1. Introduction

This privacy policy will explain how JP Medicals Recruitment uses the personal data we collect from you
when you use our website.
This policy sets out the Company’s policy for use of its Facilities and Networking Sites and covers all
individuals working at all levels and grades, including senior managers, officers, directors, employees,
consultants, contractors, trainees, home workers, part-time and fixed-term employees, casual and agency
staff, temps, and volunteers. (“You”). “Your” and “Yourself” shall be construed accordingly and where
there are references to “employee” and/or “your employment” throughout this document, these should
be read as referring to the terms upon which you are either employed or engaged by the Company (as
applicable).
Personal Information is any personally identifiable information, such as your email address, name, home
or work address, telephone number, bank details or tax codes, which can directly or indirectly identify
you. We refer to it as “Personal Information” here;

Topics:
• What data do we collect?
• How do we collect your data?
• How will we use your data?
• How do we store your data?
• Marketing
• What is your data protection rights?
• What are cookies?
• How do we use cookies?
• What types of cookies do we use?
• How to manage your cookies
• Privacy policies of other websites
• Changes to our privacy policy
• How to contact us
• How to contact the appropriate authorities

2. What data do we collect?

When you interact with us in the different ways described below, we may ask you for the following
information:

• Personal and contact details (for example your name, email address, date of birth, gender, and your
choice of language with which you wish to interact with us).
• Personal and contact details you give us when subscribing to receive emails, newsletters, or
marketing information from us.
• During pre-assignment vetting we will request details from you including, your name, your work
history, qualifications, contact details (such as email, telephone number and home address), your
right to work documents, details required for equality and discrimination legislation checks and your
personal preferences, choices and requirements specific to particular requests or services.
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• Details of your education, employment history, bank details and national insurance number,
references, right to work and other information you tell us about yourself (e.g. the information
contained within your CV, passport, driving licence, national insurance number, birth certificate
wherever necessary) when you engage with us for the provision of services.
• Information required for pre-assignment vetting, such as DBS checks and results of
medical/occupational health screenings.
• Information we collect via cookies or similar technology stored on your device (find out more about
cookies and how we use them in our Cookies Policy.
• Your IP address.
• Information from social media activity (such as likes, shares and tweets) when you interact with us
on social media.
• Information you provide if you report a problem with our website or service.
• Additional information which you provide voluntarily and/or which we may ask from you to better
understand you and your interests.
• We may also collect sensitive Personal Information about you (including details of your physical or
mental health, racial or ethnic origin, criminal allegations or offences, trade union membership
and/or other sensitive Personal Information that you may choose to provide to us voluntarily from
time to time.

3. How do we collect your data?

3.1. How and when do we collect your Personal Information?

We may collect your Personal Information when you apply for a role through us (or otherwise contact us
from time to time) by:

• Responding to an advert on a job board or other website.
• By directly contacting our business.
• By filling in an application form in a branch or online.
• When you speak to one of our consultants by telephone.
• Another agency or organisation passes your details to us.

3.2. Why do we collect your Personal Information?

We collect and use your Personal Information because it is necessary to obtain certain details including
Personal Information from you in the work-searching process and it is in our legitimate interests in the
course of operating our business, including:

• Responding to your queries.
• Providing work-finding services and/or information to you.
• Transmitting Personal Information between our offices or functions for internal administrative
purposes.
• Setting you up on a work assignment with a client.
• Hosting and maintaining our websites.
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• Ensuring network and information security.
• Carrying out direct marketing.

However, we will only collect, use and handle your Personal Information when:

• It is necessary for our legitimate interests in connection with carrying out our business, as long as,
in each case, these interests are in line with applicable law and your legal rights.
• Where you have agreed.
• Where this is necessary for legal obligations which apply to us.

4. How will we use your data?

We undertake the following processing of your Personal Information on the legal basis that it is necessary
to perform the contract with you and to provide the services we have agreed to provide to you. Where we
have not entered into a contract with you, we may also carry out this processing because in that pre-contractual stage where we consider it is necessary in our legitimate business interests in order to deal with requests, enquiries or comments you have made to us.

4.1. Submission of details to clients

If you register to apply for a particular role, request to be put forward for a role or if you have asked us to
put you forward for suitable roles, we will share some of your personal details including your name, work
history and qualifications with our clients offering potential roles which might be suitable for you.

