Privacy Policy

On the pass consultancy, privacy policy

Last updated: 14 August 2026

At On The Pass Consultancy ("we," "us," or "our"), we are committed to protecting your privacy and ensuring the security of your personal data. This Privacy Policy explains how we collect, use, store, and protect your personal information when you interact with our website (www.onthepassconsultancy.com), use our catering consultancy services, or otherwise engage with us. We are based in the United Kingdom and comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

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1. who we are

On The Pass Consultancy is the trading name of René Chapman, a sole trader based in Newport, South Wales, providing professional services to clients in the hospitality and catering industry. For data protection purposes René Chapman is the data controller responsible for your personal data. Our business address, and our address for service of documents, is Tanglin, Llandevaud, Newport NP18 2AE.

You can contact us at:

Email: info@onthepassconsultancy.com

2. information we collect

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

A) Information You Provide Directly

- Contact Information: Name, email address, phone number, and postal address when you enquire about or engage our services.

- Business Information: Details about your business, such as company name, size, and operational details, provided during consultations or enquiries.

- Payment Information: Billing details, such as bank account or credit/debit card information, when you make payments for our services.

- Correspondence: Records of communications, including emails, phone calls, or messages sent via our website or other platforms.

B) Information Collected Automatically

When you visit our website (www.onthepassconsultancy.com), we may collect:

- Technical Data: IP address, browser type, operating system, and browsing behaviour (e.g. pages visited, time spent on the site) through cookies and similar technologies (see Section 7).

- Usage Data: Information about how you interact with our website, such as clicks, downloads, or form submissions.

C) Information from Third Parties

- Business Partners: We may receive information from partners or clients, such as referrals or collaborative project details.

- Publicly Available Data: Information from public sources, such as your business website or professional profiles (e.g. LinkedIn), to tailor our services.

Special category data. Some of our consultancy work, particularly in care homes, schools and healthcare settings, involves dietary information that relates to people's health, such as allergens, texture modified diets and medical dietary requirements. We only handle this where a client instructs us to, we work from anonymised or aggregated information wherever the task allows it, and we do not collect any of it through this website.

3. how we use your information

We use your personal data for the following purposes, based on the legal grounds outlined below:

Purpose | Legal Basis

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To respond to enquiries and provide consultancy services | Performance of a contract or legitimate interests (to deliver our services)

To process payments and manage billing | Performance of a contract

To send marketing communications (e.g. newsletters, promotions) | Consent (where you have opted in) or legitimate interests (for existing clients, with an opt-out option)

To improve our website and services | Legitimate interests (to enhance user experience and business operations)

To comply with legal obligations (e.g. tax or accounting requirements) | Legal obligation

To prevent fraud or misuse of our services | Legitimate interests (to protect our business)

If you subscribe to the newsletter, our email platform records whether you opened an email and whether you clicked a link in it, and records how you arrived at the signup. We use this only to understand which topics are useful. You can stop it at any time by unsubscribing, using the link at the foot of every email.

We do not sell your personal data. We may share your information with:

- Service Providers: Third parties who assist us in delivering services, such as payment processors, IT providers, or marketing platforms (e.g. email services). These providers are bound by contracts to protect your data.

- Professional Advisors: Accountants, lawyers, or auditors, where necessary to comply with legal or regulatory requirements.

- Authorities: Government or regulatory bodies, if required by law (e.g. HMRC for tax purposes).

- Business Transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred to a new owner, with appropriate safeguards in place.

The specific providers who process personal data on our behalf are:

- Formspree (United States): receives and forwards enquiries submitted through the contact form on this website.

- Ghost(Pro) (United States): hosts this website and the newsletter subscriber list.

- Google (United States): provides Google Analytics, only where you have accepted analytics cookies.

- Microsoft (European Union): provides the email service behind info@onthepassconsultancy.com.

- jsDelivr: a content delivery network which serves some of this website's scripts and therefore receives your IP address when a page loads.

5. data retention

We retain personal data only for as long as necessary to fulfil the purposes outlined in this policy or as required by law:

- Client Data: Retained for the duration of our business relationship and up to 7 years thereafter to comply with tax and accounting obligations.

- Marketing Data: Retained until you withdraw consent or opt out of communications.

- Website Data: Cookies and usage data are typically retained for up to 12 months, depending on the cookie type (see Section 7).

- Enquiries That Do Not Become Work: Retained for 12 months from your last contact with us, after which the enquiry and your details are deleted.

- Newsletter Subscribers: Retained until you unsubscribe, plus a short period to action the removal.

- Google Analytics Data: Retained by Google for 14 months and then deleted.

6. your data protection rights

Under the UK GDPR, you have the following rights regarding your personal data:

- Access: Request a copy of the personal data we hold about you.

- Rectification: Ask us to correct inaccurate or incomplete data.

- Erasure: Request deletion of your data, where applicable (e.g. when no longer needed or if you withdraw consent).

- Restriction: Request that we limit the processing of your data in certain circumstances.

- Objection: Object to processing based on legitimate interests, including for marketing purposes.

- Data Portability: Request a copy of your data in a structured, commonly used format.

- Withdraw Consent: If we rely on your consent (e.g. for marketing), you can withdraw it at any time.

To exercise any of these rights, please contact us at info@onthepassconsultancy.com. We will respond within one month, as required by law. In some cases, we may need to verify your identity before processing your request.

7. cookies and tracking technologies

Our website uses very few cookies. Cookies are small text files stored on your device. The first time you visit, a banner asks whether you accept analytics cookies. Accept and reject carry equal weight, and doing nothing leaves analytics switched off. You can change your choice at any time.

- Strictly necessary: needed for the site to work, and to remember the cookie choice you make. These do not require consent.

- Analytics: Google Analytics, which is loaded only if you press accept. If you reject, it is never loaded and no analytics cookies are set.

- We do not use marketing or advertising cookies, and nothing on this site follows you to other websites.

For more details, please see our Cookie Policy.

8. international data transfers

Some of the providers listed in section 4 are based outside the UK, principally in the United States. This means your personal data is transferred outside the UK when you submit an enquiry through this website, when you subscribe to the newsletter, and where you have accepted analytics cookies.

Where that happens we rely on either a UK adequacy decision, the UK International Data Transfer Agreement, or the UK Addendum to the European Commission's Standard Contractual Clauses, depending on the provider.

You can request a copy of the safeguards that apply to any of these transfers by emailing info@onthepassconsultancy.com.

9. data security

We implement appropriate technical and organisational measures to protect your data, including:

- Encryption of sensitive information (e.g. payment details).

- Secure servers and regular software updates.

- Access controls to limit who can view your data.

- Periodic reviews of our security practices.

Despite our efforts, no system is completely secure. If a data breach occurs, we will notify you and the Information Commissioner's Office (ICO) as required by law.

10. third-party links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of these sites. Please review their privacy policies before sharing any personal data.

11. marketing communications

If you have opted in, we may send you marketing emails about our services, promotions, or industry updates. You can unsubscribe at any time by clicking the "unsubscribe" link in our emails or by contacting us at info@onthepassconsultancy.com.

12. changes to this privacy policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will notify you of any significant changes via a prominent notice on our website. The updated policy will be effective from the date stated at the top of this document.

13. complaints

If you have concerns about how we handle your data, please contact us in the first instance at info@onthepassconsultancy.com.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO):

Website: www.ico.org.uk

Phone: 0303 123 1113

Address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

14. contact us

For any questions about this Privacy Policy or our data practices, please get in touch: