Medsol
Healthcare Services Limited, GPS Locums Limited, Healthcare Staffing Solutions
Limited and The Endoscopy Group Limited Privacy Policy
Overview – the key information you should be aware of
Who we are: We are Medsol
Healthcare Services Limited ("Medsol"), GPS Locums Limited
("GPS"), Healthcare Staffing Solutions Limited (“HSS”) and The
Endoscopy Group Limited (“TEG”) all of which are either healthcare
recruitment companies or medical service companies:
Medsol supplies temporary
healthcare workers to the NHS and Private sector through all of the major
national framework agreements, supplying fully vetted and compliant Doctors and
Nurses in all grades and specialisms.
GPS supplies temporary
healthcare workers to the NHS and Private sector through all of the major
national framework agreements, supplying fully vetted and compliant Doctors and
Nurses in all grades and specialisms.
HSS supplies temporary
healthcare workers to the NHS and Private sector, supplying fully vetted and
compliant Doctors and Nurses in all grades and specialisms.
TEG supplies specialist medical
insourcing services to the NHS and Private sector, supplying a fully vetted, efficient
and compliant service.
If you need it, Medsol's company
number is 04522585, GPS's company number is 08147160, HSS’s company number is
10326674 and TEG’s company number is 09853305. All have a registered office at
Mayflower House, 1st Floor, and 128A High Street Billericay CM12 9DF. All
references in this policy to "Medsol/GPS/HSS/TEG", "our",
"us" or "we" refer to Medsol /GPS/HSS/TEG, or our group
companies as appropriate.
Our values and what this
policy is for: We value your privacy and want to be accountable and fair
to you as well as transparent with you in the way that we collect
and use your personal information. We also want you to know your rights
in relation to your information which you can find here.
In line with these values, this
privacy policy tells you what to expect when we collect and use personal
information about you. We have tried to make it easy for you to navigate so
you can find the information that is most relevant to you and our relationship
with you.
We are always looking to improve
the information we provide to our customers and contacts so if you have any
feedback on this privacy policy, please let us know using our contact details
in section 12.
Who this policy applies to:
This policy applies to:
1. Visitors to our website [2.4, 3];
2. Candidates and placed
consultants (including their referees) [1.1, 2.1, 3.1, 3.4, 4.1];
4. Hiring
managers at clients and prospective clients (to whom we send marketing
communications) [2.3, 3.2, 3.3, 4.2];
5. People who contact us
with enquiries [2.4, 3.4];
6. Our
contacts at master vendor organisations and umbrella companies with whom we
deal in connection with the supply of healthcare professionals we place with
our clients [2.3, 3.2, 4.2]; and
Depending on our relationship,
we will collect and use your information in different ways. Please click on
the links above to find out the information that we collect about you and how
we use this information.
The way in which we collect
your data will depend on how it comes into our organisation. This will be:
(b)
as a result of you responding to an advertisement posted by us on a job
board, online CV library or via social media; or
(c)
as a result of us matching your CV, as uploaded by you onto a job board,
online CV library or a social media site, to a vacancy we are seeking to fill
for one of our clients; or
(d)
as a result of a telephone conversation we have with you; or
(e)
as a result of a personal recommendation; or
(f)
from a company website; or
(g)
from your business card; or
(h)
in the course of us providing permanent and/or temporary recruitment
services or services involving the subcontracting of statements of work, to you
("Services"); or
(i)
as a result of our market research;
where "you" are
a candidate, consultant, client contact or contact at any other organisation
involved in the introduction and/or supply of a candidate's or consultant's
services, such as a contact at a master vendor, consultancy company, personal
service company or umbrella company.
References in this policy
to:
• "hirer"
and "client" mean any hiring organisation to whom we offer
and/or provide recruitment, resourcing and/or consultancy services;
• "client
contact" means a hiring manager or procurer/recipient of consultancy
services at a client;
• "candidate"
means a potential or actual candidate for a role with a client;
• "consultant"
means a person whose services are supplied via Medsol/GPS/HSS/TEG to work on
temporary assignment with a hirer, or, in the case of a consultancy supply, any
consultant assigned by the relevant consultancy to work on the consultancy
services.
