|COMPANY NAME||TEMPLARS MEDICAL AGENCY (UK) LTD (Templars Medical)|
|COMPANY CONTACT DETAILS||DATA PROTECTION LEAD: ANDREA THORNTONAndrea.email@example.com
DATA PROTECTION OFFICER
1 – COLLECTION AND USE OF PERSONAL DATA
a – Purpose of processing and legal basis
Templars Medical 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 job opportunities, updating our database, 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.
Templars Medical 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 to collect and process your personal data,
- Collecting and processing your personal data for the purpose of providing you with work-finding services,
- Processing and retaining your personal data is necessary for compliance with the legal obligations Templars Medical is subject to. The legal obligations are set out below:
i – The Conduct of Employment Agencies and Employment Businesses Regulations 2003 requires us to retain records for least one year after their creation and at a least one year after the date on which we last provided work-finding services.
ii – Payroll records, holiday pay, sick pay and pensions auto-enrolment records will be retained for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation.
- Processing your personal data is necessary to secure work for you in line with the requirements of a contract to which you enter and is necessary for the performance of a contract.
b -Legitimate interest
By instructing Templars Medical to look for work for you and providing us with your personal data you will be giving your consent to processing your data for work-finding purposes. It is in the legitimate interest of you, Templars Medical and clients of Templars Medical to process your personal data to undertake the mandatory pre- and post-employment checks required to secure you work.
Where Templars Medical has 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 work-finding services to you and our clients
c – Statutory and contractual requirements
Templars Medical 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 provide the required personal data we need to collect it is unlikely we will be able to provide work-finding services to you.
d – Recipient/s of data
Templars Medical will process your personal data (which may include sensitive personal data) with the following recipients;
- Clients (including their preferred job/salary payment management portals) for securing you work and payment for services provided,
- Other recruitment agencies in the supply chain,
- Supply contracts and clients to report on the work completed by candidates under each contract (if applicable),
- Auditors as instructed by our clients or under the obligations of our supply contracts, when an audit is undertaken where we have secured work for you,
- Former employers where we may request references,
- Occupational Health service providers to obtain a certificate of fitness for work,
- Mandatory training providers to enable you to undertake any mandatory training requirements as required,
- Payroll service providers who manage payroll on our behalf or other payment intermediaries and pension provider whom we may introduce you to,
- Service providers who validate your passport and/or right to work in the UK and undertake criminal records checks,
- General Medical Council to confirm your licence to practise as a doctor in the UK,
- The Recruitment and Employment Confederation (REC),
- IT and CRM providers.
e – Sharing data with third parties
Where we process your data with third parties Templars Medical has undertaken the relevant steps to ensure your data is adequately protected by having the relevant agreements in place. For information on the third parties we work with contact firstname.lastname@example.org.
2 – PERSONAL DATA WE COLLECT
Templars Medical may collect the following personal data from you:
a – Personal data
- Full name, date of birth, gender, nationality, next of kin details,
- Contact details, including but not limited to telephone number/s, email address, skype address and postal address,
- CV, employment history, training, qualifications,
- Passport and/or right to work, proof of identity,
- Bank details and national insurance number,
- Professional body registration and professional indemnity information,
- Information required to process a criminal record check, including fitness to practise information,
- Information required to process occupational health clearance and a fitness to work certificate,
- All other personal data not listed above provided to complete the mandatory pre-employment checks which enables Templars Medical to provide work finding services.
b – Sensitive personal data
- Disability/health conditions relevant to the role,
- Criminal allegations and convictions,
- Fitness to practise declarations.
c – Source of the personal data
You may give your personal details to Templars Medical by the following methods:
- By email, mail, telephone, social media, via our website or by visiting our office,
- On a registration form, occupational health medical questionnaire, criminal records check application form,
- From a job advert we have placed on a jobs board or by accessing a CV database.
3 – OVERSEAS TRANSFERS
Templars Medical will only transfer the information you provide to us to countries within and outside of the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services with your permission. 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.
4 – DATA RETENTION
Templars Medical will retain your personal data (which may include sensitive personal data) only for as long as is necessary.
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 (a) from the date of their creation or (b) after the date on which we last provide you with work-finding services.
We must also keep 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. This is currently 3 to 6 years.
Contractual obligations with supply frameworks require us to retain personal data for a period of 7 years from the expiry or termination of the relevant contract agreement for contractual monitoring and audit purposes.
Where Templars Medical has obtained your consent to process your personal data (which may include sensitive personal data) we will do so in line with our Record Retention Policy. Upon expiry of the retention period Templars Medical will seek further consent from you. Where consent is not granted we will cease to process your data. You can request a copy of the Record Retention Policy by emailing email@example.com.
5 – YOUR RIGHTS
Templars Medical is required to ensure you are aware you have the following data protection rights:
- The right to be informed about the personal data Templars Medical processes on you;
- The right of access to the personal data Templars Medical 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 Templars Medical processing your personal data (including sensitive personal data) you have the right to withdraw this consent at any time by contacting firstname.lastname@example.org. Note, that if you withdraw your consent to further processing this does not affect any processing done prior to the withdrawal of your consent. There may be circumstances where Templars Medical 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 any of your data which Templars Medical has processed is incorrect or incomplete, contact email@example.com 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.
6 – COOKIES
Templars Medical may obtain data about you from cookies. Cookies are small text files which are placed on your computer by websites you visit. Cookies are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Most web browsers allow some control of most cookies through the browser settings.
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
9 – SALE OF TEMPLARS MEDICAL
If Templars Medical’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
Templars Medical takes every precaution to protect your personal data and prevent unauthorised access. Data is stored securely and all software is current, patched and secured appropriately. The information is encrypted where possible. Firewalls are in place both locally in our office and on the cloud platform. Anti-virus software is in place across the organisation.
Your data is accessed only by authorised users who need the data to perform a specific function. Access is managed by password protected user accounts and where applicable specific user groups and permissions are allocated to access all data.
Templars Medical uses all reasonable efforts to safeguard your personal information and we undertake periodic reviews of security to ensure data is protected and secure. However, you should be aware the use of email and the internet is not entirely secure and for this reason Templars Medical cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email or the internet. If you share a device with others we strongly recommend you do not select the “remember my details” function when this option is offered.
If you have any questions about data security contact firstname.lastname@example.org.
12 – COMPLAINTS OR QUERIES