About us

HFHC Healthcare Limited is a company registered in England and Wales with registered number 05738967 and our registered office is at 55 Loudoun Road, St Johns Wood, London NW8 0DL.

We are registered with the Information Commissioner’s Office and we will be the ‘data controller’ for the purposes of data protection law in relation to any personal information we hold about you.

We are committed to maintaining high standards of confidentiality in relation to the information provided to us in the course of our business.

This privacy policy is designed to provide information about our practices concerning the collection, use and disclosure of personal information in the course of our business. We specialise in Complex Care, Elderly Care, Dementia Care, End of Life Care, Palliative Care, Mental Health and Learning Disability Support delivering care and support to people in their own homes as well as to care organisations looking for specialist staff.

Privacy Notice Clients

Privacy Notice Marketing

Privacy Notice Employees and Agency Workers

Privacy Notice Recruitment

Privacy Notice Clients

1. Who this privacy notice applies to

This privacy notice applies to all persons whose personal information we collect and process (except in connection with our marketing activities and our employment practices) in the course of our business of providing care and support workers to our clients.

This includes the individuals and organisations listed below or individuals who work for any of the following organisations or bodies:

  • Individual Clients or prospective clients
  • Families of Individual Clients
  • Establishment Clients or prospective clients
  • Commissioners or prospective Commissioners
  • Our regulators, insurers, auditors, professional advisers and certification/accreditation bodies.

2. Information we may collect and process

In the course of our business, we will need to collect and process various types of personal information for various purposes. We may obtain personal data from a variety of sources, but primarily from those referred to in section 1 above.

Given the nature of our business and the services we provide, we actually collect a very limited amount of data from you. What we do collect and process are your contact details, contact details of individuals within your organisation and information relating to the services you may wish us to provide and we collect the information in order to ensure the smooth and efficient provision of our services, either with your specific consent, to the extent required, or where we have a legal basis to do so.

3. How we use and disclose information collected

Where we receive personal data in connection with the provision of our business of supplying agency workers we process that data for the purposes of:

  • matching Clients with a suitable pool of care and support workers;
  • preparing appropriate contract documentation with our Clients;
  • undertaking Client satisfaction surveys;
  • storing your information so we can contact you in relation to recruitment and marketing initiatives;
  • complying with our legal obligations or making disclosures to government, regulatory or other public bodies where in our reasonable opinion the disclosure is appropriate and permitted by law including:
  • disclosures required by law or court order;
  • disclosures to the police, tax authorities, the National Crime Agency or other public or government authorities where in our reasonable opinion the disclosure is required in relation to any criminal investigation or prosecution;
  • disclosures to our regulators, ombudsman or other government, public or regulatory authority, including any data protection supervisory authority or regulator of residential care service, where in our reasonable opinion the disclosure is required or permitted by law;
  • Providing access to our files for audit, review or other quality assurance checks, by our regulators, auditors, professional advisers and certification/accreditation bodies;
  • Processing required in connection with the day to day operation of our business;
  • Processing required in connection with any actual or proposed reorganisation, merger, sale, joint venture, assignment, transfer or other transaction relating to all or any portion of our business or assets.

We share personal information with our group and associated companies. Other than these entities we will only share personal information with third parties, where we have a legitimate business interest in doing so and will only do so where in our reasonable opinion that information will be adequately protected; where they are approved by us and subject to contractual obligations designed to ensure compliance with data protection legislation.

It is not our intention to transfer your data out of the EEA.

4. How long we keep personal information

We retain personal data in accordance with our retention and destruction policy.

5. How we protect personal information

We are strongly committed to data security and we take reasonable and appropriate steps to protect the personal information we hold from unauthorised access, loss, misuse, alteration or corruption. We have put in place physical, electronic and managerial procedures to safeguard and secure that information.

6. The legal basis for processing personal information

Data protection law requires us to have a legal basis for processing your information. In most cases we will only process your personal information:

  • so we can provide you with a suitable pool of candidates;
  • carry out our contract with you;
  • take any steps you ask us to before entering into a contract with you;
  • where necessary for our legitimate purposes in providing agency worker to our Clients.

When processing personal data we comply with the data protection principles and our own data protection standard. By doing so we consider that the interests and fundamental freedoms of people whose personal data we process do not override the pursuit of our legitimate interests and/or those of our Clients and our agency workers.

7. Rights of data subjects

You have a number of rights. You may:

  • request a copy of the personal data we hold about you;
  • you may object to our processing of it or ask us to rectify it, restrict the way in which we process it or erase it from our records;
  • complain about the way in which we process or have processed your data.

For further information about your rights, or how to exercise them, including how to make a complaint, you should contact our Data Compliance Officer.

If you remain dis-satisfied you may lodge a complaint with the Information Commissioner’s Office.

8. Complaints

If you have any cause for concern about our handling of personal information, please contact us using the details below.