Specifically, this privacy
policy provides you with details about the personal information we collect and
hold about you, how we use your personal information, and your rights regarding
your personal information.
It does not cover any use
of your personal information by:
• an actual or potential
employer or hirer;
• an umbrella company;
or
• any
other organisation involved in the supply of your services or consultancy via
us to a hirer,
to whom we provide your personal
information as part of the recruitment or consultancy process. That use will be
governed by the relevant employer's, hirer's, master vendor's or Umbrella
Company’s privacy policy.
What this policy contains:
This privacy policy describes the following important topics relating to your
information (you can click on the links to find out more):
Your rights to object:
You have various rights in respect of our use of your personal information as
set out in section 7. Two of the
fundamental rights to be aware of are that you may:
1.
ask us to stop using your
personal information for direct-marketing purposes. If you exercise this
right, we will stop using your personal information for this purpose.
2.
ask us to consider any valid
objections which you have to our use of your personal information where we
process your personal information on the basis of our, or another person's,
legitimate interest.
You can find out more
information in section 7.
What you need to do and your
confirmation to us: Please read this privacy policy carefully to understand
how we handle your personal information. By engaging with us in the ways set
out in this privacy policy, you confirm that you have read and understood the
entirety of this privacy policy, as it applies to you.
The
detail – the key information you should be aware of
1.
How we obtain your personal information
1.1
Candidates and Consultants: we will collect information about you when:
(a)
you access and browse our Site (including when you submit personal information
to us through data entry fields on our website); or
(b)
you respond to an advert posted by us whether via a job board, LinkedIn
or other social networking site; or
(c)
we download details uploaded by you onto a job board, LinkedIn or other
social networking site in relation to a vacancy we are seeking to fill for one
of our clients; or
(d)
we download details uploaded by you onto a job board, LinkedIn or other
social networking site in connection with our internal market research ; or
(e)
you contact us or we contact you by phone, email or otherwise; or
(f)
you register with us; or
(g)
we provide Services to you or to an actual or a potential hirer of your
services; or
(h)
we contact you with a view to providing Services to you; or
(i)
we request your information from universities, Royal Colleges, NHS
Trusts or Occupational Health Departments as part of your registration and background
checks we are required to carry out before placing you; or
(j)
we request a reference from one or more of your referees;
(k)
we provide on-boarding services to a hirer of your services,
(l)
you submit your time records to us;
(m)
we liaise with your umbrella company regarding contractual terms, hours
worked and payment for your services.
(n)
after one of our third party interview team conducts an interview with
you, we liaise with the third party interview team.
(o)
we liaise with agencies or training providers to verify documents
1.2
We may also obtain your information from third parties such as our
clients, umbrella companies, master vendors, market research companies, our
suppliers, group companies, public websites and public agencies.
1.3
You may give us personal information about yourself by using the online
forms provided on our website, completing our registration form or by
contacting us by phone, email or other means. This includes, for example, where
you provide your personal information to us in order to receive information or
Services from us.
2.
What information we will collect about you
2.1
Candidates and Consultants:
(a)
At the pre-registration stage we will normally only collect the
following information from or about you:
(i)
name, phone and e-mail details
(b)
As part of our registration process we will collect the following
further information from or about you:
(i)
name
(ii)
address;
(iii)
phone and e-mail details;
(iv)
your bank details
(v)
multiple proof of addresses
(vi)
a copy of your passport details including your passport photograph;
(vii)
ethnic origin
(viii)
your current and previous employment/work details, including job title
and employer;
(ix)
any professional certifications relevant to the role you seek to work
in, education and qualifications, skills, career history, salary/fee range,
right to work status, citizenship, and any other information relevant or
required by law to enable us to provide the Services;
(x)
any other information which you include in your CV or a completed
application form;
(xi)
any information which has been published or made available on a social
media profile or job board (whether by you or a third party), or in any news
media;
(xii)
details of your umbrella company or personal service company;
(xiii)
the contract we hold with you, your umbrella company or personal service
company relating to the work you do or will do for our client, including
timesheet data and charge rates relating to the work you perform under or as a
result of that contract;
(xiv)
details of your referees and emergency contacts;
(xv)
references from third parties such as previous employers and nominated
referees;
(xvi)
the results of pre-employment screening or vetting checks which we are
asked or required to undertake in relation to you (including the results of any
Disclosure and Barring checks and any information you provide relating to
current and/or spent criminal convictions carried out on behalf of the client
during the on boarding process);
(xvii)
Immunisation certificates
(xviii)
Health declaration form
(xix)
training certificates
(xx)
appraisal details
(xxi)
GMC or NMC documents
(xxii)
Qualifications
(xxiii)
Professional indemnity information
(xxiv)
any e mail communications, including attachments, which you send to us;
(xxv)
the results of any right to work checks we are required to carry out by
our client;
(xxvi)
your time worked on an assignment.
