Privacy Notice

 

Company Name:
Globe Locums Limited T/A Globe Workforce Solutions (‘the Company’)

Company Contact details:
Data Protection Officer
dataprotection@globeworkforcesolutions.co.uk
Thavies Inn House, 3-4 Holborn Circus, London, EC1N 2HA

Document DP5:
Privacy Notice (including for use on the company website)

Topic:
Data Protection

Date:
30.5.2022

Version:
GL006GWS.A3.V1

Introduction

Globe Workforce Solutions is a provider of insourced services to support the provision of healthcare, including clinical insourcing and engages third parties for the provision of recruitment services who act as either a recruitment business or recruitment agency as defined under The Conduct of Employment Agencies and Employment Business Regulations 2003 who provide work-finding services to clients and work-seekers.

We must process personal data including sensitive personal data so we can provide insourcing services – in doing so, we act as a data controller.

At all times we are committed to protecting and safeguarding the privacy and security of personal information and complying with current data protection laws.

This policy should be read together with our Cookie Policy available on our website.

1.           Collection and use of personal data

a.      Purpose of processing

As a candidate or prospect candidate we 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, in doing so, we act as a data controller.

Work-finding services include 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.

The greater the information we have about you regards your skills, expertise, qualifications, type of work you are seeking, work preferences, the better placed we are to provide our service to you.

As a candidate if you have opted-in we may also send you marketing information and news via email/text.  You can opt-out from receiving these at any time by clicking “unsubscribe” when you receive these communications from us and/or requesting this by emailing dataprotection@globeworkforcesolutions.co.uk.

As a client or prospect client we may need to collect personal data about you or individuals at your organisation in the course of providing insourced services to you.

As a supplier we need contact details of relevant individuals at your organisation so we can communicate with you and ensure contractual arrangements between us can be properly implemented.

We may also collect third party data, such as emergency contacts and referees. We use referees’ personal data to help our candidates find suitable work best matched to their skills, qualifications, experience and preferences. We may also use referees’ personal data to contact them in relation to recruitment activities that may be of interest. We use nominated emergency personal contacts of a candidate or employee in the event of an accident or emergency affecting that individual.

Please note that should you decline to provide us with personal data and depending on the grounds on which we may be processing it, we may not be able to fulfil our contractual requirements or potentially continue to provide services to you. 

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.

Legal basis for processing your data

We must have a legal basis to process your personal data. The legal bases we rely on as 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

b.     Legitimate interest

This is where we have a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us.  Where we have relied on a legitimate interest to process your personal data our legitimate interests are as follows:

  • Managing our database and keeping work-seeker records up to date

  • Providing insourcing services to our clients

  • Providing work-finding services to candidates

  • 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 as part of our insourcing solutions.

d.     Recipients of data – who your data may be data shared with

We may process your personal data and/or sensitive personal data with the following recipients:

  • Clients (whom we may introduce or supply you to) e.g. NHS Hospitals and Trusts, Private Healthcare Providers, Health Sector Frameworks

  • Former employers whom we may seek references from

  • Any third parties who carry out audits to ensure operational compliance

  • Payroll service providers who manage payroll on our behalf or other payment intermediaries whom we may introduce you to

  • Any umbrella companies that we pass your data to, for payroll purposes

  • Pension providers

  • Other recruitment agencies in the supply chain e.g. master/neutral vendors and second tier suppliers

  • Thirty party suppliers and outsourced service providers in supply chain, IMS and QX, supporting the delivery of services, business operations and functions

  • Public information sources and third party organisations – the Disclosure and Barring Service (DBS), Disclosure Scotland, Nursing and Midwifery Council (NMC), General Medical Council (GMC) and other professional bodies

  • Training and immunisation providers to enable ‘fitness to work’ certificates and compliance

  • Recruitment and Employment Confederation (REC)

  • Government, law enforcement agencies and other regulators e.g. the Police, Home Office, HMRC, Employment Agencies Standards Inspectorate (EASI)

  • Any group companies

  • Our insurers and legal advisers

  • Providers of web analytics services, marketing automation platforms and social media services to ensure any advertising you receive is targeted to you.

