Privacy Policy
Company Name: | Clinical Employment Services Ltd T/A CES Locums (‘the Company’) |
Company Contact details: | Quality Assurance Manager 020 8204 3131 |
Document DP5 | Privacy Notice (including for use on the company website) |
Topic: | Data protection |
Date: | May 2018 |
Version: | DP5/CES/2018.2 |
CES Locums‘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.
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. 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 this privacy statement. At all times we will comply with current data protection laws.
1. Collection and use of personal data
a. Purpose of processing and legal basis
The Company will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with work-finding services. This includes for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, arranging payments to you and developing and managing our services and relationship with you and our clients.
If you have opted-in we may also send you job alerts and news via email/ text. You can opt-out from receiving these at any time by clicking “unsubscribe” or reply “STOP” when you receive these communications from us.
In some cases we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.
We must have a legal basis to process your personal data. The legal bases we rely upon to offer our work-finding services to you are:
∙ Your consent
∙ Where we have a legitimate interest
∙ To comply with a legal obligation that we have
∙ To fulfil a contractual obligation that we have with you
∙ Where you are an individual working for a third party with whom we have dealings. For example, a client or a payroll company
b. Legitimate interest
This is where the Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:
∙ Managing our database and keeping work-seeker records up to date;
∙ Providing work-finding services to you and our clients;
∙ Contacting you to seek your consent where we need it;
∙ Giving you information about similar products or services that you have used from us recently;
c. Statutory/contractual requirement
The Company has certain legal and contractual requirements to collect personal data (e.g. to comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003, immigration and tax legislation, and in some circumstances safeguarding requirements.) Our clients may also require this personal data, and/or we may need your data to enter into a contract with you. If you do not give us personal data we need to collect we may not be able to continue to provide work
finding services to you.
d. Recipient/s of data
The Company will process your personal data and/or sensitive personal data with the following recipients:
∙ Clients (whom we may introduce or supply you to)
∙ Former employers whom we may seek references from
∙ Payroll service providers who manage payroll on our behalf or other payment intermediaries whom we may introduce you to
∙ Other recruitment agencies in the supply chain
2. Information to be provided when data collected not from the data subject Categories of data:
The Company has collected the following personal data on you: Personal data: not an exhaustive list
∙ 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 right 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
∙ 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
Sensitive personal data: not an exhaustive list
∙ Health information including whether you have a disability
∙ Criminal conviction
Source of the personal data: The Company sourced your personal data/sensitive personal data: not an exhaustive list
∙ 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.
3. Overseas Transfers
The Company will not transfer the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.
4. Data retention
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.
5. Your rights
Please be aware that you have the following data protection rights:
∙ The right to be informed about the personal data the Company processes on you; ∙ The right of access to the personal data the Company processes on you;
∙ The right to rectification of your personal data;
∙ The right to erasure of your personal data in certain circumstances;
∙ The right to restrict processing of your personal data;
∙ The right to data portability in certain circumstances;
∙ The right to object to the processing of your personal data that was based on a public or legitimate interest;
∙ The right not to be subjected to automated decision making and profiling; and ∙ The right to withdraw consent at any time.
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 our quality assurance manager Reem Khafaji on 020 8204 3131 or [email protected]. Please note that if you withdraw your consent to further processing that does not affect any processing done prior to the withdrawal of that consent, or which is done according to another legal basis.
There may be circumstances where the Company will still need to process your data for legal or official reasons. Where this is the case, we will tell you and we will restrict the data to only what is necessary for those specific reasons.
If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.
You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.
6. Cookies
A cookie is a small file of letters and numbers that is 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 ∙ 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
7. Log Files
We use IP addresses to analyse trends, administer the site, track users’ movements, and to gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.
8. Links to external websites
The Company’s website may contains links to other external websites. Please be aware that the Company is not responsible for the privacy practices of such other sites. When you leave our site we encourage you to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by the Company’s website.
9. Sale of business
If the Company’s business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.
10. Data Security
The Company takes every precaution to protect our users’ information.
Only employees who need the information to perform a specific job (for example, consultants, our accounts clerk or a marketing assistant) are granted access to your information.
The Company uses all reasonable efforts to safeguard your personal information. However, you should be aware that the use of email/ the Internet is not entirely secure and for this reason the Company cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email/ the Internet.
If you share a device with others we recommend that you do not select the “remember my details” function when that option is offered.
11.Changes to this privacy statement
We will update this privacy statement from time to time. We will post any changes on the statement with revision dates. If we make any material changes, we will notify you.
12.Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact: The Director, 020 8204 3131 or [email protected]
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.