You can update your CV or
personal data at any time by forwarding a copy to [email protected], [email protected], [email protected]
and [email protected]
2.2
Referees and emergency contacts: the personal information we collect about you where
"you" are a referee or emergency contact. We collect basic contact
details (such as name, title, address, email and tel) so that we can contact
you for a reference or as an emergency contact for one of our
candidates/consultants.
2.3
Client contacts: the personal information we collect about you where
"you" are a contact at one of our clients or at master vendor,
umbrella company or personal service company involved in the supply of a
person's services to a hirer.
We need to collect information
about you as an essential part of providing our Services. When:
(a)
we contact you with a view to providing Services to you; or
(b)
you email us expressing an interest in working with us;
(c)
you provide us with your business card or other information provided to
us, given to our employees at sales and marketing events;
(d)
you post information or advertisements on job boards or social media
websites;
(e)
we provide Services to you as an actual or a potential hirer of your
services; or
(f)
we complete contractual documentation relevant to the Services,
we will usually collect the
following information from or about you:
(g)
your name;
(h)
your phone and e-mail details;
(i)
details of your role, title and responsibilities within your
organisation;
where "you" are a
client contact:
(j)
any opinion or feedback you share with us regarding a candidate or
consultant;
(k)
details of any queries you raise with us regarding the Services;
(l)
details of any recruitment, resourcing or consultancy requirements or
plans you share with us.
In some cases we regard you as
both a candidate and a client contact. Where this is the case please read the
sections below relating to candidates and client contacts and how we will use
your personal information.
2.4
All Visitors to our website - what
personal information we collect about you
(a)
We, or third parties on our behalf, may collect and use any of the
following information about you:
(i)
your name;
(ii)
your postal address;
(iii)
your email address;
(iv)
your telephone number;
(v)
information provided when you correspond with us;
(vi)
any updates to information provided to us;
(vii)
personal information we collect about you or that we obtain from our third
party sources;
(viii)
the following information created and recorded automatically when you
visit our website:
(A)
Technical information. This includes: the Internet protocol (IP)
address used to connect your computer to the internet address; the website
address and country from which you access information; the files requested;
browser type and version; browser plug-in types and versions; operating system;
and platform. We use this personal information to administer our website, to measure
the efficiency of our systems and to undertake an analysis on the locations
from which people access our webpages;
(B)
Information about your visit and your behaviour on our website (for
example, the pages that you click on). This may include the website you visit
before and after visiting our website (including date and time), time and
length of visits to certain pages, page interaction information (such as
scrolling, clicks, and mouse-overs), methods used to browse away from the page,
traffic data, location data, weblogs and other communication data and
information provided when requesting further service or downloads; and
(b)
How we use your personal information
We will collect, use and store the personal
information listed above for the following reasons:
(i)
to allow you to access and use our website;
(ii)
to receive enquiries from you through the website about our retirement
living services including our properties;
(iii)
for improvement and maintenance of our website and to provide technical
support for our website;
(iv)
to ensure the security of our website;
(v)
to recognise you when you return to our website, to store information
about your preferences, and to allow us to customise the website according to
your individual interests; and
(vi)
to evaluate your visit to the website and prepare reports or compile
statistics to understand the type of people who use our website, how they use
our website and to make our website more intuitive. Such details will be
anonymised as far as reasonably possible and you will not be identifiable from
the information collected.
