Welcome to Our Privacy Policy

We value your privacy and are dedicated to safeguarding your personal data. This privacy policy is designed to inform you about how we handle your personal data when you visit our website, regardless of your location, and to educate you about your privacy rights and the legal protections in place.

1. Important Information and Who We Are

We are health pro connect Ltd, a company registered in England and Wales under company number 11472575, operating under the name NovaMed Healthcare.

This privacy policy is issued on behalf of the healthproconnect. When we refer to "healthproconnect," "we," "us," or "our" in this privacy policy, we are referring to the relevant company within the healthproconnect Talent group responsible for processing your data. We will specify which entity acts as the data controller for your data when you apply for a job. NovaMed Healthcare is the data controller responsible for this website.

If you have questions or require assistance

healthproconnect Talent has appointed a data protection officer (DPO) responsible for overseeing inquiries related to this privacy policy. If you have any questions, including requests to exercise your legal rights, please contact the DPO at info@healthproconnect.co.uk or write to us at 5th Floor 4 Coleman Street London EC2R 5AR. Email communication is preferred for quicker responses.

You have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's data protection regulator (www.ico.org.uk), at any time. However, we appreciate the opportunity to address your concerns before contacting the ICO, so please reach out to us first.

Purpose of this Privacy Policy

To provide work-finding services, we need to process personal data, including sensitive category data. This privacy policy aims to provide you with information on how we collect and process your personal data.

This website is not intended for children, and we do not knowingly collect data related to children.

Please read this privacy policy alongside any other privacy or fair processing policies we may provide on specific occasions when we collect or process your personal data. While we've made it as user-friendly as possible, we recommend taking some time with a cup of tea to review it thoroughly. This privacy policy complements other notices and privacy policies and is not intended to override them.

Changes to the Privacy Policy and Your Duty to Inform Us of Changes

We regularly review our privacy policy. This version was last updated on 1st August 2023. You can obtain historical versions by contacting the DPO.

It's crucial to keep your personal data accurate and current. If your personal data changes during our relationship, please inform us.

Third-Party Links

Our website may include links to third-party websites, plug-ins, and applications. Clicking on these links or enabling connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we recommend reviewing the privacy policy of every site you visit.

2. The Data We Collect About You

Types of Data

To provide work-finding services, we collect your personal data, which may include special categories of personal data. This includes, for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, recommending you for job opportunities, processing payments to you, and developing and managing our services and relationships with you and our clients.

In some cases, we may need to use your data for investigating, reporting, and detecting crime, as well as to comply with applicable laws. We may also use your information for internal audits to demonstrate compliance with industry standards.

Personal data, or personal information, refers to any information that can identify an individual. It does not include data from which the identity has been removed (anonymous data).

Special category data includes data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data, data concerning health, or data concerning a person's sex life or sexual orientation. Rest assured, we don't collect all of this, and we'll explain below what information we do need to provide work-finding services.

Criminal offence data may be collected for roles that involve working with specific categories of people, particularly vulnerable individuals, following a DBS or enhanced DBS check.

Categories of Personal Data

We may collect, use, store, and transfer various kinds of personal data about you, which we have grouped as follows:

• Identity Data includes your first name, maiden name, last name, title, date of birth, and gender if provided in your CV. To comply with our legal and contractual obligations when providing recruitment services, we also collect nationality, "Right to Work" identification, and visa information.
• Contact Data includes your address, email address, and telephone numbers.
• Financial Data includes your bank account details to facilitate payments if you are a temporary or agency worker.
• Work History includes your CV, education, work history, qualifications/accreditations, courses completed, references, and any other information you believe is relevant for us to provide work-finding services. In some roles, we may also require you to disclose any prior investigations or complaints filed against you. We will request this information if necessary.
• Technical Data includes internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.

We also collect, use, and share Aggregated Data, such as statistical or demographic data, for various purposes. Aggregated Data can be derived from your personal data but does not identify you directly or indirectly. For example, we may aggregate your data with others to determine the percentage of people interested in specific roles or a particular website feature. However, if we combine Aggregated Data with your personal data in a way that can directly or indirectly identify you, we treat it as personal data subject to this privacy policy.

Categories of Special Category and Criminal Offence Data

We only collect this information with your consent. We treat all data shared with us, especially these categories, with great care and confidentiality because we understand their sensitivity:

• Criminal Offence Data: When required for a role and allowed by law, we may collect information from a DBS or enhanced DBS check.
• Health Data: This includes details of any disability that may affect your ability to perform a role or any health information you want us to be aware of for appropriate adjustments. Certain roles in the healthcare sector may require confirmation of vaccinations.
• Trade Union Membership: This may include membership in organizations like the British Medical Association, Royal College of Nursing, The Social Workers Union, Unite, or UNISON.