If we are unable to resolve your concerns about our handling of personal information, you have the right to complain to the Information Commissioner’s Office.

9. Contact details

Please read this notice carefully and contact us if you have any queries by emailing us at compliance@hfhchealthcare.com.

Or by writing to:
HFHC Healthcare Compliance Team, PO Box 4412, Wells, Somerset, BA5 9AH.

Or by telephone to:
01522 246 454

This privacy notice may change from time to time so we recommend that you review it periodically. This version of the privacy notice was last updated on 6th June 2019.

Privacy Notice Clients

Privacy Notice Marketing

Privacy Notice Employees and Agency Workers

Privacy Notice Recruitment

Privacy Notice Marketing

Introduction

This notice sets out how we use (and protect) your personal information for the purposes of keeping in touch – including data which we gather from you with your consent, whether from the use of our website, attendance at events organised by us or events organised by others on our behalf, from third parties or provided by you to us on other occasions

HFHC Healthcare is the Data Controller for personal information relating to people who have:

  • asked to be informed about our activities
  • asked to be kept up-to-date with our initiatives
  • agreed to receive newsletters from us
  • asked to receive marketing literature from us
  • taken part in marketing events organised by us or on our behalf
  • accessed our website

We do not trade personal information for commercial purposes. We do share personal information with our subsidiary and associated companies with whom we work closely. Other than to them, we will only disclose personal information to third parties for marketing purposes if:

  • required or authorised by law
  • necessary to arrange attendance at an event
  • we have your specific consent

We do not intend to transfer any personal information used or stored for marketing processes outside of the EU.

Read more about how we collect your personal information

When you subscribe to events at which we are taking part, newsletters, updates from us or simply tell us that you would like to know more about what we do, we will ask for your:

  • name
  • company name if appropriate
  • postal address
  • email address
  • telephone numbers

If you attend an event, we will collect this information from you in person at the event or otherwise when you indicate by whatever other means that you would like to be added to our mailing lists and to receive information about what we do, the events we are taking part in, our newsletters, new initiatives and industry updates. By subscribing to our mailing lists you will be automatically subscribed to receive email and/or postal updates depending on your preferences.

We also collect information about you when you fill in our ‘Contact Us’ page on our website. Website usage information is collected using cookies, this is not personally identifiable.

If you send us a message through our ‘Contact Us’ page we will enter your information into an internal CRM system. We will then use this to contact you about your enquiry.

Read more about how we use the personal information we collect

Our use and storage of your personal information for keeping you up to date is however based on your consent. This means that you will only receive information by post and/or email that you have asked to receive. You can withdraw your consent or change your preferences at any time, by telephoning us on 01522 716525, clicking ‘unsubscribe’ on any of our emails, by writing to us by post to Compliance, HFHC Healthcare Limited, Social Care Exchange, 1, Low Moor Road, Lincoln, LN6 3JY or by emailing us at compliance@hfhchealthcare.com.

If you unsubscribe from our emails or withdraw your consent for us to contact you, we will nonetheless store your information for a period of two years to ensure that you no longer receive emails from us. More information about how long we store information is available in our retention policy.

How we securely store your personal information

We take your privacy and security very seriously. With this in mind, we will treat your data with the utmost care and take all appropriate steps to protect it.

We have internal policies, procedures and controls in place to prevent your data being lost, accidentally destroyed, misused or disclosed.

Website visitors

Our website places cookies (text files) on your computer. The cookies contain an ID number which is used to uniquely identify your browser and track each site you visit that has Google Analytics enabled.

We use the information provided by cookies to determine the number of people visiting our site. It also helps us to better understand how people find and use our website. With this information we can continually improve our website and service.

Our cookies are operated by WordPress and Google Analytics and store the following data:

  • time of visit, pages visited, and time spent on each page of the website
  • interactions with site-specific widgets
  • referring site details (such as the URL a user came through to arrive at the website)
  • type of web browser
  • type of operating system (OS)
  • flash version, JavaScript support, screen resolution, and screen colour processing ability
  • network location and IP address
  • document downloads
  • clicks on links leading to external websites
  • errors when users fill out forms
  • clicks on videos
  • ‘scroll depth’ (how far you scroll up or down on a page).

If you already have Google Analytics cookies, they will be updated with the latest information about your visit to our website. We cannot access these cookies and are not the data controller for information held by Google Analytics.

Your consent is generally required for cookies to be placed on your computer and for the use and storage of personal information relating to you provided by the cookies. You may withdraw your consent at any time by updating your cookie settings. Where consent is not needed for cookies to be placed on your computer (for example, where a cookie is needed for the operation of our website or for the provision of a service to you), the use and storage of any personal information provided by the cookies will be based on legitimate interests. The legitimate interests we are pursuing are the operation of our website and promotion of our business. A link to our full cookie policy can be found here.

