Recruitment privacy notice
Introduction
Welcome to Portman Healthcare (Group) Limited’s, Portman Healthcare Holdings (Ireland) Limited including their respective subsidiaries, (collectively “we”, “our”, “us”, “the Company” PortmanDentex) Privacy Notice. As part of our recruitment process, we collect and process personal data relating to job applicants. We respect your privacy and are committed to protecting your personal data. This privacy notice contains information about how we look after your personal data when you apply to work for us, your privacy rights and how the law protects you.
Important information and who we are
What is the purpose of this document?
PortmanDentex is a “controller” in relation to personal data. This means that we are responsible for deciding how we hold and use personal information about you. You have been referred to this privacy notice because you are applying for work with us (whether as an employee, worker or contractor). This privacy notice provides you with certain information that must be provided under the UK General Data Protection Regulation (“UK GDPR”) and the EU General Data Protection Regulation (“EU GDPR”). If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out in paragraph 1.4 below.
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
Contact details
Full name of legal entity: Portman Healthcare (Group) Limited
Email address: [email protected]
Registered office address: Rosehill, New Barn Lane, Cheltenham GL52 3LZ
Full name of legal entity: Portman Healthcare Holdings (Ireland) Limited
Email address: [email protected]
Registered office address: Suite 3, One Earlsfort Centre, Lower Hatch Street, Dublin 2, Ireland
If you consider that our collection or use of personal information is unfair, misleading or inappropriate, or have any other concern/ complaint about our data processing, please raise this with our Data Protection Officer in the first instance at email: [email protected]
Our Data Protection Officer is responsible for informing and advising us about our data protection law obligations and monitoring our compliance with these obligations.
You have the right to make a complaint at any time to a Supervisory Body for data protection issues. Please email us in the first instance, [email protected] as we would appreciate the chance to deal with your concerns before you approach a Supervisory Body.
The Information Commissioner’s Office: 0303 123 1113, Via a live chat, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
The Data Protection Commission: Via their online contact form, Via post at 21 Fitzwilliam square south, Dublin 2, D02 RD28
Changes to the privacy notice and your duty to inform us of changes
We keep this privacy notice under regular review. This version was last updated in March 2024.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Should your application be successful, when you are engaged by us another privacy notice will be provided that explains how we process your personal data.
Personal data
The data we collect about you Personal data means any information relating to an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
In connection with your application to work with us, we will collect, store, and use the following categories of personal information about you:
• The information you have provided to us in your curriculum vitae including qualifications
• The information you have provided on our application form (if applicable), including name, title, address, contact numbers, personal and work email addresses, employment history and qualifications, gender, age and date of birth, national insurance number
• Information about your employment history, job titles, including current salary, benefit entitlements, notice period, reasons for wanting to leave, professional memberships, experience and skills
• Any information you provide to us during an interview
• Publicly available information about you such as your business and personal social media presence
• Images captured by CCTV at our premises if they have CCTV and you visit them or attend an interview
• Equal opportunities monitoring information, including information about a candidate’s ethnic origin, sexual orientation, health and religion or belief
• Information from referees where applicable once a verbal offer has been accepted.
You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly
How is your personal data collected?
We collect personal information about candidates from the following sources:
• You, the candidate
• Recruitment agencies, from which we collect your name and curriculum vitae
• Referees via details that you provide – only applicable once a verbal offer has been accepted
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use the personal information we collect about you to:
• Assess your skills, qualifications, and suitability for the role and our business
• Carry out reference checks, where applicable
• Communicate with you about the recruitment process
• Keep records related to our hiring processes
• Ensure that appropriate access arrangements can be provided for a candidate that requires them
• To make you aware of job opportunities and share updates on news relating to us
• Comply with legal or regulatory requirements.
Having received your application, 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 to invite you for an interview. We will then use the information you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role, we will then carry out relevant background checks before confirming your appointment.
Interviews may be conducted remotely, by telephone or online using Microsoft Teams. Where practical, interviews may be recorded to facilitate the recruitment process.
Lawful basis for processing a candidate’s personal data
The lawful basis that we rely on for processing your personal data during the recruitment process is legitimate interests as it is in our legitimate interests to decide whether to appoint you to the relevant role since it would be beneficial to our business to appoint someone to that role.
We may also collect, use and store information about a candidate that falls into special categories of more sensitive personal data to comply with its legal requirements in the field of employment such as:
• To comply, monitor and report on equal opportunities and responsibilities under relevant Equality legislation e.g. gender, age, race, ethnic origin, religious, sexual orientation, disability and caring responsibilities.
• Legal Obligation - To satisfy our legal obligations for example it is mandatory to check hepatitis b vaccination status for some positions.
• We may also collect information about a candidate’s disability status to make appropriate adjustments during the recruitment process. We process such information to carry out our obligations and exercise specific rights in relation to employment or engagement of a worker.
Disclosures of your personal data
We will only share your personal data with the following third parties for the purposes of processing your application:
• SmartRecruiters Ltd – provider of our recruitment software platform
• TalentWise – provider of our referencing service. T
he above third parties may change from time to time. This privacy notice will be updated on an annual basis. If you require any further information, please contact us at [email protected]
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. Third parties are only permitted to process your personal data for specified purposes and in accordance with our instructions.
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. 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 security breach and will notify you and any applicable supervisory body of a breach where we are legally required to do so.
Transferring personal data internationally
We mainly store data in the UK or the European Economic Area (EEA), however some of our service providers may store personal data outside these areas (usually in the USA). Where this is the case, we have a contract with these service providers which ensures they process data securely and in line with data protection laws.
We currently transfer personal data outside the EEA as we store personal data on cloud systems based in the EEA that have backup systems that may sometimes be located outside the EEA.
Data retention
If your application is successful, we will retain your personal information for a period of 7 years following expiry or termination of your contract with us. This is subject to our Colleague Privacy Notice, which we will provide to you on commencement of your contractual relationship with us, if your application is successful.
If your application is unsuccessful, we will retain your personal information for a period of 2 years from submission of your application. We retain your personal information for that period so that we can show 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 the applicable retention period, we will securely destroy your personal information in accordance with applicable laws and regulations. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, by law you have the right to:
• Be informed about the collection and use of your personal data. A privacy notice will be provided to you at the time your personal data is collected and will explain simply and clearly how and why we intend to process your data.
• Access your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we held about you and to check that we are lawfully processing it.
• Rectification of the personal information we hold about you. This enables you to have any incomplete or inaccurate information hold about you corrected.
• Erasure of your personal information. This enables you to ask us to delete or remove your personal information where there is no good reason for us continuing to process it for the purposes for which it was provided; we aren’t using the personal data in a lawful manner.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you for example if you consider that: • any of the information that we hold about you is inaccurate
• we no longer need to process the information for the purposes for which it was provided, but you require the information to establish, exercise or defend legal claims • we aren’t using your information in a lawful manner
• 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 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. You must tell us your circumstances justifying your objection to processing. Please be aware that we can still process personal information where there are compelling grounds, or it is necessary for legal claims.