4.2. On-boarding for a work-assignment

If you are offered and accept a work assignment through us, we will need further Personal Information
from you such as NI number, bank details, emergency contact details and some medical information in
order to fulfil our statutory and contractual obligations to both you and our client

4.3. Reporting to clients and managing timesheets, payroll and work performance

We sometimes have to prepare reports for clients relating to the services provided by us for example
reports on financial or administrative matters or compliance with legal requirements. Such reports may
contain your Personal Information such as your name, hours worked, and pay rate. In addition, we may
need to manage the submission of timesheets, payroll services, and other Human Resourcing services such as
managing your statutory rights and work appraisals for our clients, all of which would require the use of your
Personal Information.

4.4. Other lawfully permitted processing

We may also use any Personal Information that you provide to us to employers or any other company who
you ask us to approach on your behalf for work-searching purposes. If you choose not to provide Personal
Information requested by us, we may not be able to provide you with the services and/or information you
have requested or otherwise fulfil the purpose(s) for which we have asked for the Personal Information,
including placing you in a work-assignment. We will where possible anonymise or aggregate such data for
reporting purposes.

4.5. We undertake Pre-Assignment Vetting

Pre-Assignment Vetting
We collect your Personal Information which you provide to us when applying for a role or registering for
our job-finding services to comply with our (and clients’) legal obligations regarding your right to work and
any necessary qualifications for roles. We may also process your Personal Information for this purpose
where we consider it necessary for the performance of the contract with you, or otherwise with your consent.
We undertake the following processing of your Personal Information with your consent.

4.6. Other information sources

We use your data through the public information sources and third party organisations that we may use
to carry out suitability checks on work-seekers e.g. Companies House, the Disclosure and Barring Service
(DBS including update service checks), Nursing and Midwifery Council (NMC), General Medical Council
(GMC), DVLA, credit reference agencies (wherever it applies). Government, law enforcement agencies
and other regulators e.g the Police, Home Office, HMRC, Employment Agencies Standards Inspectorate
(EASI), Local Authority Designated Officers (LADOs), GLAA, Trade unions; any of our group companies.

5. How do we store and share your data?

Our Company securely stores your data at our customer relationship management system that is GDPR
compliant.


Our Company will keep your date as set out in the Annexure 1. Once this time period has expired, we will
delete your data by [enter how you delete users’ data.


Some services that we provide require the involvement of third parties. We have carefully selected these
third parties and taken steps to ensure that your Personal Information is adequately protected. The third
parties may include our clients, suppliers of IT services, pay-rolling services or vetting services.
Where we employ third party companies or individuals to process Personal Information provided by us on
our behalf for business functions, including (without limitation) IT support, hosting our data on cloud
platforms, legal, accounting, audit, consulting and other professional service providers, and providers of
other services related to our business. Portions of our services may be provided by organisations with
which we have a contractual relationship, including subcontractors, and, accordingly, your Personal
Information may be disclosed to them. We only provide these organisations with the information that they
need to be able to perform their services.


We will have in place an agreement with our service providers which will restrict how they are able to
process your Personal Information.


We may also provide your information to other third parties such as regulators and law enforcement
agencies, where we are required by law to do so, where necessary for the purposes of preventing and
detecting fraud, other criminal offences and/or to ensure network and information security.

It is our policy to retain your Personal Information for the length of time required for the specific purpose
or purposes for which it was collected, which are set out in this Privacy Policy. However, on occasion we
may be obliged to store some data for a longer time, for example, where a longer time period is required
by applicable laws. In this case, we will ensure that your Personal Data will continue to be treated in
accordance with this Privacy Policy

6. Data Retention

The Company will retain your personal data only for as long as is necessary for the purpose we collect it.Different laws may also require us to keep different data for different periods of time. For example, the
Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep workseeker records for at least one year from (a) the date of their creation or (b) after the date on which we
last provide you with work-finding services.

We must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as
long as is legally required by HMRC and associated national minimum wage, social security and tax
legislation. This is currently 3 to 6 years.

Where the Company has obtained your consent to process your personal and sensitive personal
data/specify which personal data, we will do so in line with our retention policy. Upon expiry of that period
the Company will seek further consent from you. Where consent is not granted the Company will cease to
process your personal data and sensitive personal data.

7. Security and Confidentiality

We employ appropriate security measures to help protect your Personal Information and guard against
access by unauthorised persons. Information storage is on secure computers in a secure environment, or
in secure, locked storage in the case of hard copy information. The information is encrypted wherever
possible and we undergo periodic reviews of our security policies and procedures to ensure that our
systems is secure and protected. However, the transmission of information via the Internet is not
completely secure so we cannot guarantee the security of your information when it is transmitted to our
website or from third party websites such as job boards.

We acknowledge that the information you provide may be confidential. We do not sell, rent, distribute, or
otherwise make Personal Information commercially available to any third party, but we may share
information with our service providers for the purposes set out in this Privacy Policy. We will keep your
information confidential and protect it in accordance with our Privacy Policy and all applicable laws.

