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Privacy Policy

This Privacy Notice applies to all agency workers seeking work through Parkwood Healthcare.  It is important that you read this notice, together with any other privacy policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are aware of how and why we are using such information.

The Company is a recruitment business which provides work-finding services to its clients and work-seekers. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller.  We are required under data protection legislation to notify you of the information contained in this privacy notice.

You may give your personal details to the Company directly, such as on an application or registration form or via our website, or we may collect them from another source such as a jobs board. If we have obtained your details from a jobs board, the personal data that we will have collected on you prior to contacting you will be limited to your name, contact details, work history, skills and qualifications as detailed on your CV which you have provided to the jobs board. The Company must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services and/or information relating to roles relevant to you we will only use your personal data in accordance with the terms of the following statement.

1.       The data we hold about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are "special categories" of more sensitive personal data which require a higher level of protection.

We may, amongst others, collect, store, and use the following categories of personal data about you:

a)       Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses; date of birth; gender; marital status; next of kin and emergency contact information; qualifications and training certificates; National Insurance number; bank account details, payroll records and tax status information; start date; copy of driving licence; and recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process).

During the course of your registration with us, we may also collect, store and use the following categories of personal data about you:

b)       Work placement records (including job roles, work history, working hours, training records and professional memberships); performance information; complaints information; and information about your use of our information and communications systems; photographs.

We may also collect, store and use the following “special categories” of more sensitive personal data:

c)       Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions; information about your health, including any medical condition, health and sickness records; information about criminal convictions and offences; and trade union membership.


2.       How we collect your personal data

The Company will collect your personal data (which may include sensitive personal data) through the application and recruitment process and will process your personal data for the purposes of providing you with work-finding services.  We will only use your personal data for the purpose for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.  If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

We will collect additional personal data in the course of job-related activities throughout the period of you working for us.


3.       How we use your personal data

3.1    We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

a)       Where we need to perform the contract we have entered into with you.

b)       Where we need to comply with a legal obligation.

c)       Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

3.2   We may also use your personal data in the following situations, which are likely to be rare:

a)       Where we need to protect your interests or someone else’s interests.

b)       Where it is needed in the public interest.  

3.3     We will use your personal data primarily to perform our contract with you and to enable us to comply   with legal obligations.  In some cases we may use your personal data to pursue legitimate interests of our own or third parties, provided your interests and fundamental rights do not override those interests.  The situations in which we will process your personal data are:

a)       Checking you are legally entitled to work in the UK.

b)       Paying you and deducting tax and National Insurance contributions.

c)       Liaising with your pension provider.

d)       Administering the contract we have entered into with you.

e)       Business management and planning, including accounting and auditing.

f)        Complying with health and safety obligations.

g)       To prevent fraud.

h)       Equal opportunities monitoring.

3.4    If you fail to provide certain data when requested, we may not be able to perform the contract we have entered into with you (such as seeking work placements for you or paying you), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

3.5    Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

3.6    Special category data

Special categories of particularly sensitive personal data require higher levels of protection.  We need to have further justification for collecting, storing and using this type of personal data.  We may process special categories of data in the following circumstances:

a)       Where we need to carry out a legal obligation and in line with our data protection policy. 

b)       Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.

c)       When it is needed in the public interest, such as for equal opportunities monitoring and in line with the data protection policy

3.7    We will use your particularly sensitive data in the following ways:

a)       We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs to ensure meaningful equal opportunity monitoring and reporting.

b)       We will use information about your physical and mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work and provide appropriate workplace adjustments.

c)       We will use information about your trade union membership only for the purpose of assessing appropriate indemnity insurance (Registered Nurses only).

Any data in the above categories will only be processed by the Company where we have obtained your written consent.

3.8    Information about criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so.  This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our data protection policy.

Information about criminal offence data will only be processed where we have obtained your written consent.


4.       Data Sharing

4.1    The Company will process your personal data and/or sensitive data with third parties where required by law, where it is necessary to administer the working relationship with you, where we have a legitimate interest in doing so or where you have provided your written consent.  Third parties may include the following recipients:

a)       The Disclosure and Barring Service

b)       Occupational Health screening provider(s)

c)       Training providers

d)       Potential clients for the purpose of finding suitable work placements for you

e)       Payroll and pension administration

f)        Intermediaries when you provide your services through an umbrella company

g)       IT services

4.2    All our third party service providers and other entities are required to take appropriate security measures to protect your personal data in line with our policies.  We do not allow our third-party service providers to use your personal details for their own purposes.  We only permit them to process your personal data for specified purposes and in accordance with our instructions.

4.3    We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.


5.       Data Security

5.1    We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from our data protection officer.

5.2    We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so. 


6.       Data retention

6.1    We will only retain your personal data for as long as is necessary to fulfil the purposes we collected it for including for the purposes of satisfying any legal, accounting, or reporting requirements.  To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve this purpose through other means, and the applicable legal requirements.  Different laws require us to keep different data for different periods of time.

6.2    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.

6.3    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.

6.4    Where the Company has obtained your consent to process your personal data and sensitive personal data (equal opportunities information, trade union membership, information about criminal convictions and information about your physical or mental health, or disability status) we will do so in line with our retention policy (available upon 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.

6.5    If we cannot find a suitable role for you upon your initial application, we may retain your application data and will contact you in the future of a suitable vacancy arises.  We maintain this information to ensure we offer you suitable roles and will keep such information for as long as necessary to fulfil the purposes we collect it for.  If you do not wish to be contacted in the future in relation to work opportunities please inform us by sending us an email to: londonenquiries@parkwoodhealthcare.co.uk
 

7.       Rights of access, correction, erasure and restriction

7.1    It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your working relationship with us.

7.2    Under certain circumstances, by law you have the right to:

a)   Request access to your personal data (commonly known as a Data Subject Access Request).  This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

b)   Request correction of the personal data that we hold about you.  This enables you to have any incomplete or inaccurate information we hold about you corrected.

c)   Request erasure of your personal data.  This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.  You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing.

d)   Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.  You also have the right to object where we are processing your personal data for direct marketing purposes.

e)   Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.

f)    Request the transfer of your personal data to another party.

7.3    If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact our data protection officer in writing.

7.4    You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

7.5    We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

7.6    In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us as indicated below. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

 

8.       Withdrawal of consent

Where you have consented to the Company processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by contacting:

Mark Lambourne, Managing Director (mark.lambourne@parkwoodhealthcare.co.uk) or

Katie Lupton, Operations Director (katie.lupton@parkwoodhealthcare.co.uk) or

Claire Moffett, Senior Branch Manager (claire.moffett@parkwoodhealthcare.co.uk)


9.       Complaints or queries


If you wish to complain about this privacy notice or any of the procedures set out in it please contact: Mark Lambourne, Managing Director or Katie Lupton, Operations Director or Claire Moffett, Senior Branch Manager. 

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.


10.   Changes to this privacy policy

We reserve the right to update this privacy policy at any time, and we will provide you with the new privacy policy we make any substantial updates.  We may also notify you in other ways from time to time about processing of your personal data. 

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