Newson Health Limited
Privacy Notice for Staff and Applicants
The following information forms part of our Privacy Notice for our employees including job applicants
and agency staff. It sets out further important information about the personal data that Newson
Health Limited holds about you and how that information may be used.
The Personal 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). The extent of the information we collect, and use will depend on what information you choose
to provide to us or what information is provided to us on your behalf.
We may collect, use, store and transfer different kinds of personal data about you which we have
grouped together as follows:
- Identity Data: includes your name, marital status, title, date of birth and gender, name of
next of kin;
- Contact Data: includes billing address, delivery address, email address and telephone
numbers, next of kin contact details;
- Work background data: includes right to work permit details (if relevant), professional
qualifications, work history and experience, a copy of your Curriculum Vitae, a copy of
confirmation of qualifications;
- Staff Records: includes interview records, references we have received about you and
references we have written on your behalf, appraisal and training records, records of any
grievance or disciplinary process that you have been involved in, holiday records,
remuneration and benefits records;
- Financial Data: includes bank account and payment card details, pension records, private
medical insurance records, life assurance records;
- Other Data: Car registration mark, CCTV images.
Special Categories of Personal Data
Special Category Personal Data specifically means personal data relating your race or ethnicity,
religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union
membership, information about your health, and genetic and biometric data.
We may collect and hold the following special categories of information about you: Information about
your health such as details of medical conditions, sickness records, Occupational Health records; race;
ethnicity; sex life or sexual orientation; religious or philosophical beliefs and details of trade union
membership.
We may also records relating to any criminal convictions (including offences and alleged offences and
any court proceedings or sentence) if you have given this information to us or we have obtained it
from a third party such as the Disclosure and Barring Service.
Where Do We Obtain Your Personal Data From?
- Direct interactions. We will collect your personal information from you when you apply for
a job with us or become an employee. Information may be collected from correspondence
such as telephone calls or email;
- Third parties and publicly available sources. In most cases, the personal data we collect
will come directly from you. However, in limited circumstances we may receive information
about you provided by a third party such as:
- The Disclosure and Barring Service and overseas Police agencies (in the context of a
job application);
- Referees that have sent us a reference about you;
- Professional and educational bodies such as the Nursing and Midwifery Council
(NMC), Health and Care Professions Council (HCPC) in the context of confirmation of
qualifications or professional regulatory matters;
- A family member or other person communicating with us on your behalf;
- Occasionally, government agencies such as HMRC or the Home Office.
If You Provide Us with Personal Information About Others
If you provide personal information to us about others you should inform the individual about the
contents of this Privacy Notice. We will process such information in accordance with this Privacy
Notice.
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 employ you . In this case, we may have to
withdraw our offer of employment but we will notify you if this is the case at the time.
How we use your personal data
We will process your personal information in accordance with this Privacy Notice and only where we
are legally permitted to do so. The main purposes for collecting and using your personal data are to
facilitate your contract of employment with us and so that we can comply with our legal and regulatory
requirements. More information about how we use your personal data is set out below.
Data protection law requires us to have a legal basis to justify using your personal data. The legal basis
used will vary, depending on why we are using your personal data. If we process "special categories
of personal information", we must have an additional legal basis to justify using it.
You will find details of the "legal bases" we rely upon for each of our processing purposes set out
below.
Purpose: For the Recruitment Process
Newson Health will use your personal data to assess your suitability for the role you have applied for
including your qualifications, skills and experience. We may carry out background checks, take up
references, confirm your qualifications and, where relevant confirm that you have the right to work in
the UK. We will use your name and contact details to correspond with you about your application and
for monitoring outcomes generally. Your information may be used to comply with our equal
opportunity monitoring and reporting obligations are met. We will retain some of the recruitment
records for a certain period of time in accordance with our Data Retention Policy.
Legal Bases:
- Where the use is necessary in connection with your employment contract with us.
- Where the use is necessary in order for us to comply with our legal obligations. For example,
we may have a legal duty to carry out background checks.
- Where the use is necessary for our legitimate interests including carrying out our assessment
to see if you are suitable for the role you have applied for, complying with our legal obligations
and developing our recruitment process, providing these interests are not overridden by your
privacy rights and freedoms.
Additional legal bases for special categories of personal data:
- Where the use is necessary in order for us to comply with our obligations as an employer. For
example, we may need to process your health information to determine if we need to make
reasonable adjustments so that you can attend the interview and carry out the job you have
applied for and also to confirm your fitness to perform the job in question.
