Agile Workforce Services Limited (“the Company”)
6th January 2020
1. About the Company
Agile Workforce Services Limited (''we'/'us'/'our'/”the Company”) provides workforce management solutions within the healthcare sector to include end to end recruitment technology solutions, bank and agency management, invoicing, payroll, compliance, direct engagement, insourcing of medical services, management information and other strategic advice.
The Company process personal data (including special category personal data) as defined in GDPR, so that we can provide services on behalf of both our clients and candidates. Personal data is any information that can be used to identify a living individual.
Candidates may provide personal details to the Company directly, such as on an application or registration form or via our website; or the Company may collect them from another source such as directly from your engaging Trust or “Host Trust”.
Client and Suppliers will provide the personal details of their contacts to us further to entering into a contract with us (whether in writing or otherwise).
We will only process your personal data when we have a legal basis to do so. If you are a candidate, we process your personal data for the purposes of providing you with recruitment services and/or information relating to roles relevant to you. We therefore have a contractual basis for holding and processing your personal data when trying to find you suitable roles (albeit that we do not have a written agreement with you). If you are a client or supplier we have a contractual basis for processing personal data received from you further to our agreement with you, for example under the relevant NHS Framework Agreement.
2. What Personal Data do we Collect and Why?
- Candidate Data
As a candidate looking for employment, the Company provides you with recruitment services; short term, long term and permanent work at NHS Trusts, and with private healthcare providers. On this basis, we collect and use your personal data to offer and provide you with such recruitment services.
The type of personal data the Company collects from you includes but is not limited to your name, address, contact details, DOB, nationality and visa details (if appropriate).
The Company may share your personal data with any member of its group of companies (the Company is part of the Pettra Limited group of companies) in circumstances where we have a legitimate interest in doing so and/or in order to perform a contract we are about to enter into or have entered into with you. For example, where you have expressly requested recruitment services that are provided by another group company.
The Company will share your personal data with prospective employers and match your skills and experience against job opportunities. The Company may be asked by a prospective employer for information that you have supplied such as your references, GMC status, qualifications or criminal record.
The only Special Category data the Company processes is that relating to physical or mental health and information about criminal records that is handled in accordance with the requirements of GDPR.
The Company wants to provide you with tailored job details and relevant articles to read to help you with your job search and therefore process your data to ensure that you are sent the most appropriate content as part of the recruitment service.
The Company use your data for payroll and invoicing where relevant and as necessary for the Company to comply with the law. If you are a candidate supplied to us through an Umbrella Company we may need to carry out certain compliance and financial checks from time to time in order to verify the legitimacy of the Umbrella Company. We may ask for certain payroll details, including copies of your payslips. This is necessary for our legitimate interests to carry out a financial audit of any Umbrella Company that we engage with and to detect or prevent any fraudulent activity.
3. Disclosure of Candidate Information to Third Parties
The Company will share your personal data with the following organisations in order to obtain additional personal data and / or Special Category Personal Data about you (and which the Company may also be required to share with clients). A (non-exhaustive) list of third-party service providers is as follows:
- Healthier Business Group - https://www.hbcompliance.co.uk/online-training/
- Osmosis Training - http://www.osmosistraining.co.uk
Some clients require specialist training relevant to your grade and speciality (for locum work) and the Company therefore provide you with details of training providers as part of the service offering to you. The Company will share your contact information with specialist training providers to enable you to attain the training required in order to be considered for relevant work at your grade and speciality.
Criminal Records Check
- Criminal Records Agency - https://www.criminalrecordsagency.co.uk/
The Company undertakes checks for candidates applying for certain roles, for example in healthcare. This is known as a Disclosure and Barring Service (DBS) check.
Certificate of Fitness to Work
- Healthier Business Group - https://www.hbcompliance.co.uk/occupational-health/
Information provided by candidates enables the company to apply for a certificate of fitness from an occupational health provider as required prior to placement into work.
General Medicine Council (GMC)
A search of the GMC list of registered medical practitioners confirms that a Doctor’s registration qualifies them for the work they would like to undertake and provides the company with additional information that is needed such as any restrictions on a registration.
The Company may source up to date references from previous and current placements as part of the selection process for appointments within the NHS. We will ask you for the name and contact details of any referees that you wish us to contact.
If a candidate ‘connects’ with the Company as its designated body, a Transfer of Information request will be made from the Company’s Responsible Officer (RO) to the candidate’s previous RO relating to the candidate’s last appraisal and practice.
- Referees, Appraisers, Responsible Officer and Emergency Contacts of Candidates
If your personal details are provided as an emergency contact, the Company will only use these details in case of an emergency and such processing is therefore lawful on the basis that it is necessary to protect someone’s life.
Please note that if you have given the company information, including personal data, relating to someone else, (appraiser, referee or emergency contact) you confirm that the relevant individual:
- has a contractual relationship with you and knows that you will be transferring their personal data to the Company for specific purposes; or
- knows that you will be transferring their personal data to the Company for specific purposes and has also agreed that you can:
- Give consent on his/her behalf to the processing of his/her personal data
- Receive on his/her behalf any data protection notices
- Give consent to the processing of his/her Special Category Personal Data
4. Direct Emails
The Company may send an email to you about certain job vacancies. These will be vacancies for which you have registered your interest and will only be our latest job opportunities based on your skills and expertise. Please inform the Company if you would like to stop these emails been sent to you; there is always an unsubscribe option on such emails to enable you to update your communication preferences.
5. Overseas Transfers
If we need to transfer personal data outside the EEA because our suppliers or clients are based there we will take steps to ensure that the appropriate legal safeguards are in place. (The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.)
6. Automated Decision Making
The Company’s Locum Management System (LMS) software performs automated profiling to match candidates to jobs. This process is based on information provided by the candidate and may include work history, grade and specialty, locality, qualifications and availability. However, the actual booking of a candidate into a job involves manual intervention and therefore the Company does not believe that automated decision making is undertaken.
LMS is a tailored recruitment software solution, on which the Company stores your personal data so you can be contacted in relation to providing temporary workforce solutions.
7. Client Data
To ensure the Company provides you with a tailored recruitment solution, your personal data and personal data of contacts at your organisation together with all other relevant information is stored on the Locum Management System (LMS) so the Company can contact you in relation to providing recruitment solutions.
The Company’s LMS platform records:
- Job data
- Note records of emails and conversations
- Vacancy and placement data
- Management information
8. Contact Details
The company has a dedicated Data Protection Officer who can be contacted by emailing firstname.lastname@example.org