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Welcome to Care4Health's Privacy Statement

Care4Health Ltd respects your privacy and is committed to protecting your personal data. Our privacy statement tells you how we look after your personal data as well as your sensitive personal data when you register with us to get help finding work, when you visit our website, register for a draw or ask for information about jobs that might interest you. The policy will tell you about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY STATEMENT
This privacy statement aims to give you information on how Care4Health Ltd collects, processes and stores your personal and your sensitive personal data including but not limited to any data you may provide directly to us through the job-seeking application, registration or compliance process or when you sign up to receive information about our jobs, services or products, when you purchase a service or product, when you sign up for an account or take part in a draw, competition or survey. We may collect personal data from another source such as a jobs board.

We 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 toyou or to enter you into a draw or competition, we will only use your personal data and sensitive personal data in accordance with the terms of the following statement.

Neither or work-seeking service or our website is intended for children and we do not collect data relating to children.

It is important that you read this privacy statement together with any website privacy statement or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy statement supplements the other notices and is not intended to override them.

CONTROLLER
Care4Health Ltd is a recruitment business which provides work-finding services to its clients and work seekers. We must process personal data and sensitive personal data so that we can provide these services – in doing so, Care4Health acts as a data controller. Care4Health Ltd have never bought or sole your personal or sensitive personal data, and we never will.

In this policy we are collectively referred to as “Care4Health Ltd”, “we”, “us” or “our” in this privacy statement.

Our Director, Celinda Huband, is responsible for overseeing questions in relation to this privacy statement. If you have any questions including any requests to exercise your legal rights, please contact Celinda using the details set out below.

CONTACT DETAILS
Care4Health Ltd
Celinda Huband, Director 
Telephone Number:  01905 642500
Email address: celinda@care-4-health.co.uk
Postal address: 8 Millhouse, Elgar Business Centre, Moseley Road, Hallow, Worcester. WR2 6NJ

YOUR DUTY TO INFORM US OF CHANGES
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS
Our Care4Health Ltd website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those 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 encourage you to read the privacy statement of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, 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).

Sensitive personal data means any information relating to racial or ethnic origin, political and religious, philosophical beliefs, trade union membership, physical or mental health, sex life or sexual orientation or criminal records.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data includes [first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender].
Contact Data includes home address, email address and telephone numbers.
Transaction Data includes details about payments to and from you and other details of services and products we have provided you with, hours and days you have worked, tax, NICs, references, etc.
Technical Data includes internet protocol (IP) address, your 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 this website.
Profile Data includes your username and password, your interests, preferences, feedback.
Usage Data includes information about how you use our website, services and products.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate all locum hours to complete management reports under the Framework Agreements.  However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy statement.

We also collect Special Categories of Personal Data about you also called Sensitive personal Data (this includes details about your nationality for purposes of Right to Work checks,  information about your health  for Occupational Health checks, information about any criminal convictions and offences to apply for your Enhanced DBS due to the Rehabilitation of Offenders Act 1974 (Exceptions Order) 1975).  

IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with work seeking services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. It may mean that a work opportunity is withdrawn until we receive and process your personal and sensitive personal information.

3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity or contact details directly by completing an application or registration form via our website, by email or by corresponding with us by post, phone, in person at a seminar, conference or otherwise; or we may collect them from another source such as a jobs board This includes  personal data you provide when you;
  • apply for our services or products;
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback.

  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.
  • Third parties or publicly available sources. We may receive or share personal data about you from various third parties and public sources as set out below:
  • Identity and Contact Data from an ID Verification and Right to Work system we use called uComply.
  • Identity and Contact Data from publicly availably sources [such as Companies House professional registration bodies such as the HCPC/GMC/NMC, DVLA, HMRC, Disclosure and Barring Service, Worcestershire Working Well (an Occupational Health service that provides our Fitness to Work Certificates), and The Doctors Lab (a laboratory that provides our serology reports and proof of immunity)].

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal and sensitive personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you e.g. 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 database, helping you to get fully compliant, putting you forward for job opportunities, arranging payments to you and developing and managing our services and relationship with you and our clients.
  • 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 need to comply with a legal or regulatory obligation. 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 or external audits to demonstrate our compliance with certain industry standards.
  • Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by using the unsubscribe form here.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal and sensitive personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal or sensitive personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new candidate such as application, registration or website registration forms, CV, interview forms, etc.