Your rights

If we process your personal data, you have a number of rights. You may request a copy of the personal data we hold about you (and request that that data be provided in a portable format) and you may object to our processing of it (including by way of direct marketing) or ask us to rectify it, restrict the way in which we process it or erase it from our records.

Where we use or store personal information relating to you, you have the following rights:

  • the right to be informed how personal information relating to you is being used or stored (which is what this privacy notice is for)
  • the right to access personal information relating to you which we use or hold
  • the right to object to our keeping in touch (either by using the unsubscribe button or clicking here)
  • the right to object to processing carried out on the basis of legitimate interests
  • the right to erasure of information relating to you that we use or hold (only in some circumstances)
  • the right of data portability
  • the right to have your data rectified if its inaccurate
  • the right to have your data restricted or blocked from processing.

Please be aware that these rights are not always absolute and there may be some situations in which you cannot exercise them or they are not relevant. To help you understand how they work, we have provided link to the Information Commissioner’s Office’s guidance on each of the rights here. 

Complaints

If you have any cause for concern about our handling of personal information, please contact us using the details below.

If we are unable to resolve your concerns about our handling of personal information, you have the right to complain to the Information Commissioner’s Office.

Contact details

Please read this notice carefully and contact us if you have any queries by emailing us at compliance@hfhchealthcare.com.

Or by writing to:

Compliance, HFHC Healthcare Limited, Social Care Exchange, 1, Low Moor Road, Lincoln, LN6 3JY

Or by telephone to:

01522 716525

This privacy notice may change from time to time so we recommend that you review it periodically. This version of the privacy notice was last updated on 6th June 2019.

Privacy Notice Clients

Privacy Notice Marketing

Privacy Notice Employees and Agency Workers

Privacy Notice Recruitment

Privacy Notice Employees and Agency Workers

Data controller: HFHC Healthcare Limited (Company Number: 05738967 ) (HFHC HEALTHCARE)

Data Protection Compliance Officer: Steve Cranston

1. Introduction

HFHC HEALTHCARE is a “data controller”.  This means that we are responsible for deciding how we hold and use personal information about you.

HFHC HEALTHCARE collects, stores and processes personal data relating to its employees and other individuals who undertake work for it as independent contractors or consultants, in order to manage the employment or other working relationship. This privacy notice sets out how HFHC HEALTHCARE collects and uses personal information about you prior to, during and after your working relationship with us.  The personal information may be held by HFHC HEALTHCARE on paper or in electronic format. 

This privacy notice applies to current and former employees, workers, trainees (including graduate trainees), contractors and consultants, volunteers, internships and work experience placements, throughout this notice referred to collectively as “employees”. This notice does not form part of a contract of employment or any contract to provide services and may be updated at any time.

HFHC HEALTHCARE is committed to protecting the privacy and security of your personal information and to meeting its data protection obligations under the General Data Protection Regulation (“GDPR”). HFHC HEALTHCARE is committed to being clear and transparent about how it collects and uses that data and to meeting its data protection obligations.

The purpose of this Privacy Notice is to make you aware of how and why we will collect and use your personal information both during and after your working relationship with HFHC HEALTHCARE.

2. Data Protection Principles

  1. HFHC HEALTHCARE complies with data protection law. This means that the personal information we hold about you must be:
  • Used lawfully, fairly and in a transparent way;
  • Collected only for valid purposes that we have explained to you clearly and not used in any way that is incompatible with these purposes;
  • Relevant to the purposes we have told you about and limited to those purposes only;
  • Accurate and kept up to date;
  • Kept only for such time as is necessary for the purposes we have told you about; and
  • Kept securely.

3. What Information Does HFHC HEALTHCARE Collect and Process?

HFHC HEALTHCARE collects and processes a range of personal information (personal data) about you. Personal data means any information which relates to you and from which you can be identified. This includes information set out in Schedule 1 to this Notice. 

We may also collect, store and use the special categories of more sensitive personal information which are set out in Schedule 2 to this Notice.

HFHC HEALTHCARE collects this information in a variety of ways. For example, data is collected through the application and recruitment process and during work-related activities throughout your period of working for us.

In some cases, HFHC HEALTHCARE collects personal data about you from third parties, such as references supplied by former employers, information from employment background check providers, information from credit reference agencies and information from criminal records checks permitted by law.

We will collect additional personal information throughout your period of employment or engagement (referred to collectively throughout this notice as employment) with us which may be collected during the course of your work-related activities. 

Whilst some of the personal information you provide to us is statutory and/or mandatory or a contractual requirement, some of it you may be asked to provide to us on a voluntary basis.  We will inform you whether you are required to provide certain personal information to us or if you have a choice in this. 

