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Recruitment Privacy Policy

Doctor Care Anywhere Recruitment Privacy Policy

Welcome to the DCA Recruitment Privacy Policy, which contains essential legal information informing you of how we process your personal data.

 

At DCA we have one purpose, to improve people’s lives.  We do this by providing the highest quality healthcare, which is truly affordable, through our beautifully designed and easy to use technology.

 

Your personal data is central to our recruitment process to ensure we hire the best talent to help us deliver quality healthcare, and we are passionate about keeping it safe and protecting your privacy.  We comply with the General Data Protection Regulation ("GDPR") and relevant implementing legislation and always challenge ourselves to be better, putting you, our patients, first and foremost.

 

This Privacy Policy explains how we use your personal data, so that you can make informed choices and be in control of your personal data.  This Privacy Policy also governs the use of your data through DCA’s recruitment website, Workable, an online application tool provided by Workable Software Limited.

 

We use Workable to assist with our recruitment process. We use Workable to process personal information as a data processor on Our behalf. Workable is only entitled to process your personal data in accordance with Our instructions.

 

Where you apply for a job opening posted by us, these Privacy Notice provisions will apply to our processing of your personal information.

 

Where you apply for a job opening via the application function on a job site or similar online service provider (“Partner”), you should note that the relevant Partner may retain your personal data and may also collect data from us in respect of the progress of your application. Any use by the Partner of your data will be in accordance with the Partner’s Privacy Notice.

 

Please take some time to understand this Privacy Policy.  It is important that you read this Privacy Policy together with any other fair processing notice that we may provide to you on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data.  This Privacy Policy supplements other privacy notices and is not intended to override them.

 

Changes to this Privacy Policy and your duty to inform us of changes to your personal data

 

We keep our Privacy Policy under regular review.  We may update this Privacy Policy from time to time, and if we make any material changes, we will notify you when we do so.  This version was last updated on 24 May 2021. Historic versions can be obtained by contacting us.  By continuing to use our products and services after the changes and notification, the way we use your personal data will be subject to the terms of the updated Privacy Policy.

 

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.

 

What this Privacy Policy covers

 

This Privacy Policy has been split into sections for your convenience. Click on each to find out more. 

WHO IS DOCTOR CARE ANYWHERE?

Doctor Care Anywhere is a group of companies parented by Doctor Care Anywhere Group PLC together the "DCA Group", whose companies include:

- Doctor Care Anywhere Limited

- Doctor Care Anywhere Ireland Limited;

- DCA Innovation Ltd; and

- Doctor at Hand Diagnostics Limited.

The registered office of the DCA Group is: Second Floor, Harmsworth House, 13-15 Bouverie Street, London, EC4Y 8DP.

Controller

When this Privacy Policy talks about ‘Doctor Care Anywhere’, ‘DCA’, ‘we’, ‘us’ or ‘our’, it means Doctor Care Anywhere Group PLC, who is controller in relation to your personal data processed for recruiting you into any of the DCA Group companies.  Your relationship is with DCA, who is responsible for your personal data that is processed in connection with our recruitment processes.  We provide your personal data to other companies in the DCA Group who are data processors of your personal data, acting under instruction of DCA.

Contact details

We have appointed a Data Protection Officer ("DPO") who is responsible for overseeing questions in relation to this Privacy Policy.  If you have any questions about this Privacy Policy, including any requests to exercise your legal rights please contact the DPO using the details set out below.

- By email: DPO@doctorcareanywhere.com

- In writing: Data Protection Officer, Doctor Care Anywhere Limited, Second Floor, Harmsworth House, 13-15 Bouverie Street, London, EC4Y 8DP.

You have the right to make a complaint at any time to a data protection supervisory authority.

- In the UK this is the Information Commissioner’s Office ("ICO") ico.org.uk

- In Europe this is the Irish Data Protection Commission ("DPC") https://www.dataprotection.ie/.

We ask that you please attempt to resolve any issues with us before contacting the ICO or the DPC.