8. Marketing

If you have agreed to receive marketing, you may always opt-out at a later date. Where legally permitted
to do so where you have provided us with your contact details and have agreed to be contacted for
marketing purposes, we may contact you by telephone or by post for marketing purposes relating to our
services, our website, and/or to research opinion on proposed business developments. Your agreement
to the use of your Personal Information for these purposes is optional (see Marketing Opt-out below) and
if you fail to provide your agreement, your use of our work-finding services will not be affected.

You have the right at any time to stop Our Company from contacting you for marketing purposes. If you
no longer wish to be contacted for marketing purposes, please contact us.

9. What are your data protection rights?

Our Company would like to make sure you are fully aware of all of your data protection rights. Every user
is entitled to the following:

9.1. The right to access

You have the right to request Our Company for copies of your personal data. We may charge you a small
fee for this service.

9.2. The right to rectification

You have the right to request that Our Company correct any information you believe is inaccurate. You
also have the right to request Our Company to complete information you believe is incomplete.

9.3. The right to erasure

You have the right to request that Our Company erase your personal data, under certain conditions.

9.4. The right to restrict processing

You have the right to request that Our Company restrict the processing of your personal data, under
certain conditions.

9.5. The right to object to processing

You have the right to object to Our Company’s processing of your personal data, under certain conditions.

9.6. The right to data portability

You have the right to request that Our Company transfer the data that we have collected to another
organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these
rights, please contact us at our email: [email protected]
Call us at: 0161 9980636

Or write to us: JP Medicals Recruitment, The Enterprise center, 34, Benchill Road, Wythenshawe,
Manchester, M22 8LF.

10. What are cookies?

Cookies are text files placed on your computer to collect standard Internet log information and visitor
behavior information. When you visit our websites, we may collect information from you automatically
through cookies or similar technology.

For further information, visit allaboutcookies.org

11. How do we use cookies?

Our Company uses cookies in a range of ways to improve your experience on our website, including:

We may use cookies on our website for a number of reasons, all of which are designed to improve your
experience of using it. Cookies allow you to navigate around our website better and enable us to tailor
and improve our website by saving your preferences and understanding your use of it.

12. What types of cookies do we use?

There are a number of different types of cookies, however, our website uses:

• Functionality – Our Company uses these cookies so that we recognize you on our website and
remember your previously selected preferences. These could include what language you prefer
and location you are in. A mix of first-party and third-party cookies are used.
• Advertising – Our Company uses these cookies to collect information about your visit to our
website, the content you viewed, the links you followed and information about your browser,
device, and your IP address. Our Company sometimes shares some limited aspects of this data
with third parties for advertising purposes. We may also share online data collected through
cookies with our advertising partners. This means that when you visit another website, you may
be shown advertising based on your browsing patterns on our website.

12.1. Strictly Necessary Cookies

These cookies are essential in order to enable you to move around our website and use its features, such
as accessing secure areas of the website. Without these cookies, the services you have asked for may not
be provided.

12.2. Performance Cookies

It is important for us to understand how you use our website, for example, how efficiently you are able to
navigate around it, and what features you use. Performance cookies enable us to gather this information,
helping us to improve our website and your experience of it. These cookies collect anonymous information
on the pages visited.

12.3. Functionality Cookies

These cookies remember your choices to improve your experience. Functionality cookies enable us to
provide additional functions to you on our website such as personalization and remembering your saved
preferences.

Strictly Necessary, Performance and Functionality Cookies

These three types of cookies are necessary to maintain the effectiveness of our website, use of use and to
provide you with the best experience. As such we have not provided an option for these to be disabled
independently and by using our website you are agreeing that we can place these types of cookies on your
computer.

12.4.Targeting Cookies

It is also important for us to know when and how often you visit our website, and which parts of it you
have used (including which pages you have visited and which links you have clicked on). As with analytics
Cookies, this information helps us to better understand you and, in turn, to make our website and
advertising more relevant to your interests. Some information gathered by targeting Cookies may also be
shared with third parties.

12.5. Persistent Cookies

Any of the above types of cookie may be a persistent cookie. Persistent cookies are those which remain
on your computer or device for a predetermined period and are activated each time you visit our website.

12.6. Session Cookies

Any of the above types of cookie may be a session cookie. Session cookies are temporary and only remain

on your computer or device from the point at which you visit our website until you close your browser.
Session cookies are deleted when you close your browser.

Third-party cookies are not placed by us and we have no control over them. Third-party cookies may be
used by advertising services to serve up tailored advertising to you on our website, or by third parties
providing analytics services to us (these cookies will work in the same way as analytics cookies described
above).