Data (including Personal Data) is collected and stored in a range of different ways and places through/on our digitally enabled IT platform Zone Standard. This enables us   and any other companies in the group of companies of which HFHC HEALTHCARE forms part or any associated company (Group) that you have dealings with either now or in the future  to manage both our obligations to you and your employment relationship with us/ the Group.

4. Why Does HFHC HEALTHCARE Process Personal Data?

HFHC HEALTHCARE needs to process personal data to enter into its contract with you and for both parties to meet their obligations under the contract.

In addition, HFHC HEALTHCARE needs to process personal data to ensure that we are complying with our legal obligations, for example, we are required to check an employee’s entitlement to work in the UK. For certain positions, it is necessary to carry out criminal records checks to ensure that individuals are permitted to undertake a particular role given the nature of our organisation due to the nature of its work with vulnerable adults.

Additionally, HFHC HEALTHCARE has a legitimate interest in processing personal data before, during and after the end of the employment relationship.

We collect data through our digitally enabled IT platform Zone Standard as an integral part of HFHC’s everyday operations and processes. We use this data to continually improve our processes and develop the way we operate our model of care. This may impact on you, our staff, the individuals we support and their families, our commissioners and regulators.

Against this background, we will process your personal information relying on one or more of the following grounds:

  • Where we need to do so to perform the employment contract, casual worker agreement, consultancy agreement or contract for services we have entered into with you;
  • Where we need to comply with a legal obligation (such as where laws or regulations may require us to use your personal information in certain ways);
  • Where we need to comply with our contractual obligations including to those to whom we are contracted to provide a service, for example those who commission with us or to whom we supply temporary workers;
  • Where it is necessary in any of:
    • our legitimate interests;
    • the legitimate interests of those we are commissioned to support, their families, our commissioners and regulators;
    • the legitimate interests of any other third party
  • and your interests or your fundamental rights and freedoms do not override these interests. When relying on this ground we will carry out a balancing test of our interests in using your personal information against the interests you have as an employee and the rights you have under data protection laws;
  • Where it is necessary to establish, exercise or defend a legal claim including if you, we or an Establishment or an Individual we Support brings a legal claim or a claim is brought against you, us or an Establishment or Individual we Support we may use personal data in either establishing our position or defending ourselves in relation to that legal claim or in order to establish our position or defend ourselves;
  • In certain circumstances we may need your consent unless authorised by law in order to use personal information about you which is classed as special category data.

We may occasionally use your personal information where we need to protect your vital interests or someone else’s, such as the Individuals we Support. 

5. Situations in Which We Will Use Your Personal Information

Situations in which we anticipate we may  process your personal information are set out in Schedule 3 to this Notice:

Please note that we may process your personal information without your consent provided we process that information lawfully.

6. If You fail to Provide Personal Information

If you do not prove certain information when requested, HFHC HEALTHCARE may not be able to perform the contract we have entered into with you, such as paying you or providing a benefit.  You may also have to provide HFHC HEALTHCARE with data in order to exercise statutory rights, for example in relation to statutory leave entitlements, without the provision of that information, you may also be unable to exercise your statutory or contractual rights. 

7. Change of Purpose

HFHC HEALTHCARE will only use your personal information for the purpose for which it was collected unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.  If we need to use your personal information for an unrelated purpose, we will advise you of this and explain the legal basis which allows us to do so.

You should be aware that we may process your personal information without your knowledge or consent where this is required or permitted by law.  We may also issue a new Privacy Notice to you.

8. How We Use Sensitive Personal Information

Some special categories of personal data, such as information about health or medical conditions, is processed to carry out employment law obligations (for example, in relation to employees with disabilities and for health and safety purposes).

HFHC HEALTHCARE uses other special categories of personal data, such as information about ethnic origin, sexual orientation, health or religion or philosophical belief, this is only done for the purposes of processing set out in Schedule 4 to this Notice.

Where data is used by HFHC HEALTHCARE for the purposes of equal opportunities reporting, recording and monitoring, data is anonymised or is collected with your express consent it can be withdrawn at any time. You are entirely free to decide whether or not to provide such data and there are no consequences of failing to do so.

HFHC HEALTHCARE is required to obtain details about past criminal convictions as a condition of employment.  HFHC HEALTHCARE also undertakes DBS checks on all staff due to the nature of its work supporting vulnerable adults. 

There are occasions when HFHC HEALTHCARE will need to share special data with work colleagues within HFHC HEALTHCARE for example Occupational Health Services may seek information from other teams or share information with the HR Team about fitness to work.  HFHC HEALTHCARE will only process this data with your explicit consent; this means you will be asked specifically for your permission for disclosure of such special data. 

Circumstances may also arise where special data is shared within HFHC HEALTHCARE without first obtaining your explicit consent. The circumstances when we can do this are set out in Schedule 5 of this document.

Information About Criminal Convictions

We envisage that we will hold information about criminal convictions to the extent necessary to confirm whether a DBS criminal record check has returned a satisfactory or unsatisfactory result.