- Where the use is necessary for reasons of substantial public interest based upon law. For
example, where the job you are applying for entitles or requires us to carry out criminal
records checks.to deal with insurance-related matters or fraud prevention and detection.
- Occasionally, where the use is necessary to establish, exercise or defend our legal rights.
Purpose: To Administer your Employment or other Contract
Newson Health will collect and use your personal data in order to administer and manage our
employment contract, fulfil the contractual obligations we owe you as your employer, and to comply
with our legal and regulatory obligations. Your personal data may be used in the context of running
our business and sites generally including CCTV footage and IT records. We will also use your
information to maintain records relating to those that work for us and to investigate issues raised with
us regarding your work or role.
Legal Bases:
- Where the use is necessary in connection with your employment contract with us. For
example, ensuring your pay and benefits are administered.
- Where the use is necessary in order for us to comply with our legal obligations. For example,
we may have a legal duty to carry out background checks or report certain concerns to a
regulatory body.
- Where the use is necessary for our legitimate interests including administering your
employment or other contract, and investigating and where appropriate, sharing, concerns
regarding you or your work, providing these interests are not overridden by your privacy
rights and freedoms.
Additional legal grounds for special categories of personal data:
- Where the use is necessary in order for us to comply with our obligations as an employer. For
example, we may need to process your health information in order to process Statutory Sick
Pay payments.
- Where the use is necessary for reasons of substantial public interest based upon law. For
example, where the law requires us to report concerns relating to you to a third party body.
- Occasionally, where the use is necessary to establish, exercise or defend our legal rights. For
example, in connection with legal proceedings.
Purpose: Complying with our legal obligations and regulatory requirements
Legal Basis:
- Where the use is necessary for us to comply with a legal obligation. For example, we may have
a legal duty to carry out background checks or report certain concerns to a regulatory body.
- Where the use is necessary for fulfilling our legitimate interests including compliance with
relevant statutory, regulatory or legal requirements, providing those interests are not
overridden by your privacy rights and freedoms.
Additional legal bases for special categories of personal data:
- Where the use is necessary in order for us to establish, exercise or defend our legal rights.
- Where the use is necessary for reasons of substantial public interest on the basis of law. For
example, where it is necessary to process your personal information for the purposes of crime
prevention or safeguarding purposes or to protect any individual from neglect or harm.
Who Do We Share Your Personal Data With?
We may share your personal data with third parties listed below for the purposes set out above
(Purposes/Legal Bases). Where your personal data is shared, we only share the minimum amount of
information required to fulfil the purpose of sharing. It is shared securely and strictly in accordance
with the law.
- Other internal staff that are involved in the recruitment process, management of staff and
record keeping;
- Occupational Health staff (who may not be directly employed by Newson Health);
- Your previous employers, referees, other current employers, staffing agencies, educational
establishments and professional bodies such as NMC and HCPC;
- Disclosure and Barring Service or Disclosure Scotland;
- Patients, doctors, nurses, other staff and our advisors in order to deal with questions,
complaints or claims, including those made by yourself;
- HM Revenue and Customs, our regulators such as the Care Quality Commission and the
Information Commissioner’s Office (ICO) and other authorities based in the UK and other
relevant jurisdictions who require us to report processing activities in certain circumstances.
- The police and other regulatory third parties in connection with the prevention and detection
of crime or for safeguarding purposes;
- Our third party service providers such as our IT services provider, document storage providers,
digital dictation service, website hoster, marketing and email providers (Mailchimp and
Microsoft). These third party service providers are required to process your personal data only
on our instructions, securely and in accordance with relevant EU or UK data protection laws;
- Third party professional advisors including lawyers, accountants, auditors and insurers;
- Anyone that has been appointed or you have asked to communicate with us on your behalf
such as your insurer, individuals you have named as an emergency contact, such as your next
of kin;
- Third parties to whom we may sell, transfer or merge parts of our business or assets.
Other General Information About How We Process Your Personal Data
For general information about how we collect and process your personal data including for example,
how we keep it secure, how long it is retained, your legal rights and who to contact if you have any
questions about this Privacy Notice or your personal data please refer to our ‘Newson Health Privacy
Notice – General Privacy Information’ available on Sharepoint.
