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GDPR Privacy notice for applicants

1.     INTRODUCTION

Promedica24 (Lancashire) Ltd is committed to protecting the privacy and security of your personal information.  We only collect and use personal data in line with the General Data Protection Regulation, the Data Protection Act and any other applicable laws and regulations.

This Privacy Notice informs you (the ‘data subject’) about our processing activities: the data we hold, why we use it, how long we will retain it for, and other relevant information.

Any questions and requests regarding personal data may be sent to our Data Protection Officer by sending an email to: dataprotection@promedica24.co.uk or by phone: +44 800 086 8686 , or by post: Suite 38, Hardmans Business Centre, New Hall Hey Road, Rawtenstall, BB4 6HH.

2.     APPLICABILITY

This notice is issued by Promedica24 (Lancashire) Ltd (the ‘data controller’); it applies only to Applicants for Employment . This notice does not form part of any contract between you and Promedica24 (Lancashire) Ltd.

Please also note that the following entity may act as joint controller with Promedica24 (Lancashire) Ltd.

  • Promedica24 Plus Ltd, Suite 38, Hardmans Business Centre, New Hall Hey Road, Rawtenstall, BB4 6HH.
  • Promedica24 UK Ltd, Suite 38, Hardmans Business Centre, New Hall Hey Road, Rawtenstall, BB4 6HH.

3.     DATA PROTECTION PRINCIPLES

We ensure any personal data we hold about you is:

  • Use lawfully, fairly and in a transparent way
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
  • Relevant to the purposes we have told you about and limited only to those purposes
  • Accurate and kept up to date
  • Kept only as long as necessary for the purposes we have told you about
  • Kept securely

4.     THE KIND OF INFORMATION WE HOLD ABOUT YOU

Personal data 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).

We collect, store, and use the following categories of personal information about you:

  • Address
  • Appearance and size
  • Attendance and leave records
  • Commencement / termination dates
  • Contractual requirements
  • Correspondence inc. statements of opinion or intent
  • Criminal record checks / details (S)
  • Date of Birth
  • Details of payments or deductions
  • Employer/s name/s
  • Employment benefits (e.g. pension, etc)
  • Employment History
  • Expressions of opinions regarding data subject
  • Financial information
  • Gender
  • ID documents (e.g. passport, driving licence)
  • Location Data
  • Marital status
  • Names
  • Notes biographical in nature
  • Payroll, tax and NICs information
  • Personal contact details
  • Recruitment records
  • Right to work information
  • Photographs / video
  • References
  • Signature
  • Unique identifier number or code
  • Usernames and passwords
  • Work contact details

We may collect, store and use “special categories” of more sensitive personal information in line with our Processing Sensitive Data Policy, these categories are marked (S) in the list above.  Special categories of personal data are more sensitive personal data which require a higher level of protection.

5.     WHAT LEGAL BASES DO WE RELY ON?

We use the types of personal data above on the following legal bases:

  • When we need to comply with our legal obligations.
  • 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.
  • Consent

We only collect, store and use sensitive personal information (marked (S) in the list above) when: where processing is necessary in the field of employment, or where necessary in relation to a legal claim, or where necessary to assess working capacity.

6.     WHY DO WE PROCESS THIS INFORMATION?

The situations in which we will process your personal information are listed below:

  • ANALYSIS – To undertake data analytics for internal staff management or external service management purposes
  • ARCHIVE – To maintain appropriate historical records
  • AUDIT – To retain information that may be relevant to an audit
  • CARE – To comply with our duty of care and consider adjustments
  • CONTRACT – To generate appropriate contractual documentation
  • HUMAN RESOURCES – To process personnel matters including appraisal, professional development, fitness for work, disciplinary, contract termination, promotion, and pay review
  • IT – To restrict network access and to monitor and manage the use of our systems LAWFUL – To ensure our activities are within the law
  • MANAGEMENT – To effectively manage our staff, their activities, and our tangible assets
  • PLANNING – To plan accounting and internal resource allocation
  • RECRUITMENT – For the purposes of recruitment
  • REGULATOR – To comply with a requirement of our regulator
  • PAYROLL – To administer pay, tax, NI, and other deductions and allowances
  • SERVICE DELIVERY – To provide our services to clients

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

We will only use your personal information for the purposes 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 information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

7.     WHERE DID WE COLLECT THIS DATA FROM?

In relation to employees, workers and contractors, we may also have obtained personal data from one or more of the following:

  • Employment agencies or businesses
  • The Disclosure and Barring Service (DBS)
  • The Home Office
  • Former employees or workers who may have recommended you
  • Those you gave as referees
  • Service users and clients
  • Other care and health professionals
  • Our data processors

We will also collect some of the information in the categories above in the course of your employment.

8.     ARE YOU UNDER ANY OBLIGATION TO PROVIDE THE PERSONAL DATA?

Where we process Personal Data to comply with our legal obligations you must provide this information.

If you fail to provide certain information when requested we may be prevented from: performing the contract we have entered into with you, complying with our legal obligations, or achieving our legitimate interests.

9.     WHO DO WE SHARE THIS INFORMATION WITH?

We will share your personal information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data.  Group entities are required to take appropriate security measures to protect your personal information in line with our policies.

 

We use some third-party service providers (the ‘processors’) who process data for us under strict instructions and under a binding contract with us. Our processors provide the following services:

  • Web-based Customer Relationship Management software
  • Cloud-based storage
  • Outsourced HR
  • Data Protection Consultancy
  • Legal advisors

Processors are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our processors to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

10. TRANSFERS TO OTHER COUNTRIES OR TO INTERNATIONAL ORGANISATIONS

We transfer your personal information to entities in our group in the EU and we may also transfer this information outside the EU.  If we do, you can expect a similar degree of protection in respect of your personal information as in the UK and the EU.

11. WILL THE INFORMATION BE USED FOR AUTOMATED DECISION MAKING OR PROFILING?

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

12. HOW LONG DO WE KEEP THIS INFORMATION?

We retain personal data in for 6 years in line with the Limitation Act 1980 except in the cases below, where we are obligated to retain records for longer than this:

  • Health surveillance cases where the Control of Substances Hazardous to Health Regulations 2002 require us to retain records for a minimum of 40 years
  • Health and social care records where the Records Management Code of Practice for Health and Social Care 2021 requires us to retain records for a minimum of 8 years.

To ensure that we do not prematurely delete records, and for administration purposes, we add a ‘buffer’ period of 1 year to the retention periods above.

Where the data asset entry in which the personal data is stored relates solely to a data subject with whom we have a contract the retention period runs from the end of the contract.  Otherwise the retention period runs from the date of the entry or the last entry in the data asset in question.

13. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the recruitment process.

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

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information 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 information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

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

You will not have to pay a fee to access your personal information (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.

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 information is not disclosed to any person who has no right to receive it.

14. Right to Withdraw Consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please notify us on the email address above.  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.

15.     COMPLAINTS

If you have any concerns or complaints about data protection you should first raise this with us either by email to: dataprotection@promedica24.co.uk or by phone: +44 800 086 8686 , or by post: Suite 38, Hardmans Business Centre, New Hall Hey Road, Rawtenstall, BB4 6HH.

If you have a complaint or concern that has not been remedied internally, you may choose to raise this with the Information Commissioner’s Officer (ICO).  Visit www.ico.org.uk for more information.

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