Welcome to HealthCare21’s privacy notice
HealthCare21 (HC21) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our websites (regardless of where you visit it from) or when you otherwise provide personal data to us via other means (such as email), and will tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so that you can easily click through to the specific areas set out below.
Please also refer to the Glossary that we have set out at the end of the Policy, if there is any terminology used in this privacy notice that you are unfamiliar with or that you don’t fully understand.
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how HC21 collects and processes your personal data, including any data you may provide through our website or via any other means (such as through email). This website is not intended for children and we do not collect data in relation to children.
It is important that you read this privacy notice, together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you. This way, you will be fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
This privacy notice is issued on behalf of HealthCare21 as the legal entity: when we refer to ‘HC21’, ‘we’, ‘us’ or ‘our’ in this privacy notice, we are referring to one of these legal entities responsible for processing your data. We will let you know which entity will be the controller for your data when you contact us. We have appointed a data protection officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data protection officer at the address below:
Data Protection Officer
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 (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. Our ICO registration number is: Z3042626.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 12 June 2018. It is important that the personal data we hold about you is accurate and current. Please keep us informed if any of the details you provide to us should change, during the course of your relationship with us.
This 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 notice 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). We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together follows:
(A) Identity data: This includes data relating specifically to your identity, such as your first name, maiden name, last name or similar identifier, marital status, title, date of birth and gender.
(B) Contact data: This includes data relating to how you may be contacted, such as your home address, work address, email address and telephone numbers.
(C) Financial data: This includes data relating to your means and methods of payment, such as your bank account and payment card details.
(D) Transaction data: This includes data relating to the transactions that we may have paid to you for services you have provided HealthCare21 with, or for consultancy services on behalf of our clients.
You may opt out of Google Analytics by visiting: https://tools.google.com/dlpage/gaoptout?hl+en=GB.
Special categories of personal data
3. How your personal data is collected?
Data is collected from you through a variety of direct interactions:
You may give us your identity, contact and financial data by filling in forms or by corresponding with us by email, phone, text, post or otherwise. This includes personal data you provide when you:
- make a job application
- become an employee (either full time, part time or as freelancer)
- request travel arrangements
- provide bank details for honoraria/expenses claims.
4. How we use your personal data
We will only use your 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/employment agreement we are about to enter into or have entered into with you
- 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.
You have the right to withdraw consent to us processing your personal data at any time by contacting us.
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 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 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. Examples of where we may process on 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|
|Employment/processing payroll/salary||Identity/Contact/Financial||Performance of a contract|
|To process and confirm travel and accommodation requirements||Identity/Contact||Performance of a contract|
|To process honoraria and expense claim forms as a third party||Identity/Contact/Financial||Performance of a contract|
|To use data analytics to improve our website and user experience||Technical/Usage||Necessary for our legitimate interests (to keep our website updated and relevant to develop our business)|
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 request 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 data with the parties set out below for the purposes set out in the table above. In addition:
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
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
Sometimes we need to work with external third parties who are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. For example, this could occur if we are working with a client preferred travel agency based in the United States (US). Where you have requested a booking for travel arrangements that are located or otherwise due to be fulfilled outside the EEA, we will have to transfer your personal data to the suppliers fulfilling or providing those travel arrangements outside the EEA in order to make your booking and for those suppliers to be able to provide you with the travel arrangements you have booked. For example, we may need to work with a travel partner based in the US. Where we are unable to rely on one of the safeguards outlined below when transferring data to those suppliers outside the EEA, we will rely on the derogation under Article 49 of the GDPR in order to transfer your personal data to countries outside the EEA (as the transfer relates to the performance of a contract for your benefit), and you hereby permit us to do so. You also acknowledge that when your personal data is transferred outside the EEA, controls on data protection may not be as wide as the legal requirements within the EEA. For all other transfers of data, whenever your personal data is transferred outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. HC21 uses a confidential waste service to destroy all material containing confidential details. In addition, we limit access to your 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? We will securely retain your personal data for up to five years to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. By law we have to keep basic information about our employees, workers, freelancers and anyone else whose details are obtained through the natural course of project work (including contact, identity, financial and transaction data) for five years after they cease being active for legal and tax purposes. In some circumstances, you can ask us to delete your data: see request erasure below for further information.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see sections below to find out more about these rights:
(A) Request access to your personal data.
(B) Request correction of your personal data.
(C) Request erasure of your personal data.
(D) Object to processing of your personal data.
(E) Request restriction of processing your personal data.
(F) Request transfer of your personal data.
(G) Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us. 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 would try to respond to all legitimate requests within one week. 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.
Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure that 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 personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
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.
Internal third parties
Other companies in the HealthCare21 Holdings acting as joint controllers or processors and who are based in the United Kingdom and provide IT and system administration services and undertake leadership reporting.
External third parties
i. Suppliers of travel services acting as processors, such as hotels, airlines and transport providers based both within and outside the EEA and who provide the travel services that make up any booking of travel/accommodation arrangements that we make on your behalf.
ii. Service providers acting as processors based within and outside the EEA who provide IT and system administration services.
iii. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based within the EEA who provide consultancy, banking, legal, insurance and accounting services.
iv. 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.
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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.