There may though be exceptional circumstances where the information in the criminal record check has been assessed by HFHC HEALTHCARE or HFHC HEALTHCAREs regulatory body, the Care Quality Commission (CQC) as relevant to the ongoing working relationship. If it has been assessed as relevant to the ongoing working relationship, a DBS criminal record check will be deleted following the next CQC Audit or once the conviction is “spent” if earlier (information about spent convictions may be retained where your role is an excluded occupation or profession).

We will only collect information about criminal convictions if it is appropriate given the nature of your role and where we are legally able to do so. We will use information about criminal convictions in the following ways:

  • In compliance with CQC requirements to check the suitability of all staff ensuring recruitment practices are effective and safe;
  • In compliance with CQC requirements to ensure renewal of the DBS check to maintain assurances as to the suitability of staff.

9. Automated Decision-Making

Our employment decisions are not based on automated decision-making.

10. For How Long Do You Keep Data?

HFHC HEALTHCARE will only hold your personal data for as long as is necessary to fulfil the purposes we collected it for, including any legal, accounting, regulatory or reporting requirements. The periods for which your data is held after the end of employment is generally 6 years although further guidance on retention periods is set out in our Retention Notice.

11. Who Has Access to Data?

HFHC HEALTHCARE is part of a Group and we will share information (including personal data) between the members of the Group on a need to know basis; this may include sharing your personal data with functions such as legal, accounting and internal audit.  Your information will be shared internally as set out in Schedule 6.

HFHC HEALTHCARE shares your personal data with third parties where required by law, where it is necessary in order to administer the working relationship with you, in order to deliver our services in accordance with our model of care or where we have another legitimate interest in doing so.  

Services carried out for us by third party service providers are set out in Schedule 7.

Our business is in supplying temporary and in some cases permanent staff to our clients. HFHC HEALTHCARE shares your data with clients and commissioners and regulators as well as with the families of the individuals we support in their own homes and our advisers/consultants/insurers. The content of staff profiles can vary client by client. Usually it is data that you have already given to us which we will share with clients, commissioners and regulators. We usually  share data with commissioners and regulators as part of a contract monitoring or compliance visit or inspection and supply information which is necessary to secure an assignment. If we are asked to provide information to a client/commissioner or regulator that we do not hold, we will ask you for that information and if applicable to consent to it being shared at the time we are asked to provide it.

HFHC HEALTHCARE may also share your data with other third parties where we consider we have a legitimate interest in so doing. One example would be in the context of a sale of some or all of its business. In those circumstances the data will be subject to confidentiality arrangements.

HFHC HEALTHCARE may disclose data to auditors undertaking investigations or to selected individuals acting on behalf of HFHC HEALTHCARE such as organisations undertaking market or academic research provided no personal data is published. 

HFHC HEALTHCARE will often confirm dates and the nature of an individual’s employment to a prospective employer in a reference.

In certain circumstances HFHC HEALTHCARE may pass data on staff debtors to an external debt collection agency if HFHC HEALTHCARE has been unable to recover any debts by normal internal financial or HR processes.

 HFHC HEALTHCARE will not transfer your data to countries outside the European Economic Area (EEA) but you should be aware that some of our clients have GDPR policies which do not restrict the storage of data to the EEA so in providing your data to clients as part of the terms of an assignment that shared data may be held outside of the EEA.

12. How Does HFHC HEALTHCARE Protect Data?

HFHC HEALTHCARE takes the security of your personal data seriously. HFHC HEALTHCARE has internal policies, procedures and controls in place to prevent your data being lost, accidentally destroyed, misused or disclosed. All data is subject to a series of permissions so as to ensure it is not accessed except as authorised by other employees, workers, contractors or consultants  where they have a need to know in the proper performance of their duties. Similarly, with agents and other third parties who have a business need to know in order to properly perform their duties and responsibilities.

When HFHC HEALTHCARE engages third parties to process personal data on its behalf, they do so on the basis of written instructions, where third parties are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of such data.  We only allow them to process your personal information for specified purposes and in accordance with our own written instructions and we do not allow them to use your personal information for their own purposes.

HFHC HEALTHCARE also has in place procedures to deal with a suspected data security breach and we will notify the Information Commissioner’s Office (or any other applicable supervisory authority or regulator) and you of a suspected breach affecting your data where we are required to do so. 

13. Your Duty to Inform Us of Changes

It is important that the personal information we hold about you is accurate, relevant and current.  Please be sure to keep us informed if your personal information changes during your time working with us.