(c)
A word about cookies
(i)
Some pages on our website use cookies, which are small files placed on
your internet browser when you visit our website. We use cookies in order to
offer you a more tailored experience in the future, by understanding and
remembering your particular browsing preferences.
(ii)
Where we use cookies on our website, you may block these at any time. To
do so, you can activate the setting on your browser that allows you to refuse
the setting of all or some cookies. However, if you use your browser settings
to block all cookies (including essential cookies), you may not be able to
access all or parts of our website or to use all the functionality provided
through our website.
(iii)
For detailed information on the cookies we use and the purposes for
which we use them, please refer to our cookies policy here
3.
How we use your personal information and our lawful bases for
processing your personal data
3.1
Candidates and consultants: we
collect, store and use information that we obtain in relation to you for our
legitimate interests:
(a)
so that we can contact you (via email, SMS, phone, WhatsApp or Skype )
about permanent and/or temporary opportunities and assignments that we believe
you will be interested in;
(b)
to assess your suitability to work in a healthcare role and to help us
to provide suitable candidates for our clients who engage us to assist them
fulfil their recruitment and resourcing requirements;
(c)
to provide a channel through which you can submit your CV for general
applications, to apply for specific jobs or to subscribe to our job alerts;
(d)
to match your details with vacancies, to assist us in finding a position
that is most suitable for you and to send your information to clients for
potential jobs. Please note that we will always obtain verbal or written
consent before presenting your personal details to a client;
(e)
to enter into and administer contracts which are necessary in order for
your services to be supplied or made available to a hirer;
(f)
to make payments, in respect of any services you provide via us to our
client, to your personal service company or umbrella company;
(g)
to provide recruitment-related support;
(h)
to notify of any communications intended for you from the hirer;
(i)
to carry out market research for our internal use;
(j)
to develop an industry-relevant database of candidates and clients to
help meet our clients' resourcing requirements and connect candidates with work
opportunities;
(k)
for internal record keeping purposes;
(l)
to carry out compliance checks to ensure that whoever is paying you is
complying with tax and national insurance law;
(m)
to carry out services that we, you or our client have requested
including work-related references, qualifications and criminal references
checking services, verification of the details you have provided from third
party sources, psychometric evaluations or skills tests;
(n)
to inform you of Medsol/GPS/HSS/TEG networking and other
career-development related events and news articles.
3.2
Clients: We will collect, use and store the personal
information listed above for the following reasons:
(a)
to provide you with our Services;
(b)
to deal with any enquiries or issues you have about our Services and/or
candidates;
(c)
to provide support for any issues you have regarding candidates and/or
consultants placed by us;
(d)
to send you certain communications (including by email or post) about
our Services such as service announcements and administrative messages (for
example, setting out changes to our terms and conditions and keeping you
informed about our fees and charges);
(e)
to carry out statistical analysis and market research;
(f)
if you have consented or, otherwise, if it is in our legitimate
interests, for business development and marketing purposes, to contact you
(including by email or post) with information about our Services and any
related events which either you request, or which we feel will be of interest
to you (including newsletters).
3.3
Prospective clients to whom we market our Services
(a)
We, or third parties on our behalf, may collect and use any of the
following information about you:
(i) your name;
(ii) your postal address;
(iii) your email address;
(iv) your telephone number;
(v) information
about your preferences
(b)
How we use your personal information
We will collect, use and store the personal
information listed above, if you have consented or, otherwise, if it is in our
legitimate interests, for business development and marketing purposes, to
contact you (including by email, telephone or post) with information about our
products and services which either you request, or which we feel will be of
interest to you (including newsletters).
3.4
People who contact us with enquiries
(a)
We will collect and use any of the following information about you:
(i) your name;
(ii) your postal address;
(iii) your email address;
(iv) your telephone number;
(v) information provided when you correspond with us;
(vi) any updates to information provided to us.
(b)
How we use your personal information
We will collect, use and store the personal
information listed above to deal with any enquiries or issues you have about
our Services any questions you may have about how we collect, store and use
your personal information, or any requests made by you for a copy of the
information we hold about you. If we do not have a contract with you, we may
process your personal information for these purposes where it is in our
legitimate interests for customer services purposes.