WHAT WE USE YOUR PERSONAL DATA FOR

How we use your personal data

We will only use your personal data when the law allows us to.  Most commonly we rely on legitimate interest as the lawful basis on which we process your personal data. Our legitimate interests are the recruitment of staff for our business.

Legitimate interests means the interests of our business in conducting and managing our business, to enable us to give you the best service/product and the most secure experience. We make sure we consider your rights and balance any potential impact on you (both positive and negative) before we process your personal data for our legitimate interests. We do not process your personal data for our legitimate interests where your rights or interests override ours. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us (see contact details in section Who is Doctor Care Anywhere).

Where you apply for a job opening through a Partner’s application functionality, We rely on your consent, which is freely given by you during the application process, to disclose your personal data to the Partner on the basis described below.

Purposes for which we will use your personal data

We have set out below a description of the purposes for which we use your personal data.

- To consider your application in respect of a role for which you have applied.

- To consider your application in respect of other roles.

- To communicate with you in respect of the recruitment process.

- To enhance any information that we receive from you with information obtained from third party data providers.

- To find appropriate candidates to fill our job openings.

- To help our service providers (such as Workable and its processors and data providers) and Partners (such as the job sites through which you may have applied) improve their services.

Automated decision making/profiling

We may use Workable’s technology to select appropriate candidates for us to consider based on criteria expressly identified by us, or typical in relation to the role for which you have applied. The process of finding suitable candidates is automatic, however, any decision as to who we will engage to fill the job opening will be made by our staff.

WHAT DATA WE HOLD AND HOW WE GET IT

We collect and use some or all of the following categories of data about you.

- Information that you provide when you apply for a role. This includes information provided through an online job site, via email, in person at interviews and/or by any other method.

- In particular, we process personal details such as name, email address, address, telephone number, date of birth, qualifications, experience, information relating to your employment history, skills experience that you provide to us, as well as your video in case you conduct your interview using the Video Interview feature.

- If you contact us, we may keep a record of that correspondence.

- A record of your progress through any hiring process that we may conduct.

- Details of your visits to Workable’s website including, but not limited to, traffic data, location data, weblogs and other communication data, the site that referred you to Workable’s website and the resources that you access.

Cookies:

- We also use 'cookies'. Cookies are files saved on your devices such as computer, phone or tablet when you visit a website. They collect information about how you use the website and the pages you visit. We do not use cookies on your medical or health information. You can determine what cookies we collect and find out more about how we use cookies in our Cookie Policy, which you can access here.

Information from third parties:

- Workable provides us with the facility to link the data you provide to us, with other publicly available information about you that you have published on the Internet – this may include sources such as LinkedIn and other social media profiles.

- Workable’s technology allows us to search various databases – some publicly available and others not, which may include your personal data (including your CV or Resumé), to find possible candidates to fill our job openings. Where we find you in this way, we will obtain your personal data from these sources.

We may receive your personal data from a third party who recommends you as a candidate for a specific job

WHO YOUR DATA IS SHARED WITH

Your privacy is paramount to us, so we only share your data when it is necessary and lawful to do so as described below.  We require any party who we share your data with to respect the security of your data and to only process it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our written instructions.

- We may share your personal data within the DCA Group. This ensures we can effectively recruit across the group and ensure your application is properly considered.

- We may share your personal data with other companies we have contracted with, including Workable. These companies act as data processors acting on our behalf, as instructed by us and are governed by a contract in accordance with Article 28 GDPR. In such circumstances they are bound by strict confidentiality and security provisions.

- Where you have applied for a job opening through a Partner’s application functionality, and where you have consented to this disclosure, we will disclose to the Partner certain personal data that we hold, including but not limited to a unique identifier used by the Partner to identify you, and information about your progress through our hiring process for the applicable job opening, as well as tangible, intangible, visual, electronic, present, or future information that we hold about you, such as your name, contact details and other information involving analysis of data relating to you as an applicant for employment (collectively “Disposition Data”). The Partner’s Privacy Notice in respect of the Partner’s use of the Disposition Data is available on the Partner’s website.