If You Fail to Provide Personal Data

If we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide it when requested, we may not be able to provide you with work-finding services.

Client Data

This section applies if you are an individual working for an employer that uses our recruitment services. We may need to collect and process information about you or individuals at your organization to provide our recruitment services. These include (but are not limited to) finding a suitable pool of candidates for your vacancies, offering Managed Service Provider ("MSP") programs, Recruitment Process Outsourcing ("RPO") services, providing market-relevant information, or sourcing potential opportunities from you as part of our recruitment services.

The information we collect: We collect minimal information about our clients, mainly to ensure smooth operations and compliance with legal requirements. This may include retaining records of our interactions to meet contractual obligations, address legal claims, assess suitability to contact you regarding potential opportunities or our services, and ensure compliance with this privacy notice.

3. How Is Your Personal Data Collected?

We use various methods to collect data from and about you, including:

• Direct Interactions: You may provide us with your data by filling out forms or corresponding with us via mail, phone, email, or other means. This includes data provided when:
  • You apply for a role by completing applications or registration forms.
  • You share documents like your ID, CV, or DBS certificates.
  • You create an account on our website to register for roles.
  • You provide feedback or contact us.
• Job Boards: We may collect your data from job boards or similar sources like LinkedIn. We do so in compliance with the permissions you have granted to those platforms.
• Third Parties: These may include your referees to verify your work history and performance, our clients (especially if you are on a temporary placement), other recruitment agencies that may pass your details to us, referrals from individuals you know or have worked with, and government organizations when conducting right-to-work or DBS checks.
• Automated Technologies or Interactions: As you interact with our website, we may automatically collect Technical Data about your devices and browsing activities through cookies, server logs, and similar technologies. Please refer to our cookie policy for more details.

4. How We Use Your Personal Data

We will only use your personal data when permitted by law. Most commonly, we will use your personal data for the following purposes:

• To perform the contract we are about to enter into or have entered into with you.
• When necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests.
• To comply with a legal obligation.

If you are a candidate and register on our website, we may use an automated process to assess your suitability for specific vacancies and assignments. If you do not want us to process your data in this manner, you can submit your details via email or telephone using the contact information on our website.

We generally do not rely on consent as the legal basis for processing your personal data, except when collecting special category or criminal offence data or sending third-party direct marketing communications to you via email or text message. You have the right to withdraw your consent for marketing at any time by contacting us.

Purposes for Which We Will Use Your Personal Data

We have outlined below, in a table format, the various ways we intend to use your personal data, along with the legal bases on which we rely. We have also indicated our legitimate interests where applicable.

Please note that we may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. If you need details about the specific legal ground we rely on when processing your personal data, please contact us.

Marketing

We aim to offer you choices regarding certain personal data uses, particularly with regard to marketing and advertising. We have established the following personal data control mechanisms:

• Promotional Offers from Us: We may use your Identity and Contact Data to form a view on what you may want or need, or what may be of interest to you. You will receive marketing communications from us if you have requested information from us or have received work-finding services from us and you have not opted out of receiving that marketing.
• Third-Party Marketing: We will obtain your explicit opt-in consent before sharing your personal data with any third party outside of healthproconnect Talent for marketing purposes.
• Opting Out: You can ask us or third parties to stop sending you marketing messages at any time. This can be done by logging into our website and adjusting your marketing preferences, following the opt-out links in marketing messages, or contacting us at any time. Opting out of marketing messages will not affect personal data provided to us as a result of work-finding services.

Cookies

You can configure your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. However, if you disable or refuse cookies, some parts of our website may become inaccessible or function improperly. For more information about the cookies we use, please see our Cookies & Data Processing Policy.

Change of Purpose

We will only use your personal data for the purposes we collected it for, unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis for doing so. Please note that we may process your personal data without your knowledge or consent when required or permitted by law.

5. Disclosures of Your Personal Data

We may share your personal data with the following parties for the purposes specified in the "Purposes for Which We Will Use Your Personal Data" table above:

• Internal Third Parties, as described in the Glossary.
• External Third Parties, as described in the Glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or assets. If our business undergoes a change, the new owners may use your personal data in the same way described in this privacy policy.