(c)
Source of personal information. We may receive some of your
personal information from third party sources, such as your employer or your
employer's company website. We may also collect this personal information from
publicly-available sources, such as LinkedIn.
(a)
to deal with any enquiries or issues you have about how we collect,
store and use your personal information, or any requests made by you for a copy
of the information we hold about you. If we do not have a contract with you,
we may process your personal information for these purposes where it is in our
legitimate interests for customer services purposes;
(b)
to comply with any procedures, laws and regulations which apply to us –
this may include where we reasonably consider it is in our legitimate interests
or the legitimate interests of others to comply, as well as where we are
legally required to do so;
(c)
to establish, exercise or defend our legal rights – this may include
where we reasonably consider it is in our legitimate interests or the
legitimate interests of others, as well as where we are legally required to do
so.
We will not use your personal information in any
way that is incompatible with the purposes set out in this section 3. Please
contact us using the details in section 2.1
if you want further information on the analysis we will undertake to establish
if a new use of your personal information is compatible with these purposes.
4.
Legal basis for use of your personal information
4.1
Candidates and Consultants: We consider that the legal bases for using your
personal information as set out in this privacy policy are as follows:
(a)
The storage and use of your personal information allows you to be
contacted about roles which we think will be of interest to you, now or in the
future, and we do not believe that this storage and use will unduly prejudice
your rights or freedoms.
(b)
We will store and use your personal information in order to comply with
relevant legal obligations to which Medsol/GPS/HSS/TEG is subject, including
carrying out:
(i)
verification of your identity to comply with The Conduct of Employment
Agencies and Employment Businesses Regulations 2003;
(ii)
right to work checks to comply with relevant immigration legislation;
(c)
Where you are successful in securing assignment or consultancy work with
one of our clients we will store and use your personal information for the
purposes of completing and administering contracts with your chosen personal
service company, umbrella company or consultancy company and for processing
payment to such company in respect of services you (or your consultancy) have
performed for our client. Such processing will be for our legitimate interests
so that we can provide Services to you and our client. We do not believe that
this storage and use of your personal information will unduly prejudice your
rights or freedoms.
(d)
Such processing will also be necessary for the performance of a contract
to which you are party (i.e. your contract with the company with whom you work
to provide assignment/consultancy services) and/or in order to take steps prior
to you entering into such contract, including contracts we enter into with the
client relating to the provision of your services or consultancy services.
(e)
Information about your health and medical records: we will use
your special categories of data (such as health and wellbeing information)
where you have provided your consent (which you may withdraw at any time after
giving it, as described below). Specifically we will use your health and
disability information as provided by a part of your registration including;
(i)
any updates to that information;
(ii)
your Immunisation records;
(iii)
your Occupational health
(iv)
any further information regarding your health or medical records which
come to light to us during the recruitment process or during your time on
assignment with our client(s);
(v)
any absence from work you may require due to illness or disability or
for the purpose of attending medical appointments. Such information will
typically include doctors' sick notes and hospital admission letters. We will
share this information with the relevant client.
(f)
Information about your criminal record: we will also collect
information (including from you and via DBS checks) about your criminal record,
including information about unspent and spent convictions, where you have
provided your consent (which you may withdraw at any time after giving it, as
described below). This includes:
(i)
information you provide to us in this registration form;
(ii)
any DBS check certificate(s) you provide to us;
(iii)
the results of any DBS checks we carry out on you.
We may process your personal information in some
cases for marketing purposes on the basis of your consent (which you may
withdraw at any time after giving it, as described below).
(g)
If we rely on your consent for us to use your personal information in a
particular way, but you later change your mind, you may withdraw your consent
by contacting us at [insert relevant contact details] and we will stop doing so.
However, if you withdraw your consent, this will impact the ability for us to
be able to provide our recruitment Services to you because, placing healthcare
professionals in healthcare roles requires us to use of your special categories
of data such as health information.
