safety evidence, communications, bookings, attendance and invoice/payment records. We process information as necessary for contracts with individuals, legal obligations including accounting and tax, and legitimate interests in managing business relationships, preventing fraud, resolving queries and supplying workers safely. Where a contact acts for an organisation, legitimate interests will usually support business account administration. A privacy-notice acknowledgement is not blanket consent for every use.

Only upload information needed to arrange safe staffing. Do not upload complete service-user files, irrelevant health details or criminal-record information. Any necessary sensitive information requires an appropriate additional legal condition and restricted handling.

How long we keep it

Information	Retention approach
General enquiries and unused intake links	Review at closure or expiry. Eligible records may be authorised for disposal six calendar months after the documented decision. Open matters, shift-linked enquiries and claims require a separate review.
Unused client registrations	Review on closure. Registrations with no assignments, invoices, active members or accepted contract may be authorised for disposal after six calendar months. Used client relationships and accepted contracts are reviewed separately.
Client login accounts	Revoke access when it is no longer authorised. Eligible disabled accounts may be disposed of 90 days after the documented closure/review decision. Contract signatures and necessary audit attribution are retained separately.
Safety and registration documents	Keep current evidence while needed. Review replaced or closed-registration evidence; eligible copies without linked assignments or invoices may be authorised for disposal after six calendar months. Evidence needed for assignments, contracts or claims receives a documented retention review.
Invoices, payments and accounting evidence	Generally retain necessary records for at least six years from the end of the relevant company financial year, and longer where a legal obligation or unresolved matter requires it. At the review date we reassess necessity; the system does not automatically erase financial or assignment records.
Recovery copies	Managed database and complete recovery snapshots expire after 30 days unless an explicit hold applies. Disposed records are kept beyond normal use during the backup cycle and disposal decisions are reapplied before a restored system reopens. Other provider-held copies require their own documented arrangements.

These are Bina Pathways Ltd's purpose-based retention rules, not universal GDPR time limits. Legal, safeguarding, complaint, tax or investigation holds suspend disposal until explicitly released. Review dates do not automatically end a hold.

Access, sharing and your choices

Access is restricted by organisation, location and role. We share relevant information with authorised staff, supplied workers and service providers only as needed for the service, and with authorities where required. The company notice explains wider sharing and safeguards.

To request access, correction, restriction or erasure, object to relevant processing, or ask about retention, email admin@binapathways.co.uk or call 07337 541218. We verify identity and assess requests against applicable rights and duties. Erasure may not apply to records we must lawfully retain. You may complain to the Information Commissioner's Office.

Chat records and the purposes of access

Bina records verified account identity, company and department details, conversation membership, messages and attachments, booking actions, delivery/read events, security events and investigation access records. These support work communication, staffing administration, service security, fair complaint handling and necessary safeguarding investigations. Client–staff, client–management and management–staff work conversations retain existing Bina management and department oversight. Access must be used for an authorised work purpose; a role or technical capability is not permission to browse out of curiosity. Staff-only conversations require the separate director-authorised control described above.

Lawful basis and proportionate investigation

Bina records the applicable lawful basis for each purpose. Routine staffing administration and proportionate security or complaint handling may rely on legitimate interests after a documented necessity and balancing assessment; legal obligation is used only where a specific duty applies. A client supply contract is not automatically a contract basis for processing a worker’s information. Before investigation access is enabled, the director must record the concern, why access is necessary, the selected conversation, investigators and duration, and consider a less intrusive route. Complete a DPIA where required and identify any Article 9 condition, Article 10 authority and associated UK-law requirements before processing the relevant sensitive information. Staff acknowledgement is not consent to surveillance and does not replace these assessments.

Limits on access and retained evidence

Investigation access exposes the selected conversation history and available attachments during the authorised period, including new messages while access remains active. The current control does not restrict access to selected dates within a conversation. The director must consider this scope before granting it. Switching access off ends further application access; it cannot withdraw a lawful copy or information already seen. Necessary retained evidence must be placed in the restricted case record, limited to the purpose and reviewed under the applicable retention schedule. No personal app, private device content or unrelated conversation is included. Do not use this control for covert monitoring.

Acknowledgement and optional choices

Staff acknowledge receipt and understanding of the current handbook and chat policy. Clients acknowledge the operational and privacy information, and an authorised company administrator separately accepts revised contractual terms where required. Nobody may accept or sign for another user. Earlier signed versions and receipts remain historical evidence. Optional marketing, device notification permission and any genuinely optional consent remain separate, may be declined without preventing ordinary account access, and can be changed through the relevant control. Essential service and policy notices are operational communications rather than marketing.

Retention and privacy rights

Chat participants cannot delete sent messages, attachments or conversations through the app. Own-message text editing ends two minutes after original sending; edits retain their audit history. This user-interface restriction does not remove data protection rights or authorise indefinite retention. Routine closed support conversations follow the published review schedule; operational chat and necessary investigation evidence follow their applicable justified category, with a specific legal hold where required. Contact admin@binapathways.co.uk for access, correction, objection, restriction, deletion or other applicable rights. Bina will assess the legal conditions and any necessary protection of another person’s information and explain any limitation. You may complain to the ICO.

Client work chat boundaries

Clients and eligible staff may communicate for staffing and assignment purposes. Bina management and departments retain oversight of client–staff and client–management work conversations for authorised operational, service, security and safeguarding purposes. Clients cannot see another company’s conversations or staff-only conversations. Staff-only investigation controls apply solely to staff-to-staff conversations and do not switch off oversight of client work conversations. Bina must use access proportionately and follow the privacy notice, confidentiality obligations and applicable law.