2.    Categories of data

We may collect the following personal data on you:

Personal data:

  • Contact information – name, postal address, telephone/mobile number, email address

  • CV – education, experience, employment, qualification, training history

  • Language proficiencies and other work related skills

  • Professional registration checks/records

  • Information on your interests and needs regards future work opportunities

  • Nationality/citizenship/place of birth (through right to work check)

  • Immigration status

  • Photograph

  • Social Security / National insurance number

  • Bank account information

  • Tax related information

  • Details about your current remuneration, pensions or benefits arrangements

  • Credit checks

  • Information you choose to tell us

  • Information your referees choose to tell us about you

  • Information that our clients may tell us about you or that we find from other third party sources such as job sites or professional networking sites

  • Referee details

  • Emergency contact details

  • Telephone recordings

  • Internet Protocol address

  • Dates, times and frequency with which you access our services

  • CCTV footage if you attend our premises

Sensitive personal data:

  • Date of birth

  • Gender

  • Marital status

  • Health information including whether you have a disability

  • Criminal convictions and cautions, if required for a role you are interested in applying for

  • Immunisation history

  • Special categories of data such as information about ethnic origin, sexual orientation or religion or belief in order to monitor diversity  

 Source of the personal data

We may source personal data/sensitive personal data by the following means:

  • From yourself directly either through our website, advertisements on third party sites, application or registration form, CV, email or telephone communications

  • From jobs boards, where you have provided your personal information

  • From a publically accessible source such as social media including but not limited to Facebook and LinkedIn

  • From third parties and colleagues who have shared your data with us e.g. former employer or referral

  • Cookies listed in our Cookie Policy 

 Some information may come from a publically accessible source.

3.     Overseas Transfers

We may 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. We will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.

Should we transfer personal information from within the EEA to countries outside of the EEA, the transfer takes place on the basis of adequacy decision by the European Commission or in the absence of any adequacy decision other legally permitted grounds for example:

  • Legally binding and enforceable instrument between public authorities or bodies

  • Binding corporate rules

  • Standard contractual clauses (‘SCCs’ or ‘Model Clauses’) adopted by the Commission

  • An approved code of conduct

  • Certification under an approved certification scheme

  • Contractual clauses authorised by the ICO

 If you would like more information about the methods used to transfer your personal data outside of the EEA, please contact us at dataprotection@globeworkforcesolutions.co.uk.

 

4.           Data retention

We 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.

As a candidate, if we have not had ‘meaningful contact’ with you for a period of over two years, we will delete your personal data from our systems unless we believe in good faith that the law or other regulations require us to preserve it, for example due to our obligations to tax authorities or in connection with any anticipated litigation.

For candidates whose services are provided via a third party company or other entity, ‘meaningful contact’ means meaningful contact with the company or entity which supplies your services.

By ‘meaningful contact’ we refer to communication between us, either electronic, verbal or written, where you are actively engaging with our services. If you are a candidate we will consider there to be meaningful contact with you if you submit your updated CV, communicate with us about potential roles, update us on your work preferences either by verbal or written communication or click through from any of our marketing communications. Your receipt, opening or reading of an email or other digital message from us will not count as meaningful contact, this will only count if you click-through or reply directly.

As a candidate, if there has been no contact whatsoever, we will delete your data after six months. 

As a candidate, if you have been deployed for work by Globe Locums, to comply with Framework Agreements we are required to keep secure and maintain records for six years, therefore we will retain your records for six years after the date last worked and/or two years after meaningful contact, whichever is the later.

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 pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation.

Where we have obtained your consent to process your personal and sensitive personal data, we will do so in line with our retention policy. Upon expiry of that period we will seek further consent from you. Where consent is not granted we will cease to process your personal data and sensitive personal data.

 5.      Your rights as a Data Subject

Please be aware that you have the following data protection rights:

  • The right to be informed about the personal data we process on you

  • The right of access to the personal data we process 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

  • The right to withdraw consent at any time.

For further information please review on our Data Protection Policy and/or to exercise any of your rights please contact the Data Protection Team at dataprotection@globeworkforcesolutions.co.uk.

6.           Automated decision-making  

We do not use automated decision-making, including profiling.

7.           Cookies  

We may obtain data about you from cookies.  These are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies also enable us to deliver more personalised content. For more information, please read our Cookie Policy.

8.           Log Files

We use Internet Protocol (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.

9.           Links to external websites

Our website may contains links to other external websites. Please be aware that we are 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 our website. 

10.        Sale of business

If the Company 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.

11.        Data Security

We takes every precaution to protect our users’ information, through a number of measures including:

  • Appropriate IT hardware and software implementation such as firewalls, antivirus and filtering measures

  • Controlled access to our systems through appropriate passwords and physical restrictions

Only employees who need the information to perform a specific job (for example, consultants, compliance or accounts personnel) are granted access to your information as appropriate.

We use 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 we 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.

If you have any questions about the security at our website, please email the Data Protection Team at dataprotection@globeworkforcesolutions.co.uk.

12.         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. This Privacy Notice was last updated 30th May 2022.

13.         Complaints or queries

If you wish to complain about this privacy notice or any of the procedures set out in it please contact the Data Protection Team at dataprotection@globeworkforcesolutions.co.uk.

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.