4.2
Our use of your personal information where "you" are a client
contact is:
(a)
necessary to perform our obligations under any contract with you (for
example, to supply our Services to you, to comply with the terms of use of our
website which you accept by browsing our website and/or to comply with our
contract to provide services to you); or
(b)
necessary for complying with our legal obligations (for example, to
comply with our obligations under the Conduct of Employment Agency and
Employment Businesses Regulations 2003, immigration law and tax law); or
(c)
where neither (i) nor (ii) above apply, use of your personal information
is necessary for our legitimate interests or the legitimate interests of others
(for example, to ensure the security of our website). Our legitimate interests
are to:
(d)
send you the details of candidates and consultants and contact you about
our Services;
(e)
contact you to receive and administer any Services which your
organisation has requested.
(f)
run, grow and develop our business relationship with you;
(g)
operate our website;
(h)
select appropriately skilled and qualified candidates;
(i)
marketing, market research and business development;
(j)
provide recruitment Services to our Clients make and receive payment and
provide customer services;
(k)
place, track and ensure fulfilment of orders with our suppliers; and
(l)
for internal group administrative purposes.
(m)
In the case of contacts at umbrella companies and personal service
companies this allows you to be contacted to receive details of current and
future assignments, related timesheet data and payment details.
4.3
We do not believe that this storage and use of your personal information
will unduly prejudice your rights or freedoms.
4.4
If we rely on our (or another person's) legitimate interests for using
your personal information, we will undertake a balancing test to ensure
that our (or the other person's) legitimate interests are not outweighed by
your interests or fundamental rights and freedoms which require protection of
the personal information. You can ask us for information on this balancing
test by using the contact details at section 13.
5.1
We may share your personal information between Medsol, GPS, HSS and TEG
and with our group companies where it is in our legitimate interests to run,
grow and develop our business and for internal administrative purposes (for
example, ensuring consistent and coherent delivery of our Services to
candidates and clients, corporate strategy, compliance, auditing and
monitoring, research and development and quality assurance).
5.2
Where personal information is shared with clients, hirers, umbrella
companies, personal services companies or managed service providers in the
circumstances described above, then those organisations will handle your
personal information in line with their own privacy policies.
5.3
We will disclose information under the following circumstances:
(a)
Service and website usage information: When we share anonymous
information generated by our Services with our clients.
(b)
Third-party service providers: When we share information with
third-party service companies for them to facilitate and support us in the
provision of the Services. This includes:
(i)
IT support service providers;
(ii)
providers of credit reference, vetting and screening services;
(iii)
payment processors and software providers;
(iv)
CV formatting service providers.
5.4
These organisations are appointed by Medsol/GPS/HSS/TEG as data
processors and authorised to use your personal information only as necessary to
provide the relevant services to us. These organisations are required to
process such information based on our instructions and in accordance with this
privacy policy. They do not have any independent right to share this
information.
5.5
Group companies: We provide your personal information to our
subsidiaries or affiliated companies for the purpose of processing personal
information on our behalf to provide the Site and the Services. These parties
are required to process such information based on our instructions and in
accordance with this privacy policy. They do not have any independent right to
share this information.
5.6
Compliance with laws and legal proceedings: When we have a legal
duty to respond to court orders, or legal process, or to establish or exercise
our legal rights or defend against legal claims. When we believe it is
necessary to share information in order to investigate, prevent or take actions
against illegal activities, suspected fraud, situations involving potential
threats to the physical safety of any person, violations of our terms of use,
or as otherwise required by law.
5.7
To enforce or apply our terms and conditions or any other
agreement or to respond to any claims, to protect our rights or the rights of a
third party, to protect the safety of any person or to prevent any illegal
activity.
5.8
To protect the rights, property, or safety of Medsol/GPS/HSS/TEG, our
staff, our clients or other persons. This may include exchanging personal
information with other organisations for the purposes of fraud protection and
credit risk reduction.
5.9
Merger or acquisition: When we need to transfer information about
you if we are acquired by or merged with another company. If we are involved
in a merger, acquisition, or sale of all or a portion of its assets, you will
be notified by email and/or a prominent notice on our Site of any change in
ownership or uses of your personal information, as well as any choices you have
regarding your personal information.
If we disclose personal data to a prospective
purchaser of our business or any part of it we will ensure that your privacy is
protected.