14. Your Rights

As a data subject, you have a number of rights. You can:

  • access and obtain a copy of your personal data on request (known as a “data subject access request”);
  • require HFHC HEALTHCARE to change incorrect or incomplete personal data;
  • request erasure of your personal information. This enables you to ask HFHC HEALTHCARE to delete or stop processing yourpersonal data, for example where the data is no longer necessary for the purposes of processing;
  • object to the processing of your personal data where HFHC HEALTHCARE is relying on its legitimate interests as the legal ground for processing; and
  • ask HFHC HEALTHCARE to suspend the processing of your personal data for a period of time if data is inaccurate or there is a dispute about its accuracy or the reason for processing it.

If you would like to exercise any of these rights, or you have any questions about the privacy notice, please contact the Data Compliance Officer by email to compliance@hfhchealthcare.com.

If you believe that HFHC HEALTHCARE has not complied with your data protection rights, you have the right to make a complaint to the Information Commissioner’s Office.

Schedule 1

 What personal information will we process?

  • personal contact details, such as your name, title, address and contact details, including email address and telephone number;
  • date of birth;
  • gender;
  • National Insurance Number;
  • the terms and conditions of your employment;
  • recruitment records including personal information included in a CV or Application Form, cover letter, interview notes, references, including references, history with previous employers, including references given to those employers, information about your nationality, copies of proof of right to work in the UK documentation, copies of qualification certificates, copy of driving licence and other background information
  • details of professional memberships;
  • your salary, entitlement to benefits and pension information;
  • details of your bank account, tax status and national insurance number;
  • information about your marital status, next of kin, dependants and emergency contacts;
  • details of periods of leave taken by you, including holiday, sickness absence, family leave and sabbaticals, and the reasons for the leave;
  • information on and used to compile your rota;
  • your personal profile (from time to time);
  • training records;
  • details of any accident or injury or incident you are involved in or witness and associated trackers;
  • any information captured from discussions held around any issues that impact on you personally and as relevant your ability to carry on your role on a day to day basis, including with Intersourcers;
  • details of any disciplinary or grievance procedures in which you have been involved, including any warnings issued to you and related case trackers, correspondence/records;
  • assessments of your performance, including appraisals, One2One’s, training you have participated in, performance improvement/development plans, performance data, and related trackers, correspondence/records;
  • CCTV footage;
  • If you are an authorised driver, data including images collected by a vehicle tracking device;
  • Information about your use of our IT systems including use of telephones, emails and the internet;
  • Images and films, including live streaming of films and voice recordings, taken in the ordinary and everyday course of you performing your role;
  • Images and films to be used for designated marketing purposes only – with your specific consent

Schedule 2

 What special information will we process?

  • information about medical or health conditions, including whether or not you have a disability for which HFHC HEALTHCARE needs to make reasonable adjustments;
  • sickness absence records (including details of the reasons for sickness absence being taken)
  • medical reports and related correspondence
  • details of trade union membership;
  • information about your criminal record; and
  • equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.

 

Schedule 3

 Situations in which we will process your personal information

In order to:

  • make decisions about recruitmentsecondment and promotion processes;
  • match an employee with an Individual we Support as part of a core team;
  • maintain accurate and up-to-date employment records and contact details (including details of whom to contact in the event of an emergency), and records of employee contractual and statutory rights;
  • check you are legally entitled to work in the UK;
  • gather evidence for, and keep a record of, disciplinary, capability and grievance processes, to ensure acceptable performance and conduct within the workplace;
  • pay you and, as applicable, make deductions for tax and National Insurance including liaising with any external benefits, pension providers, insurers, student loan providers and childcare voucher providers
  • administer the Contract we have entered into with you;
  • ensure compliance with your statutory and contractual rights;
  • ensure compliance with the contractual and other reasonable requirements of those for whom we are contracted to provide a service, our commissioners;
  • ensure compliance with our regulator; the Care and Quality Commission;
  • maintain effective systems and control in respect of employee identification and security;
  • make decisions about salary reviews and compensation;
  • make decisions about secondment arrangementsand experience weeks;
  • operate and keep a record of employee performance and related processes;
  • manage, plan and organise work including your rota (if applicable);
  • enable effective workforce management;
  • keep records of training, development and competency requirements;
  • operate and keep a record of absence and absence management procedures, to allow effective workforce management ;
  • ascertain your fitness to work;
  • operate and keep a record of other types of leave (such as maternity, paternity, adoption, parental and shared parental leave), to allow effective workforce management, to ensure that the organisation complies with duties in relation to leave entitlement;
  • meet our obligations under Health and Safety Laws and other statutory obligations ;
  • ensure compliance by authorised drivers with all road traffic and other relevant legislation;
  • to promote your health safety and wellbeing as well as of the individuals we are commissioned to support and your fellow staff members;
  • ensure effective operation of the business through our day to day processes;
  • provide references on request for current or former employees;
  • deal with actual or possible legal disputes involving you or other employees, workers contractors, Individuals we Support and/or third parties whether as witness, claimant or defendant;
  • facilitate equal opportunities monitoring in the workplace;
  • provide facilities such as access to Zone Standard and locations;
  • preventing and detecting crime such as using CCTV, vehicle tracking devices and ID Cards;
  • maintaining contact with past employees
  • fundraising and marketing
  • provision of wellbeing and support services
  • provision of Occupational Health and Wellbeing services;
  • ensure adherence to Company rules, policies and procedures;
  • protect the vital interests of the Individuals we Support;
  • prevent fraud;
  • using various media (including YouTube and other social media platforms) to
    • communicate internally and externally i.e. Twitter, Parent Portal, Zone Standard;
    • demonstrate transparency in the delivery of care;
    • evidence the processes employed in and the nature of the specialist service we provide to the individuals we support (often using images, film, voice recording (including live streaming and case studies);
    • in connection therewith to celebrate achievement;
    • raise awareness;
    • inform and educate.

