This Privacy Notice sets out the basis on which Concept Care Solutions will process personal information provided to us, this information is also referred to as ‘personal data’.
We take our obligations in respect of the privacy of personal data very seriously and we will only process personal information as detailed in this notice, unless we inform you otherwise. In order to ensure that the personal data we hold is accurate and up to date, we request that you inform us of any relevant changes to the personal information we hold about you.
We help individuals to find work and we are also an employer. Our core business activity is recruitment, we assist individuals in finding work with our hirer clients, whether this is directly or through supply by us, and we assist hirers in introducing or supplying the staff that they require. We also recruit staff to work for us to provide our recruitment services. For the purposes of this Privacy Notice, our commercial activities and services for individuals and businesses are referred to as ‘Recruitment Services’, and our actual or potential hiring customers are referred to as ‘Clients’.
Data Compliance Officer is our NHS Operations Director and can be contacted on 0208 731 5972.
If you do not wish us to process personal data in accordance with this policy, then please do not provide it to us, Please refer to Section 4 ’Your rights‘, in respect of data that we already hold, or which we receive from third parties.
Section 1: This section applies to individuals wishing to use or using our Recruitment Services or looking for a role to work with us, known as (‘the Candidate’)
The personal data we collect or receive includes the following as applicable:
- Name
- Address
- Email and other contact details
- Date of birth
- Job history (including information relating to placements through us)
- Educational history, qualifications and skills
- Visa and other rights to work or identity information
- Passport
- Bank details
- National insurance and tax (payroll) information
- Next of kin and family details
- Contact details of referees
- Personal information relating to hobbies, interests
- and pastimes
- The information contained in references and pre-employment checks from third parties
- Other sensitive personal information such as health records (see ‘Sensitive Personal Data’ section below)
Your marketing preferences
We may obtain your personal data from the following sources (please note that this list is not exhaustive):
- You (e.g. a Curriculum Vitae, application or registration form)
- A client
- Other candidates
- Online jobsites
- Marketing databases
- The public domain
- Social Media
- At interview
- Conversations on the telephone or video conferencing (which may be recorded)
- Notes following a conversation or meeting
- Our websites and software applications
Where you are a Candidate and we have obtained your personal data from a third party such as an online job board, it is our policy to advise you of the source when we first communicate with you.
How we will use your personal data:
- The processing of your personal information may include:
- Collecting and storing your personal data, whether in manual or electronic files
- Notifying you of potential roles or opportunities
- Assessing and reviewing your suitability for job roles
- Introducing and/or supplying you to actual or
- potential Clients
- Engaging you for a role with us or with our Clients including any related administration e.g. timesheets and payroll
- Collating market or sector specific information and providing the same to our Clients
- Sending information to third parties with whom we have or intend to enter into arrangements which are related to our Recruitment Services
- Providing information to regulatory authorities or statutory bodies, and our legal or other professional advisers
- including insurers
- To market our Recruitment Services
- Retaining a record of our dealings
- Establishing quality, training and compliance with our obligations and best practice
- For the purposes of backing up information on our computer systems
Why we process your personal data:
- Entering into and performing a contract with you:
In order to provide our Recruitment Services, we may enter into a contract with you and/or a third party. In order to enter into a contract we will need certain information, for example your name and address. A contract will also contain obligations on both your part and our part and we shall process your data as is necessary for the purpose of those obligations. For example, in order to process payroll, a national insurance number and bank details will
be required.
- Compliance with legal obligations (regulatory and statutory obligations):
We must comply with a number of statutory provisions when providing our Recruitment Services, which necessitate the processing of personal data. These include the Conduct of Employment Agencies and Employment Businesses Regulations 2003, which amongst other things require us to:
- Verify your identity
- Assess your suitability for an external job role
- Maintain records for specific periods
Where we engage a person to work for us (whether directly or as supplied to a Client), there are other statutory obligations that must be complied with including payroll, tax, social security, HMRC reporting requirements, and any other law or regulation.
We are also required to comply with statutory and regulatory obligations relating to business generally, for example complying with tax, bribery, fraud/crime prevention and data protection legislation, and co-operating with regulatory authorities such as HMRC or the Information Commissioner’s Office.
- Our legitimate interests (carrying on the commercial activity of Recruitment Services):
In providing our Recruitment Services, we will carry out some processing of personal data which is necessary for the purpose of our legitimate interests, which include:
- Retaining records of our dealings and transactions and where applicable, use such records for the purpose of:
- Establishing compliance with contractual obligations with Clients or suppliers
- Addressing any query or dispute that may arise including establishing, exercising or defending any legal claims
- Protecting our reputation
- Maintaining a back up of our system, solely for the purpose of being able to restore the system to a particular point in the event of a system failure or security breach
- Evaluating quality and compliance including compliance with this Privacy Notice
- Determining staff training and system requirements
Using your personal data to:
- assess suitability and contact you regarding potential opportunities and/or our services
- collate market information or trends including providing analysis to potential or actual Clients
- source potential opportunities or roles as part of our Recruitment Services
- personalise your experience and our offering, whether via our website or otherwise
This means that for our commercial viability and to pursue these legitimate interests, we may continue to process your personal data for as long as we consider necessary for these purposes.
- Consent to our processing of your data:
We may process your personal data on the basis that you have consented to us doing so for a specific purpose, for example, if you apply for a specific role you may have consented to our processing of the data that has been provided for the purpose of progressing your application and considering your suitability for that role. In other cases, you may have provided your written or verbal consent to the use of your data for a specific reason.
You may withdraw your consent to our processing of your personal information for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations. Withdrawal of consent will not have any effect on the lawfulness of any processing based on consent before its withdrawal.
What if we obtain your personal data from a third party?