5.10
Recruitment, resourcing and consultancy services: When we are
using your personal information in the context of our recruitment, resourcing
or consultancy services, then we will share your personal information with
clients where we believe that you or your consultancy services will be
appropriate for a particular role or vacancy with that client.
5.11
Umbrella companies, personal service companies consultancy
companies: When you inform us that you are supplying or intend to supply
your services via Medsol/GPS/HSS/TEG to a client through an umbrella company, personal
service company or consultancy company.
5.12
Recruitment Process Outsourcing and Master Vendors: In certain
cases, an organisation such as a master vendor will act as a gateway for the
supply of Services made via Medsol/GPS/HSS/TEG to the hirer. Where this is the
case, we will share your information with such organisations to the extent that
it is necessary for the purposes of the Services.
5.13
Any third parties with whom we share your personal information are
limited (by law and by contract) in their ability to use your personal
information for any purpose other than to provide services for us. We will
always ensure that any third parties with whom we share your personal
information are subject to privacy and security obligations consistent with
this privacy policy and applicable laws.
5.14
We may also disclose and use anonymised, aggregated reporting and
statistics about users of our website or our goods and services for the purpose
of internal reporting or reporting to our group or other third parties, and for
our marketing and promotion purposes. None of these anonymised, aggregated
reports or statistics will enable our users to be personally identified.
5.15
Save as expressly detailed above, we will never share, sell or rent any
of your personal information to any third party without notifying you and,
where necessary, obtaining your consent. If you have given your consent for us
to use your personal information in a particular way, but later change your
mind, you should contact us and we will stop doing so.
6.
How long we store your personal information
We keep your personal information for no longer
than necessary for the purposes for which the personal information is
processed. The length of time we retain personal information for depends on
the purposes for which we collect and use it and/or as required to comply with
applicable laws and to establish, exercise or defend our legal rights.
7.
Your rights
7.1
You have certain rights in relation to your personal information. If you
would like further information in relation to these or would like to exercise
any of them, please contact us via email at [email protected], [email protected], [email protected]
and [email protected]
at any time. You have the following rights:
(a)
Right of access. You have a right of access to any personal
information we hold about you. You can ask us for a copy of your personal
information; confirmation whether your personal information is being used by
us; details about how and why it is being used; and details of what safeguards
are in place if we transfer your information outside of the European Economic
Area ("EEA").
(b)
Right to update your information. You have a right to request an
update to any of your personal information which is out of date or incorrect.
(c)
Right delete your information. You have a right to ask us to
delete any personal information which we are holding about you in certain
specific circumstances. You can ask us for further information on these
specific circumstances by contacting us using the details in section 13.
We will pass your request onto other recipients of your
personal information unless that is impossible or involves disproportionate
effort. You can ask us who the recipients are using the contact details in
section 13.
(d)
Right to restrict use of your information: You have a right to
ask us to restrict the way that we process your personal information in certain
specific circumstances. You can ask us for further information on these
specific circumstances by contacting us using the details in section 13.
We will pass your request onto other recipients of
your personal information unless that is impossible or involves
disproportionate effort. You can ask us who the recipients are using the
contract details in section 13.
(e)
Right to stop marketing: You have a right to ask us to stop using
your personal information for direct-marketing purposes. If you exercise this
right, we will stop using your personal information for this purpose.
(f)
Right to data portability: You have a right to ask us to provide
your personal information to a third party provider of services.
This right only applies where we use your personal
information on the basis of your consent or performance of a contract; and
where our use of your information is carried out by automated means.
(g)
Right to object. You have a right to ask us to consider any
valid objections which you have to our use of your personal information where
we process your personal information on the basis of our or another person's
legitimate interest.
7.2
We will consider all such requests and provide our response within a
reasonable period (and in any event within one month of your request unless we
tell you we are entitled to a longer period allowed by applicable law). Please
note, however, that certain personal information may be exempt from such
requests in certain circumstances, for example if we need to keep using the
information to comply with our own legal obligations or to establish, exercise
or defend legal claims.
7.3
If an exception applies, we will tell you this when responding to your
request. We may request you provide us with information necessary to confirm
your identity before responding to any request you make.
8.
Marketing
8.1
We may collect and use your personal information for undertaking
marketing by email telephone and post.