We also use web beacons on our website to track your navigation around it. As with analytics cookies
described above, web beacons help us to understand how you use our website and enable us to improve
it in the future.

Our cookies have variable expiry periods. This is detailed against each cookie in section three (3) below.
We have used the categories based on the International Chamber of Commerce (ICC) UK Cookie Guide
(April 2012).

13. How to manage cookies

You can set your browser not to accept cookies, and the above website tells you how to remove cookies
from your browser. However, in a few cases, some of our website features may not function as a result.

Internet browsers normally accept cookies by default. You can change these settings if you wish, however,
please be aware that this is not generally a per-site setting and will prevent all websites from using cookies,
not just ours. Please also be aware that by disabling cookies in your browser, you may impair the
functionality of our website.

The links below provide instructions on how to control cookies in all mainstream browsers:

Google Chrome: https://support.google.com/chrome/answer/95647?hl=en-GB

Microsoft Internet Explorer: https://support.microsoft.com/en-us/help/278835/how-to-delete-cookiefiles-in-internet-explorer

Microsoft Edge: https://support.microsoft.com/en-gb/microsoft-edge (Please note that there are no
specific instructions at this time, but Microsoft support will be able to assist)

Safari (OSX): https://support.apple.com/en-gb/guide/safari/sfri11471/mac

Safari (iOS): https://support.apple.com/en-gb/HT201265

Mozilla Firefox: https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefoxdesktop?redirectlocale=en-US&redirectslug=enable-and-disable-cookies-website-preferences

https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DAndroid&hl=en
(Please refer to your device’s documentation for manufacturers’ own browsers)

14. How Do We Use Cookies in Emails?

In addition to using cookies on our website, we use cookies and similar technologies in some of the emails
we send to you. Just like the cookies on our website, these are used to help us understand your use of our
website and to keep improving it.

We use web beacons in some of our emails. We use web beacons to detect when (or whether) you open
an email and how you have interacted with it, and other information such as your email client, web
browser, computer or device, and IP address. Web beacons may also be used to serve up emails in a
particular format that is best suited to your computer or device.

Emails from us may contain links. Each one of those links will contain a unique tag that enables us to
track which links are being used and by whom. This information can then be used to improve and tailor
our emails in the future.

15. Privacy policies of other websites

The Our Company website contains links to other websites. Our privacy policy applies only to our website,
so if you click on a link to another website, you should read their privacy policy.

We also use and work with a number of third-party suppliers and partners who set cookies on this website
in order to deliver certain services and features. For example, we sometimes embed videos from sellers’
websites, which set cookies on your device when you visit a page on this website containing embedded
content. We do not control the dissemination of these cookies. If you would like more information about
the cookies used by these organizations, as well as information on how to opt out, please review the table
below.

Cookie Name Purpose

YouTube

We use seller’s videos to show some the products in action and the seller
may set cookies on your browser in order to display the video and
monitor non-attributable statistical information. Information on
YouTube's privacy policy can be found here
https://policies.google.com/privacy?hl=en&gl=uk

Facebook

Facebook uses cookies and receives information when you visit those
sites and apps, including device information and information about your
activity, without any further action from you. This occurs whether or not
you have a Facebook account or are logged in

Hubspot
Used to collect form data
Activepoint
Used to collect form data
Google Adwords

Cookies help to make advertising more effective. Without cookies, it’s
harder for an advertiser to reach its audience, or to know how many ads
were shown and how many clicks they received.

Many websites, such as news sites and blogs, partner with Google to
show ads to their visitors. Working with our partners, we may use cookies
for a number of purposes, such as to stop you from seeing the same ad
over and over again, to detect and stop click fraud and to show ads that
are likely to be more relevant (such as ads based on websites that you
have visited).
We store a record of the ads that we serve in our logs. This server
logs typically include your web request, IP address, browser type, browser
language, the date and time of your request, and one or more cookies
that may uniquely identify your browser. We store this data for a number
of reasons, the most important of which are to improve our services and
to maintain the security of our systems.
We anonymise this log data by removing part of the IP address (after nine
months) and cookie information (after 18 months).

Pardot

Pardot tracks visitor and prospect activities on your website and landing
pages by setting cookies on their browsers. Cookies are set to
remember preferences (like form field values) when a visitor returns to
your site. Pardot also sets a cookie for logged-in users to maintain the
session and remember table filters

Google cookies

Please find the link for the types of cookies used by google

domain Cookies
Site Cookie used on a permanent basis
cookiePolicyCookie
Site Cookie used on a permanent basis

16. Changes to our privacy policy

Our Company keeps its privacy policy under regular review and places any updates on this web page. This
privacy policy was last updated on 03 March 2020. We may make alter this Cookie Policy at any time. If
we do so, details of the changes will be highlighted at the top of this page. You are therefore advised to
check this page from time to time. In the event of any conflict between the current version of this Cookie
Policy and any previous version(s), the provisions, and in effect shall prevail unless it is expressly stated
otherwise.