Schedule 4

 Situations in which we will process your sensitive personal information

In order to:

  • assess your suitability for employment, engagement or promotion;
  • match an employee with an Individual we Support as part of a core team
  • comply with statutory and/or regulatory requirements and obligations such as carrying out DBS checks;
  • ensure compliance withand communication about the contractual and other reasonable requirements of those for whom we are contracted to provide a service and owed to our commissioners and clients;
  • ensure compliance with our regulator; the Care and Quality Commission;
  • comply with the duty to make reasonable adjustments for disabled employees and workers and with other disability discrimination objectives;
  • administer the contract we have entered into with you;
  • maintain effective systems and control in respect of employee identification and security;
  • ensure compliance with your statutory and contractual rights;
  • operate and maintain a record of sickness absence procedures;
  • ascertain your fitness to work;
  • ascertain your fitness to be an authorised driver if applicable;
  • manage, plan and organise work including your rota;
  • enable effective workforce management;
  • make decisions about secondment arrangements;
  • ensure payment of SSP;
  • meet our obligations under health and safety laws;
  • make decisions about continued employment or engagement;
  • operate and maintain a record of dismissal procedures;
  • ensure effective HR, personnel management and business administration;
  • ensure adherence to Company rules, policies and procedures;
  • monitor, report and record on equal opportunities including Gender Pay Gap Reporting;
  • pay trade union premiums;
  • provision of wellbeing and support services;
  • provision of Occupational Health and Wellbeing services to individuals
  • protect the vital interests of those whom we support; and,
  • prevent fraud.

Schedule 5

 Circumstances in which we may share special data without your explicit consent

This will only occur if the processing is necessary:

  • To protect your vital interests and you cannot give your consent for your consent cannot be reasonably obtained
  • To protect another person’s vital interest and you have unreasonably withheld your consent
  • For the discharge of any function which is designed for the provision of confidential counselling, advice, support or other service
  • You consent cannot be given
  • We cannot reasonably obtain your explicit consent
  • Requiring your explicit consent would prejudice the provision of that counselling, advice, support or other service
  • To meet our statutory obligations in relation to equality and diversity monitoring
  • The disclosure is made for the purposes of prevention or detection or crime, the apprehension or prosecution of offenders and we have received a notice from the policy confirming that disclosure is required for these purposes
  • Pursuant to a Court Order requiring disclosure

Schedule 6

 Who has access to data internally?

  • Our Intersourcers
  • Your Line Manager
  • Other Managers in the Team and/or location in which you work;
  • Directors

Schedule 7

 Services provided by third party providers

  • External organisations for the purposes of carrying out pre-employment reference and background checks i.e. DBS;
  • Payroll providers;
  • Pension scheme provider and pension administration;
  • Benefits providers and benefits administration including insurers and childcare vouchers;
  • Occupational health providers;
  • Medical professionals;
  • External IT services;
  • External auditors;
  • Insurers;
  • Consultants;
  • Professional advisers such as lawyers and accountants.

 

 

 

 

 

Version 110820

Privacy Notice Clients

Privacy Notice Marketing

Privacy Notice Employees and Agency Workers

Privacy Notice Recruitment

Privacy Notice Recruitment

Data controller: HFHC Healthcare Limited (Company Number: 05738967) (HFHC HEALTHCARE)

Data Compliance Officer: Steve Cranston (DCO)

What is the purpose of this document?

HFHC HEALTHCARE is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you.

You are viewing/being sent a copy of this privacy notice because you are applying for work with us whether as an employee, worker or contractor. It makes you aware of how and why your personal data will be used by HFHC HEALTHCARE, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).

Data protection principles

We will comply with data protection law and principles, which means that your data will be:

  • Used lawfully, fairly and in a transparent way.
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  • Relevant to the purposes we have told you about and limited only to those purposes.
  • Accurate and kept up to date.
  • Kept only as long as necessary for the purposes we have told you about.
  • Kept securely.

