GDPR Privacy notice for applicants
Privacy notice for Applicants for employment
|Variable data (for internal use only and not to be included in published version)|
|Data Controller’s legal name:||Promedica24 UK Ltd|
|Person Responsible for data protection:||Data Protection Officer|
|Their email address:||email@example.com|
|Their telephone no:||+44 20 331 54759|
|Their physical address:||Cassiobury House, 11-19 Station Road, Watford, WD17 1AP|
|Type of data subject covered:||Applicants for employment|
|Date Created:||31st August 2018|
|Date Amended:||22nd May 2020|
|Created by:||David Charity|
|Due for review date:||1st December 2020|
We must provide individuals with privacy information at the time we collect their personal data from them.
If we obtain personal data from a source other than the individual it relates to, we must provide them with privacy information within a reasonable period of obtaining the personal data and no later than one month.
If we plan to communicate with the individual, we must provide this information at the latest when the first communication takes place. If we plan to disclose the data to someone else, we must provide this information at the latest when the data is disclosed.
This Privacy Notice fulfils requirements under Articles 13 (and where applicable 14) of the GDPR (data obtained directly form the data subject and / or from a third party).
Promedica24 UK 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: firstname.lastname@example.org or by phone: +44 20 331 54759, or by post: Cassiobury House, 11-19 Station Road, Watford, WD17 1AP.
This notice is issued by Promedica24 UK Ltd (the ‘data controller’); it applies only to Applicants for employment. This notice does not form part of any contract between you and Promedica24 UK Ltd.
Please also note that the following entities may act as joint controllers with Promedica24 UK Ltd.
- Promedica24 (Wiltshire) Ltd in Swindon, SN2 8BW, Kembrey Park Pure Offices Suite 50
- Promedica24 (West Midlands) Ltd, in Coventry, CV4 8JA, Westwood Way, Westwood Business Park, Ensign Business Centre, First Floor No 15
- Promedica24 (Lancashire) Ltd, in Rawtenstall, BB4 6HH, New Hall Hey Road, Hardmans Business Centre, Suite 1
This notice applies only in relation to personal data you provide to us via our website (where you wish to be contacted regarding current and future vacancies and to personal data that relates to any application for employment. If you are successful in your application, you should refer to our privacy notice for employees, workers and contractors.
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:
- Application forms / CVs (resumes)
- Availability for work
- Bank details
- Commencement / termination dates
- Conduct or capability related information
- Contractual requirements
- Criminal record checks / details (S)
- Details of recommendation
- Driving licences / details
- Duties and responsibilities
- Employer name
- Employment goals
- Employment type
- Experience, knowledge or understanding
- Home address
- Home telephone
- Job titles
- NI number
- Notice period
- Other benefits
- Pay rate, history or other remuneration
- Personal attributes
- Personal email address
- Personal mobile
- Previous name
- Qualifications and training
- Reason for leaving
- Referees and related information
- Right to work documents
- Work address
- Work email address
- Work mobile
- Work telephone
- Working hours
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.
- Where we have your consent to include you in mailing lists so that we can notify you of current and future vacancies.
6. WHY DO WE PROCESS THIS INFORMATION?
The situations in which we will process your personal information are listed below:
- ARCHIVE – To maintain appropriate historical records
- CARE – To comply with our duty of care and consider adjustments
- CLAIMS – To retain documents that may be relevant to legal claims
- CONTRACT – To generate appropriate contractual documentation
- DUTY – To comply with a duty owed to a 3rd party
- ELIGIBILITY – To ensure staff are entitled to work in the UK
- FRAUD – To prevent and aid the investigation of fraud
- LAWFUL – To ensure our activities are within the law
- PAYROLL – To administer pay, tax, NI and other deductions and allowances
- QUALIFICATION – To ensure staff are suitably skilled and trained
- RECRUITMENT – For the purposes of recruitment
- SAFEGUARDING – To ensure we comply with our duties to protect children and vulnerable adults
- SHARING – To share relevant information with a 3rd party organisation/s who have a right to know it
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?
We usually only collect information for Data Subjects directly.
In the context of employment, we may also have obtained your data from one of the sources below.
- Employment agencies or businesses
- The Disclosure and Barring Service (DBS)
- Former employees or workers who may have recommended you
- Those you gave as referees
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.
You are under no obligation to provide your consent to us including you in mailing lists so that we can notify you of current and future vacancies and you may withdraw your consent to this at any time.
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, and for human resources functions for Care Workers. 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:
- Pension administration
- Benefits provision and administration
- IT services
- Web-based Customer Relationship Management software
- Cloud-based storage
- Outsourced HR
- Data Protection Consultancy
- Legal advisors
- Accountancy services
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
Your data will also be stored by entities operating in the United States of America. These entities have joined the Privacy Shield program, approved by the European Commission, which means that they properly protect personal data.
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 these categories for these periods:
|Employment application documents||6 months from the end of the recruitment process if application unsuccessful and for the duration of employment plus 6 years if successful|
|Names, contact details and copies of resumes for those who wish to be notified of current and future vacancies for Care Workers||For so long as we have your consent|
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
Where you may have provided your consent to the collection, processing and transfer of your personal information so that we can notify you of current and future vacancies, 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 or use the ‘opt out’ link that will be included in all communications notifying you of vacancies. 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.
If you have any concerns or complaints about data protection you should first raise this with us either by email to: email@example.com or by phone: +44 20 331 54759, or by post: Cassiobury House, 11-19 Station Road, Watford, WD17 1AP.
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 for more information.