17. How to contact us

If you have any questions about Our Company’s privacy policy, the data we hold on you, or you would like
to exercise one of your data protection rights, please do not hesitate to contact us.

Email us at: [email protected]
Call us: 0161 4640906

Write to us: JP Medicals Recruitment, The Enterprise centre, 34, Benchill Road, Wythenshawe,
Manchester, M22 8LF.

18. How to contact the appropriate authority

Should you wish to report a complaint or if you feel that Our Company has not addressed your concern in
a satisfactory manner, you may contact the Information Commissioner’s Office.

Subject: Privacy Policy
Version Number: 7
Date: 03/03/2022
Review Date: 03/03/2024
Implementation

Policies will be distributed by the IT/HR Director
to all other Directors and employees. Policy will
be available on the company’s office and can be
given to the worker.

Monitoring

Implementation, compliance and effectiveness
of this policy will be monitored by the IT/Human
Resource Directorate on an ongoing basis. This
will be achieved by monitoring the use of the
policy using a secure excel database..

Pages: 14
Signature:

Contact:
Gopalakrishnan Subramanian

Role: Director

19. Annexure 1

Record Keeping Table

Document type How long to keep for (and source of requirement)
Personnel records

• Work-seeker records including
application form/CV, ID checks, terms of
engagement (see also below), details of
assignments, opt-out notices and
interview notes for unsuccessful
candidates
• Hirer records including client details,
terms of business (see below),
assignment/vacancy details

1 year from the last date of supply or
introduction to your client (Conduct of
Employment Agencies and Employment
Businesses Regulations 2003 (Conduct
Regulations)
For full details please pages 16 and 19 to 20 of
the REC Guide to the Conduct Regulations.

Terms of engagement with temporary worker and terms of business with clients

6 years in order to deal with any civil action in
the form of contractual claim (Limitation Act
1980) (5 years in Scotland). Please note that 6
years is not a minimum legal requirement but is
the time period in which a contractual claim can
be made. You will still have to establish why it is
necessary to keep these records.

Working time records:
• 48 hour opt out notice
• Annual leave records

2 years from the time they were created

ContentAnnual appraisal/assessment records

No specific period – under data protection laws
you should only keep records for as long as is
necessary.

Records held relating to right to work in the UK

2 years after employment or engagement has
ended – must not be alterable

Criminal records checks/ Disclosure Barring
checks

There is no longer a 6 month time limit on how
long DBS certificates can be kept for. When it
comes to handling and storing certificates the
new DBS Code requires registered bodies to
‘handle all information provided to them by DBS,
as a consequence of applying for a DBS product,
in line with the obligations under Data
protection Act 1998’.

National Minimum Wage documentation:
• Total pay by the worker and the hours worked
by the worker
• Overtime/shift premia;
• Any deduction or payment of accommodation;
• Any absences eg rest breaks, sick leave,
holiday;
• Any travel or training during working hours
and its length;
• Total number of hours in a pay reference
period

For HMRC purposes: 3 years after the end of the
pay reference period following the one that the
records cover (National Minimum Wage Act
1998)
Or 6 years (5 in Scotland) in order to show that
you have paid at least national minimum wage
rates if a breach of contract claim is brought
against you.

Sickness records – statutory sick pay

Records can be kept in a flexible manner which
best suits your business but should be kept for
payroll purposes (see below)

Document type

How long to keep for (and source of requirement)
Statutory maternity, paternity, adoption pay
3 years from the end of the tax year to which it relates
Pensions auto-enrolment (including auto enrolment date, joining date, opt in and opt out notices, contributions paid)
6 years except for opt out notices which should be kept for 4 years. For further information please see The Pensions Regulator’s detailed guidance for employers.
Gender pay gap reporting
1 year (but the statement must be kept on the Government website and organisation’s own website for 3 years).
Company financial records
VAT
6 years –please see an overview of VAT record keeping on the Gov.uk website
Company accounts
6 years –please see an overview of running a limited company on the Gov.uk website

• Payroll information
• CIS records

3 years from the end of the tax year – please see Gov.uk guidance on keeping records for business.
ITEPA (the intermediaries legislation) records
Report due every quarter, to be kept for no less than 3 years after the end of the tax year to which they relate.