- Where you have applied to a job opening through another service provider, we may disclose data similar to the Disposition Data defined above to such service provider. The service provider shall be the data controller of this data and shall therefore be responsible for complying with all applicable law in respect of the use of that data following its transfer by us.

International transfers:

Whenever we transfer your personal data out of the UK and/or European Economic Area (“EEA”), we ensure a sufficient degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the Information Commissioners Office and European Commission.

- Where we use certain service providers, we may use specific contracts approved by the European Commission and the ICO (known as ‘Model Clauses’ or ‘Standard Contractual Clauses’), which ensure personal data is transferred securely.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and EEA

WHERE YOUR DATA IS STORED

Where we store your personal data in our own systems, it is stored in the UK and EEA, in secure data centres.  

The data that we collect from you and process using Workable’s services may be transferred to, and stored at, a destination outside the UK or EEA. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.

Your data may be accessible to:

1.Workable’s staff in the USA; or

2. may be stored by Workable’s hosting service provider on servers in the USA as well as in the EU.

Your data may be processed on servers outside of the UK and EEA as described in this Privacy Policy.  We ensure your personal data is protected in such circumstances by complying with transfer mechanisms as prescribed by the GDPR (see more detail on this under 'International transfers' in section who you data is shared with).

HOW LONG WE KEEP IT

We will only retain your personal data for as long as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We will hold all the data for 12 months.

Your personal information will be deleted on one of the following occurrences:

- deletion of your personal information by you (or by another person engaged by the Customer); or

- receipt of a written request by you (or another person engaged by the Customer) to us.

SECURITY OF YOUR PERSONAL DATA

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

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

We have adopted the following measures:

- All data is encrypted whether it is in transit over the internet from our servers to your device or stored on our secure servers. We use Advanced Encryption Standards.

- In line with best practice, we regularly test our system with penetration test partners, who simulate cyber-attacks on our system. This ensures our security is robust and continues to protect your data against the latest threats.

- You will secure your account with a password. We enforce a minimum standard for passwords to ensure they meet a certain level of strength. It is your responsibility to keep your password / pin to your device safe and confidential.

YOUR RIGHTS

You have specific rights under the GDPR, as set out below.

Access your information. 

You have the right to submit what is known as a ‘data subject access request’, which enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Rectify incorrect information. 

If you believe that any of your data is incorrect, you can ask us to rectify it. We make sure to do so if this is the case, however, we may need to verify the accuracy of the new data you provide to us. 

Erase your information. 

This enables you to ask us to delete or remove personal data where there is no lawful basis for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below).

Object to our processing of your personal data. 

You can do this where we are relying on legitimate interests to process your data and you wish to object to such processing as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.

Restrict further processing of your data. 

This enables you to ask us to suspend the processing of your personal data in the following scenarios:

- if you would like us to verify it is accurate;

- where the data has been processed unlawfully, but you do not want us to erase it;

- where you need us to hold the data even if we no longer require it to establish, exercise or defend legal claims;

- you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Request transfer of your data to you or to a third party. 

Your data will be provided in a structured, commonly used, machine-readable format. It allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without affecting its usability. Note that this right only applies to information you have provided to us.

Withdraw your consent at any time. 

This is applicable where we are relying upon your consent to process your personal data.  However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Automated decision making

If we use your personal data for the purposes of automated decision-making (a decision solely by automated means without any human involvement) and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge to such decisions under the GDPR. You may request human intervention, express your point of view, and obtain an explanation of the decision from us.  This right does not apply in the following circumstances:

  • where the decision is necessary for the entry into, or performance of, a contract between DCA and you;
  • the decision is authorised by law; or
  • you have given your explicit consent to such processing.

Profiling

Where DCA uses your personal data for profiling purposes (automated processing of personal data to evaluate certain things about data subjects), the following shall apply:

  • clear information explaining the profiling will be provided, including its significance and the likely consequences;
  • appropriate mathematical or statistical procedures will be used;
  • technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
  • all personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

If you wish to exercise any of the rights set out above, please contact us using the details set out in section 2.1 above.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Response time

We try to respond to all legitimate requests within one month of receiving the request. Occasionally, it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.