The kind of information HFHC Healthcare will hold about you

In connection with your application for work with us, HFHC HEALTHCARE will collect, store, and use the following categories of personal information about you:

  • The information you have provided to us in your curriculum vitae and covering letter
  • The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications Right to Work and identification documents.
  • Any information you provide to us during an interview.
  • Any film footage of your interview.
  • We may also collect, store and use the following types of more sensitive personal information:
  • Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
  • Information about your health, including any medical condition, health and sickness records.
  • Information about criminal convictions and offences provided by the relevant DBS Check.

How is your personal information collected?

HFHC HEALTHCARE will collect personal information about candidates from the following sources:

  • You, the candidate.
  • HFHC HEALTHCARE application process from which we collect data.
  • Disclosure and Barring Service in respect of criminal convictions.
  • Our Occupational Health provider in respect of any pre-existing health conditions that may or may not affect your working practice.
  • Your named employment and personal referees, from whom we collect data.

How HFHC HEALTHCARE will use information about you

We will use the personal information we collect about you to:

  • Assess your skills, qualifications, and suitability for the position.
  • Carry out reference checks.
  • Communicate with you about the recruitment process.
  • Keep records related to our hiring processes.
  • Comply with legal or regulatory requirements.

It is in our legitimate interests to decide whether to appoint you to the position in order to benefit  our business.

HFHC HEALTHCARE also need to process your personal information to decide whether to enter into a contract of employment with you.

Having received your CV, covering letter, completed application form, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If HFHC HEALTHCARE decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the position. If HFHC HEALTHCARE decide to offer you the position, we will then take up references, carry out the relevant level of DBS check and refer you to our  nominated Occupational Health Provider  for assessment, before confirming your appointment.

If you fail to provide personal information

If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), HFHC HEALTHCARE will not be able to process your application successfully. For example, as we require references and if you fail to provide us with relevant details, we will not be able to take your application further.

How HFHC HEALTHCARE use particularly sensitive personal information

We will use your particularly sensitive personal information in the following ways:

  • We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during an interview.
  • We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

Information about criminal convictions

HFHC HEALTHCARE envisage that we will process information about criminal convictions.

We will collect information about your criminal convictions history if we would like to offer you a position, conditional on checks and any other conditions, such as references, being satisfactory. We are required to carry out the relevant DBS check to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the position. In particular:

  • We are legally required by CQC to carry out criminal record checks for those carrying out. The role that involves supporting vulnerable individuals is one which is listed on the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975 (SI 1975/1023) and is also specified in the Police Act 1997 (Criminal Records) Regulations (SI 2002/233)] so is eligible for an enhanced check from the Disclosure and Barring Service.
  • The role within HFHC HEALTHCARE requires a high degree of trust and integrity since it involves supporting vulnerable individuals and so we would will seek out an Enhanced DBS on your behalf, HFHC Healthcare will complete an Adult First Check (previously POVA) where required and as such will retain your personal information to complete the first stage checks, HFHC Healthcare will send you a link to check and complete the details on the system for the relevant
  • We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such dta.

Automated decision-making

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

Data sharing – Why might you share my personal information with third parties?

HFHC HEALTHCARE will only share your personal information with the following third parties for the purposes of processing your application: Disclosure Barring Service and our Occupational Health providers. All our third-party service providers and other entities in our group are required to take appropriate security measures to protect your personal information in line with our policies. HFHC HEALTHCARE do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with HFHC HEALTHCARE’s instructions.

Data security

HFHC HEALTHCARE have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention How long will you use my information for?

If you are successful and become an employee of, engaged as a worker or contractor by  HFHC HEALTHCARE, we will retain your personal information in accordance with the terms of our Staff Privacy Notice. If unsuccessful post interview stage, HFHC HEALTHCARE will retain your personal information for a period of at least 6 months so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations. If you make an application for employment at HFHC HEALTHCARE and you are not shortlisted for interview, we will not retain your information.

If HFHC HEALTHCARE wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.

Rights of access, correction, erasure, and restriction – Your rights regarding personal information

Under certain circumstances, by law you have the right to:

  • Request access to your personal information commonly known as a “data subject access request”. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information HFHC HEALTHCARE hold about you corrected.
  • Request erasure of your personal information. This enables you to ask HFHC HEALTHCARE to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask HFHC HEALTHCARE to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask HFHC HEALTHCARE to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the DCO in writing.

Right to withdraw consent

You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact the DCO. Once we have received notification that you have withdrawn your consent, HFHC HEALTHCARE will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.

Data protection officer

HFHC HEALTHCARE have appointed a Data Compliance Officer to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how HFHC HEALTHCARE handle your personal information, the DCO can be contacted by email at compliance@homefromhomecare.com

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

This privacy notice may change from time to time so we recommend that you review it periodically.

This version of the privacy notice was last updated on 11th August 2020.