We require all third parties to respect the security of your personal data and treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

When we provide your personal data to clients as part of our work-finding services, the client becomes an independent data controller. To understand the data they collect and process, as well as to exercise your data protection rights concerning your personal data, you will need to contact them directly or review their privacy policy.

6. International Transfers

We may share your personal data within the healthproconnect, which may involve transferring your data outside the UK.

Whenever we transfer your personal data outside the UK, we ensure a similar level of protection is afforded to it. This may include using specific contracts approved by the Information Commissioner's Office (ICO) or ensuring the recipient is based in a country that the ICO considers to provide an adequate level of data protection.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data outside the UK.

7. Data Security

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

How Long Will You Use My Personal Data?

We will retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, whether we can achieve those purposes through other means, and the applicable legal requirements.

By law, we have to keep basic information about our clients (including Contact, Identity, Financial, and Transaction Data) for six years after they cease being clients for tax purposes.

In some circumstances, you can request the deletion of your data. In such cases, we will anonymize your data to maintain statistical data integrity.

In some cases, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes. We can use anonymized information indefinitely without further notice to you.

9. Your Rights Regarding Your Personal Data

You have the following rights regarding your personal data:

• Access Request: You can request access to your personal data, often referred to as a "data subject access request." This allows you to receive a copy of the personal data we hold about you and verify its lawful processing.
• Data Correction: You can request the correction of any personal data we hold about you. This allows you to rectify any incomplete or inaccurate data we may have, though we may need to verify the accuracy of the new information you provide.
• Data Erasure: You can request the deletion or removal of your personal data under certain circumstances. This includes situations where there is no valid reason for us to continue processing your data, or when you've successfully exercised your right to object to processing. However, please note that we may not always be able to comply with your request for erasure due to specific legal obligations, which we will inform you about if applicable.
• Objection to Processing: You can object to the processing of your personal data when we rely on a legitimate interest or that of a third party. This is applicable when you believe that your fundamental rights and freedoms are affected. You also have the right to object when we process your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate reasons for processing your information, which outweigh your rights and freedoms.
• Data Processing Restriction: You can request the suspension of the processing of your personal data in certain situations, including when you want us to verify the accuracy of your data, when our data use is unlawful but you want us to retain it, or when you need us to keep the data even if we no longer require it for legal claims. If you've objected to our data use, but we need to assess whether we have legitimate grounds for overriding your objection, this right can also be exercised.
• Data Portability: You can request the transfer of your personal data to yourself or a third party. We will provide your personal data in a structured, commonly used, and machine-readable format. Please note that this right applies primarily to automated data that you initially provided consent for or data used in the context of a contract with you.
• Consent Withdrawal: You have the right to withdraw your consent for the processing of your personal data at any time. However, this withdrawal will not affect the legality of any processing that occurred before your consent was withdrawn. In some cases, withdrawing your consent may impact our ability to provide certain products or services, which we will inform you about if applicable.

If you wish to exercise any of these rights, please contact us.

No Fee Requirement: Normally, you will not be required to pay a fee to access your personal data or exercise these rights. However, if your request is manifestly unfounded, repetitive, or excessive, we may charge a reasonable fee or refuse to comply with your request under these circumstances.

Information Needed: We may request specific information from you to confirm your identity and ensure your right to access your personal data or exercise your other rights. This is a security measure to protect against the unauthorized disclosure of personal data. We may also contact you to request additional information to expedite our response.

Response Time: We strive to respond to all legitimate requests within one month. However, if your request is particularly complex or if multiple requests are made, it may take longer to respond. In such cases, we will notify you and provide updates on our progress.

10. Glossary

Lawful Basis:

• Legitimate Interest: Our business's interest in conducting and managing our operations to provide you with the best service and experience. We carefully consider and balance the potential impact on your rights and freedoms before processing your personal data for our legitimate interests. We do not use your personal data when our interests are outweighed by the impact on you, unless we have your consent or are required or permitted by law. You can contact us for more information about how we assess our legitimate interests against potential impacts on you in specific situations.
• Performance of Contract: Processing your data when it is necessary for the performance of a contract in which you are involved or when taking steps at your request before entering such a contract.
• Compliance with a Legal Obligation: Processing your personal data when it is necessary to comply with a legal obligation to which we are subject.

Third Parties:

• Internal Third Parties: Other companies within the healthproconnect Talent group acting as joint controllers or processors.
• External Third Parties: Various service providers acting as processors, including those providing administration, IT, marketing, and system administration services, employers or agents of record, professional advisers, governmental authorities, and others involved in our operations. The roles and responsibilities of these external third parties may vary depending on the context of their involvement.