8.2
We may send you certain marketing communications (including electronic
marketing communications to existing customers) if it is in our legitimate
interests to do so for marketing and business development purposes.
8.3
However, we will always obtain your consent to direct marketing
communications where we are required to do so by law and if we intend to
disclose your personal information to any third party for such marketing.
9.
Where we may transfer your personal information
9.1
Your personal information may be used, stored and/or accessed by staff
operating outside the EEA working for us, other members of our group or
suppliers. If we have obtained consent to contact a referee outside of the EEA
then we will pass on the necessary data to obtain the reference. Further
details on to whom your personal information may be disclosed are set out in section
5.
9.2
If we provide any personal information about you to any such non-EEA
members of our group or suppliers, we will take appropriate measures to ensure
that the recipient protects your personal information adequately in accordance
with this privacy policy. These measures may include the following permitted
in Articles 45 and 46 of the General Data Protection Regulation:
(a)
in the case of US based entities, entering into European Commission
approved standard contractual arrangements with them, or ensuring they have
signed up to the EU-US Privacy Shield (see further https://www.privacyshield.gov/welcome);
or
(b)
in the case of entities based in other countries outside the EEA,
entering into European Commission approved standard contractual arrangements
with them.
9.3
Further details on the steps we take to protect your personal
information, in these cases is available from us on request by contacting us by
email at [email protected], [email protected], [email protected]
and [email protected]
at any time.
10.
Risks and how we keep your personal information secure
10.1
The main risk of our processing of your personal information is if it is
lost, stolen or misused. This could lead to your personal information being in
the hands of someone else who may use it fraudulently or make public
information that you would prefer to keep private.
10.2
For this reason, Medsol/GPS/HSS/TEG is committed to protecting your personal
information from loss, theft and misuse. We take all reasonable precautions to
safeguard the confidentiality of your personal information, including through
use of appropriate organisational and technical measures. For example physical
access controls to premises, staff training, locking files away, ISO
accreditation, encryption, passwords for systems access, anti-virus software.
10.3
In the course of provision of your personal information to us, your
personal information may be transferred over the internet. Although we make
every effort to protect the personal information which you provide to us, the
transmission of information over the internet is not completely secure. As
such, you acknowledge and accept that we cannot guarantee the security of your
personal information transmitted to our website and that any such transmission
is at your own risk. Once we have received your personal information, we will
use strict procedures and security features to prevent unauthorised access to
it.
10.4
Where we have given you (or where you have chosen) a password which
enables you to access your online account, you are responsible for keeping this
password confidential. We ask you not to share a password with anyone.
11.
Links to other websites
Our website may contain hyperlinks to websites that
are not operated by us. These hyperlinks are provided for your reference and
convenience only and do not imply any endorsement of the activities of such
third-party websites or any association with their operators. This privacy
policy only applies to the personal information that we collect or which we
receive from third party sources, and we cannot be responsible for personal information
about you that is collected and stored by third parties. Third party websites
have their own terms and conditions and privacy policies, and you should read
these carefully before you submit any personal information to these websites.
We do not endorse or otherwise accept any responsibility or liability for the
content of such third party websites or third party terms and conditions or
policies.
12.
Changes to our privacy policy
We may update our privacy policy from time to time. Any changes we make
to our privacy policy in the future will be posted on this page and, where
appropriate, notified to you by post or email. Please check back frequently to
see any updates or changes to our privacy policy.
13.
Further questions and how to make a complaint
13.1
If you have any queries or complaints about our collection, use or
storage of your personal information, or if you wish to exercise any of your
rights in relation to your personal information, please contact [email protected], [email protected], [email protected]
and [email protected].
We will investigate and attempt to resolve any such complaint or dispute
regarding the use or disclosure of your personal information.
13.2
In accordance with Article 77 of the General Data Protection Regulation,
you may also make a complaint to the Information Commissioner's Office, or the
data protection regulator in the country where you usually live or work, or
where an alleged infringement of the General Data Protection Regulation has
taken place. Alternatively, you may seek a remedy through the courts if you
believe your rights have been breached.
The practices described in this
privacy policy statement are current as of 23rd May 2018.