Recruitment Privacy Statement

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.

Data we may hold, could include:-

Personal data

  • Personal contact details such as name, title, addresses, telephone numbers and personal email addresses
  • Date of birth
  • Gender
  • Marital Status
  • National Insurance Number
  • GMC/NMC Number
  • Payroll Information e.g. bank account number etc.
  • Experience, training and qualifications
  • Employment Records (including job titles, work history, working hours, training records and professional memberships)
  • Right to work documentation e.g. passport, work permits etc.
  • Disciplinary and grievance information
  • Sensitive personal data

  • Disability/health condition relevant to the role
  • Criminal conviction/Regulatory Body Restrictions
  • Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions

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 the terms of the following statement.

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.

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.Recruitment Privacy Statement – Version 001May-18

The legal bases we rely upon to offer these 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
  • To fulfil a contractual obligation that we have in relation to work carried out for the NHS, or other client agreements ie NHS Frameworks
  • b. Legitimate interest

    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. Our legitimate interests are as follows:

  • Managing our database and keeping work-seeker records up to date;
  • Providing work-finding services, including sending your information to our clients where you have demonstrated an interest in doing that particular type of work but not expressly consented to the company passing on your CV.

c. Recipient/s of data

The Company will process your personal data and/or sensitive personal data with the following recipients:

  • Clients that the company introduce you to or supply e.g. NHS & Private hospitals or Care Homes
  • Candidates’ former employers/places of work in order to obtain or provide references
  • The Recruitment and Employment Confederation
  • Any third parties who carry out audits to ensure that the company run s its business correctly or line with contracts and legal requirements e.g. The company’s accountants and NHS Frameworks
  • Any umbrella companies that you may appoint to handle your payments
  • Other recruitment agencies in the supply chain (e.g. master/neutral vendors and second tier suppliers);
  • The company’s insurers
  • The company’s legal advisers
  • The company’s IT and CRM providers
  • Any public information sources and third party organisations that the company may use to carry out suitability checks e.g. Companies House, the Disclosure and Barring Service (DBS), National College for Teaching and Leadership (NCTL), Nursing and Midwifery Council (NMC), General Medical Council (GMC)

d. Statutory/contractual requirement

Your personal data is required by law and/or a contractual requirement (e.g. our client may require this personal data), and/or a requirement necessary to enter into a contract. You are obliged to provide the personal data and if you do not the consequences of failure to provide the data are:

  • The company will not be able to meet statutory obligations, such as the Conduct of Employment Agencies and Employment Businesses Regulations 2003 – for example, check

Recruitment Privacy Statement – Version 001May-18

identity, right to work, suitability for the role, qualifications and experience. In this case we will not be able to introduce you or supply you to a client.

2. Overseas Transfers

We may transfer the personal information we collect about you outside the EU in order to perform our contract with you. We use a secure server and database which covers our email and file storage systems.

3. Data retention

The Company will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time.

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.

We must also keep your payroll records, holiday pay, sick pay and pension’s auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation.

Where the Company has obtained your consent to process your personal and sensitive personal data, we will do so in line with our retention policy, which requires all accounting; payroll; personnel; training records; detailed company transactions (including supporting documents) to be retained for 6 complete years. 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.

4. 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 the company and requesting a withdrawal of Consent Form.

There may be circumstances where the Company will still need to process your data for legal or official reasons. We will inform you if this is the case. Where this is the case, we will restrict the data to only what is necessary for the purpose of meeting those specific reasons.Recruitment Privacy Statement – Version 001May-18

If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us and we will take reasonable steps to check its accuracy and correct it where necessary.

You can also contact us 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.

5.Complaints or queries

If you have any questions about this recruitment privacy statement or any of the procedures set out in it please contact: Mr Altin Biba at ProMedical Personnel Ltd, The Granary, 4-6 Crescent Road, Brentwood, Essex CM14 5JR.

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.