Privacy Policy

Stonor Medical is a recruitment business which provides work-finding services to its clients and work-seekers. The Company must process personal data (including special categories of personal data) so that it can provide these services – in doing so, the Company acts as a data controller.

You may give your personal details to the Company directly, such as on an application or registration form or via our website, or we may collect them from another source such as a jobs board. The Company 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 to you, we will only use your personal data in accordance with this privacy statement. We will comply with current data protection laws at all times.

Contents

1. Collection and use of personal data
   1. Purpose of processing and legal basis
   2. Legitimate interest
   3. Statutory/contractual requirement
   4. Recipients of data
2. Information to be provided when data is not collected directly from the data subject
   1. Categories of data
   2. Sources of data
3. Overseas transfers
4. Data retention
5. Your rights
6. Automated decision making
7. Cookies
8. Login files
9. Links to external sites
10. Sale of the business
11. Data security
12. Changes to this privacy statement
13. Complaints or queries

1. Collection and use of personal data

a. Purpose of processing and legal basis

The Company will collect your personal data (which may include special categories of 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 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.

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.

On some occasions 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.

We 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
• 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 the Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:

• Managing our database and keeping work-seeker records up to date;
• Providing work-finding services to you and our clients;
• Contacting you to seek your consent where we need it;
• Giving you information about similar products or services to those that you will have used from us recently;
• Passing work seekers information to other authorities for legal purposes.

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 require this personal data, and we may need your data to enter into a contract with you. If you do not give us the personal data, we need to collect In order to comply with our statutory and legal requirements, we may not be able to continue to provide work-finding services to you.

d. Recipient/s of data

The Company will process your personal data and/or sensitive personal data with the following recipients:

• Clients (who we may introduce or supply you to). Business partners, suppliers, Private hospitals and NHS hospitals, auditors and subcontractors for the performance of any contract we enter into with you.
• Your former employers who we may seek references from
• Payroll service providers who manage payroll on our behalf or other payment intermediaries who we may introduce you to
• Other recruitment agencies in the supply chain
• Auditors who are assessing the compliance and processes of the business to ensure its adherence to all relevant legislation and good practice guidance
• Any public information sources and third party organisations that you may use to carry out suitability checks on workers e.g. Companies House, The Disclosure and Barring Service (DBS), Teaching Regulation Authority (TRA), 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 Designated Officers (LADOs), GLAA;Trade unions;
• Legal advisers
• IT and CRM providers
• Any of Stonor Medical group companies; and
• Any other organisations an individual asks you to share their data with. Please note that this is not an exhaustive list.

2. Information to be provided when data collected not from the data subject

Categories of data: The Company has collected the following personal data on you:

Personal data: [this list is not exhaustive]

• Identity Data e.g., name, date of birth, gender, national insurance number
• Contact Data e.g., address, email address, phone numbers
• Financial Data e.g., bank account details
• Technical Data e.g., IP address, browser type, operating system,
• Profile Data e.g., profession, grade, speciality, CV, compliance documents, RTW, qualifications, DBS
• Marketing preferences Data e.g., notification and communication preferences regarding marketing of Stonor Medical’s products and services

Special categories of personal data: [not an exhaustive list]

• Health information including whether you have a disability
• Criminal conviction(s)
• Any Health and Safety risk assessment required on a case-by-case basis
• [Specify any other data…]

Source of the personal data: The Company sourced your personal data/special categories of personal data: [not an exhaustive list – please complete]

• From jobs boards,
• LinkedIn and other social media platforms
• A former employer
• A referee whose details you previously provided to us
• Software providers who we use to support our services
• Cookies listed in section 7

3. Overseas Transfers

The Company may transfer the information you provide to us to countries outside the UK and/or 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.

4. Data retention

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. For example, 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 are required to keep your records relating to the right to work in the UK 2 years after employment or the engagement has ended alterable and working time records including your 48-hours opt out notice annual leave/holiday records 2 years from the time they were created.

Additionally, 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. This is currently 3 to 6 years.

Where the Company has obtained your consent to process your personal and special categories of personal data we will do so in line with our retention policy (a copy of which is attached). Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal data and sensitive personal data.

5. Your rights

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

• The right to be informed about the personal data the Company processes on you;
• The right of access to the personal data the Company 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 the Company processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by contacting Simon Cummins by email: simon@stonormedical.com Please note that if you withdraw your consent to further processing that does not affect any processing done prior to the withdrawal of that consent, or which is done according to another legal basis.

There may be circumstances where the Company 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 that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.

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.

Stonor Medical GDPR Subject Access Request Policy Oct 2023

6. 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 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.

The table below explains the cookies we use and why.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, please refer to our Cookie policy. Please note that in a few cases some of our website features may not function if you remove cookies from your browser.