Part of our business activity involves researching information relating to individuals for the purposes of filling job roles. This may include obtaining personal data from online sources, for example, we may obtain information from social media sites such as LinkedIn and job boards, some information being publicly available but others being from sites or providers to which we subscribe. From time to time we may also receive personal information about you from hiring organisations, colleagues and former employers, or from persons for whom you have provided services or been otherwise engaged.
Where information from third party sources is of no use to us, or where you have notified us that you do not want us to provide you with services, we shall discard it, however, we may maintain a limited record in order to avoid the duplication of process. Where we consider that information may be of use to us in pursuance of the provision of our Recruitment Services, any processing will be in accordance with this Privacy Notice. You do have the right to object to processing, please see Section 4 ‘Your rights’.
Sensitive Personal Data (SPD)
Sensitive personal data is information which is intensely personal to you and is usually irrelevant to our consideration of your suitability for a job role. Examples of SPD include information which reveals your political, religious or philosophical beliefs, sexual orientation, race or ethnic origin, or information relating to your health.
Regardless of the basis for your dealings with us, we request that you do not provide us with any sensitive personal data unless absolutely necessary. However, to the extent that you do provide us with any sensitive personal data, such as data which you choose to share with us in conversation, we shall only use that data for the purposes of our relationship with you or for the provision of our Recruitment Services. This will be for one or more of the following reasons:
- You have explicitly consented to the processing
- For the purpose of our assessment of your suitability for job roles or working capacity
- Where processing is necessary for the purpose of obligations or rights under employment, social security or social protection law
- To maintain records of our dealings to address any later dispute, including but not limited to the establishment, exercise or defence of any legal claims
Whom, we share personal data with:
We shall not share your personal information unless we are entitled to do so. The categories of persons with whom we may share your personal information include:
- Individuals, hirers and other third parties necessary for the provision of our Recruitment Services
- Any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us
Parties who process data on our behalf, which may include:
- outsourced timesheet processors
- IT support
- storage service providers including cloud
- occupational health providers
- criminal record checks
- training providers
- Legal and professional advisers
- Insurers
Automated decisions:
We use software to review the personal data of individuals recorded on our database, or who have applied for specific roles. The software may determine suitability for a specific role via targeted questions relating to the role, and/or may identify and select individual personal information according to the stored characteristics. For example, the software may enable us to quickly identify individuals from our database who have specific skills, e.g. a medical locum and exclude individuals whose characteristics do not match particular requirements of the job role.
Where we use software to assist us with our assessment of your suitability for a particular job role and you consider that any such assessment has been made wrongly or incorrectly, you may ask for an explanation.
Data Security and Confidentiality:
It is our policy to ensure, in so far as is reasonably practicable, that our systems and records are secure and not accessible to unauthorised third parties in line with contemporary practice.
Cookies:
A cookie is a small file of letters and numbers that are downloaded on to your computer when you visit a website, which enables the website to tailor its offerings to your preferences when you visit it.
We use cookies in the following ways:
- Identify individual clients behind a shared IP address and apply security settings on a per-client basis
- Keep track of the number of times a visitor has been to the site and the activity carried out
- Gather website statistics and track conversion rates
- Measure the number and behaviours of Google Map users
- Tracking by Google i.e. track certain websites that use Google plug-ins
A simple message that applies to submitted forms i.e. if an enquiry form is completed incorrectly, a message will be stored and presented to the user to indicate the errors in the submission, or if a form is submitted successfully, a message is stored and presented to the user thanking them for
their enquiry
Retaining your data:
In most circumstances, your data will not be retained for more than six (6) years from the last point at which we provided any services or otherwise engaged with you. It is our policy to only store your personal data for as long as is reasonably necessary for us to comply with our legal obligations and for our legitimate business interests. However, we may retain data for longer than a six (6) year period where we have a legal or contractual obligation to do so, or we form the view that there is otherwise a continued basis to do so, for example, where your personal information identifies specialist skill sets which may remain in demand, or we are subject to a legal obligation which applies for a longer period.
If however, you believe that we should delete your personal data at an earlier date, please inform us in writing of your reasons. Please see Section 4 ‘Your Rights’ below.
Changes to this Privacy Notice:
This Privacy Notice is regularly reviewed and may be updated from time to time to reflect changes in our business or legal or commercial practice. Where an update is relevant to our processing of your data, we shall notify you of the same.
Section 4: Your rights
We take the protection of your personal data very seriously and it is important that you know your rights within that context, which include rights to:
Request a copy of the personal data that we hold
Object to our processing of your data where that processing is based upon legitimate interest and there are no compelling grounds for the continued processing of that data
Request that we restrict processing of your data in
certain circumstances
Request that data is erased where the continued use of that data cannot be justified
Object to any decision, which significantly affects you, being taken solely by a computer or via another
automated process
Withdraw your consent to our processing of your personal data for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations
Request that inaccurate or incomplete data is rectified
Request that data provided directly by you and processed by automated means is transferred to you or another controller; this right only being applicable where our processing of your data is based either on your consent or in performance of a contract
Make a complaint to the Information Commissioner’s Office Request that direct marketing by us to you is stopped
Please note that should you exercise your right to request that we erase data or cease any processing activity, we may retain a record of this request and the action taken in order to both evidence our compliance, and to take steps to minimise the prospect of any data being processed in the future should it be received again from a third party source.
If you have any questions concerning your rights or should you wish to exercise any of these rights please contact our NHS Operations Director on 0208 731 5972
Complaints
If you are dissatisfied about any aspect of the way in which your data is processed you may, in the first instance refer the matter to our NHS Operations Director. This does not affect your right to make a complaint to the Information Commissioner’s Office.
You can contact the Information Commissioner’s Office on:
Head office
Tel: 0303 123 1113 or 01625545745
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
