The personal data we collect may include sensitive personal data and we process this 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.

The legal bases we rely upon are:

• • Necessary on the basis of our Legitimate Interests
• • Necessary for the Performance of Contract
• • Necessary for Compliance with a Legal Obligation

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 rely on a legitimate interest to process your personal data, our legitimate interests include the following:

• • Managing our database and keeping work-seeker records up to date;
• • Providing work-finding services to you and our clients;
• • Giving you information about similar services that you have used from us recently

LEGAL / CONTRACTUAL REQUIREMENT

We have certain legal and contractual requirements to collect personal data. For example, to comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003, we will undertake various checks including your identity, right to work, suitability for job roles, qualifications and experience. We will undertake further checks to comply with immigration and tax legislation, and 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.

SENSITIVE PERSONAL DATA AND CRIMINAL CONVICTIONS/OFFENCES

• • Personal data that reveals racial or ethnic origin is processed on the basis that it is necessary for the purpose of compliance with the Equality Act 2010 / Equal Opportunities Monitoring;
• • Personal data concerning health is processed on the basis that it is necessary for:
• • the assessment of the working capacity of the data subject;
• • compliance with employment law including health and safety legislation and statutory sick pay procedures
• • Personal data concerning criminal convictions and offences is processed on the basis that we are legally required to undertake suitability checks, including enhanced level DBS checks, for all the roles we recruit for.

RECIPIENT/S OF DATA

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. hospitals, care services, local authorities);
• • Individuals and organisations who hold information related to your reference or application to work with us, such as current, past or prospective employers, educators and examining bodies and employment and recruitment agencies;
• • Potential employers and other recruitment agencies and organisations to increase your chances of finding employment / temporary work;
• • Third parties who carry out audits to ensure we run our business correctly;
• • Third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors, insurers and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);
• • Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
• • Payroll service providers who manage our payroll, or other payment intermediaries whom we may introduce you to;
• • Other recruitment agencies in the supply chain (e.g. master/neutral vendors and second tier suppliers);
• • Our IT and CRM software providers;
• • Our Telephone and SMS communications providers;
• • Training providers whom we work with to provide classroom based and e-learning training;
• • Occupational health check providers who we use to conduct compliance checks;
• • DBS umbrella bodies who we use to process online enhanced level criminal record checks;
• • Public information sources and other third-party organisations we use to carry out suitability checks on work-seekers e.g. Companies House, the Disclosure and Barring Service (DBS), Nursing and Midwifery Council (NMC), General Medical Council (GMC), DVLA, credit reference agencies;
• • Government, law-enforcement agencies and other regulators e.g. the Police, Home Office, HMRC, Employment Agencies Standards Inspectorate (EASI), Local Authority Safeguarding Teams.
• • Analytics and search engine providers that assist us in the improvement and optimisation of our site.

INFORMATION COLLECTED

The personal data we collect or receive includes the following, as applicable:

Personal data

• • Full name (including aliases)
• • Date of birth
• • Contact details (including telephone number, email address and postal address)
• • Nationality
• • National insurance number and tax-related information
• • Bank details
• • Proof of insurance cover
• • Proof of limited company registration
• • Experience, training, qualifications, professional registrations (e.g. NMC pin)
• • CV / employment history
• • Previous employment / study references and verification of gaps in employment
• • Driving licence details
• • Emergency contact details / next of kin
• • Details of dependents (a legal requirement in the event of a safeguarding investigation)
• • Details of referral
• • Copies of photographic id documents (e.g. Driving licence, passport, identity card)
• • Copies of documents providing proof of address (e.g. Utility bill or bank statement)
• • Information related to your interests and preferences regarding future employment
• • Additional information that you choose to tell us, whether in a CV, accompanying correspondence, or in any form you complete.
• • Technical information data about your use of our website (e.g. IP address, login information, browser type, time zone setting, operating system and how you navigated our website)

Sensitive personal data
• • Diversity information (including gender, racial or ethnic origin, religious or other beliefs, physical or mental health, details of any disabilities)
• • Health and medical information
• • Criminal record and offence data
• • Source of the personal data:
• • The Company may have sourced your personal data from third party sources including:
• • Job Boards (e.g. Reed.co.uk, CV Library, Indeed, LinkedIn)
• • A former employer
• • A referee whose details you previously provided to us
• • Cookies listed in section 7

DATA RETENTION

We will delete all non-legally required personal data from our systems if we have not had any meaningful contact with you (or, where appropriate, the company you are working for or with) for two years. After this period, it is likely your data will no longer be relevant for the purposes for which it was collected. Certain laws may require us to keep certain data for longer periods of time. For example, we must 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. This is currently up to 6 years.