(a) Identity

(b) Contact

a) Performance of a contract with you

b) Necessary for our legitimate business interests offering work-seeking services to you and workers to our clients

To assist you in achieving full legal compliance so that we can offer you work-seeking services, for example, Right to Work, ID Verification, obtaining an Enhanced DBS checks, taking up references, DVLA checks, HCPC/GMC/NMC checks, IR35 checks, Fitness to Work Certificates

(a) Identity

(b) Contact

(c) Personal

(d) Transaction

(e) Sensitive personal information such as criminal convictions, health information and nationality

(a) Performance of a contract with you

(b) To comply with a legal obligation (to carry out Right to Work checks, to adhere to IR35  and DBS/Safeguarding rules etc

(c) Necessary for our legitimate business interests (offering work-seeking services to you and workers to our clients)

To deliver work-seeking services to you including sending your information to clients where you have demonstrated an interest in doing that particular type of work, but not expressly consented to us sending your CV and contacting you with information about similar services that you have used from us recently.

(a) Identity

(b) Contact

(c) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate business interests (offering work-seeking services to you and workers to our clients)

To process your pay using timesheets, sending them with client invoices and communicating with your umbrella company, as well as collecting data to send to HMRC for IR35 regulations.

(a) Identity

(b) Contact

(c) Transaction

a) Performance of a contract with you.

b) Necessary to comply with a legal obligation (to comply with HMRC’s IR35 and The Conduct of Employment Agencies and Employment Businesses Regulations 2003)

To manage your data on our database to keep your records accurate and up to date

(a) Identity

(b) Contact

(c) Marketing and communications

(a) Performance of a contract with you

(b) To comply with a legal obligation

(c) Necessary for our legitimate business interests (to keep your data updated)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and communications

(a) Performance of a contract with you

(b) To comply with a legal obligation

(c) Necessary for our legitimate business (to keep your data updated and to study how customers use our services/products so that we can continually improve)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate business interests (to study how customers use our services, to develop them and grow our business/service)

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

(a) Necessary for our legitimate interests (to study how customers use our services/products, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, services/products, marketing, customer relationships and experiences

(a) Technical

(b) Usage

(a) Necessary for our legitimate interests (to define types of customers for our services and products, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about services or products that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(a)  Necessary for our legitimate interests (to develop our services/products and grow our business)

To pass on your information to debt collection services

(a) Identity

(b) Contact

(a) Necessary for our legitimate interests (to collect payments for services or overpayments)

MARKETING  

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

PROMOTIONAL OFFERS FROM US  
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services or products may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us, received work-seeking services, other services or products from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have opted to receive that marketing.

OPTING OUT  
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service or product which we have supplied to you or you have purchased, a service/product experience or other transactions.

COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

CHANGE OF PURPOSE   
We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal and sensitive personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

External Third Parties as set out in the Glossary.

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

6. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the European Economic Area (EEA). The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.

7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal and sensitive personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal and sensitive 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 they are subject to a duty of confidentiality.

We have put in place procedures 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 FOR?
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 pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation (currently for payroll information from it is 3 years from the end of the tax year).

Working time records must be kept for 2 years from the time they were created.

Right to Work documents must be kept for 2 years after your last engagement with us has ended.

For sensitive personal data such as health data we save that for the lifetime of the framework agreement under which your assignments fell for compliance audits to show continuity of compliance throughout the agreement.

9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal and sensitive personal data. Please click on the links below to find out more about these rights:

YOUR LEGAL RIGHTS
You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services or products to you. We will advise you if this is the case at the time you withdraw your consent.

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.

You can also contact us using the above details 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.

NO FEE USUALLY REQUIRED 
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU 
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

External Third Parties
Service providers acting as processors based in the United Kingdom and Australia who provide IT and system administration services.

  • Service providers offering Occupational Health checks, DBS checks, HCPC/GMC/NMC alert notices, Referees you name, Appraisers, Pathology labs for serology and immunity reports, DVLA checks, auditors authorised by our Framework providers, ID and Right to Work verification
  • Service providers acting as processors based in the United Kingdom to fulfil our email marketing requirements.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • Managed service providers and temp staffing teams based in the United Kingdom who provide master vendor, neutral vendor, online timesheet authorisation, self-billing, direct engagement services to our clients as well as you.

11. COMPLAINTS

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

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