Privacy Policy

Novello Healthcare, registered in England and Wales under company number 13793724, with its registered office at120 Bark Street, Bolton, England, BL1 2AX  is committed to protecting the privacy and security of personal data provided by candidates.

This Privacy Notice sets out how we comply with the Data Protection Legislation when using our Candidates’ personal data within our App and more generally in the course of the work-finding services which we provide.

We may update this Privacy Notice from time to time. When applicable, we shall notify you of any material changes to the Privacy Notice through the App. This will ensure that you understand (i) how we are using your personal data and (ii) your legal rights around our usage of such personal data.

2. Where We Obtain Your Personal Data

We obtain personal data relating to you directly if you have: applied for a Client vacancy; uploaded your CV or submitted an enquiry through our website; registered your details in the App; provided any personal data in person, by email or through our social media channels; or had any discussions with us about finding an assignment.

We may obtain personal data relating to you indirectly from: online professional networking sites such as LinkedIn; job boards; clients who provide feedback about your assignments; referees who provide background information for vetting purposes; online industry databases (where applicable); professional regulatory bodies; and third-party background checking services such as the DBS.

3. Types of Personal Data We Hold

We typically collect, store and process the following types of personal data about you: personal contact details; gender; date of birth; nationality; place of residence; professional skills and experience; qualifications, training and certifications; proof of identity and right to work; employment history and motivation for seeking new work; background information in your CV; professional disciplinary record; working times, pay rates and bank details; your photograph; and information about temporary assignments which you have carried out.

In respect of the App specifically, we will also capture information about your device, its MAC address and operating system, your IP address and mobile service provider, and geolocation data to assist with search functionality where you authorise your device to provide this information.

We will also collect, store, and use the following “special categories” of more sensitive personal data: Information about your race or ethnicity; Information about your health, including any medical conditions, health and sickness records, inoculations; and information about criminal convictions and offences.

4. How We Use Your Personal Data

We use your personal data to: assess and verify your potential suitability for a temporary assignment with a Client; contact you in relation to any potential assignments or to establish your current working arrangements; carry out compliance checks; introduce you to our Clients; pay you for services which you have performed; comply with our legal and contractual obligations to you and third parties; defend or bring legal proceedings; and carry out equal opportunities monitoring.

5. Our Lawful Basis for Processing Your Personal Data

We have determined that we have a legitimate interest to process your personal data where you are a Candidate on the basis that it is necessary for us to maintain a database of individuals who are (i) actively seeking new assignments with a Client or (ii) potentially suitable for an assignment with a Client.

By processing your personal data and contacting you from time to time, we are able to gain an understanding of your current role (where applicable), your skills and experience, and your career aspirations. Our processing of your personal data is therefore of benefit to: You, as it assists us to identify new opportunities about which you might not otherwise been aware; Our Clients, who rely on us to have access to suitable, pre-qualified candidates who can fill their requirements; and Us, as we are a business which relies upon being able to supply Candidates to our Clients.

In some circumstances, we may also process your data: to perform a contract which we have with you. Irrespective of whether you are engaged for a temporary assignment through a third party limited company (where relevant), we will usually have a contract with you personally to provide work-finding services; or to comply with a legal obligation. For example, the Conduct of Employment Agencies and Employment Businesses Regulations 2003 require us to hold certain data about applications and placements for at least one year.

6. Our Lawful Basis for Processing Your Special/Sensitive Personal Data

We may also need to process sensitive (special) personal data relating to you. The type of sensitive personal data which we might process includes information about: medical conditions, medical history, inoculations and/or disabilities where they are relevant to the type of work which you are proposing to carry out; unspent criminal convictions and, where relevant to the type of role which you are carrying out, spent convictions, police warnings and cautions; and information about any trade union of which you are a member insofar as it relates to an employment claim or pay and working conditions.

We are acting as an employment business in our dealings with you. In accordance with the UK-GDPR, this sensitive personal data is necessary in the field of employment. i.e. it is required for performing our obligations as employment business and is used solely for this purpose. Any sensitive personal data shall be held strictly in accordance with our policies on data retention and sensitive personal data.

7. Parties with Whom We May Share Your Personal Data

We may share your personal data for legitimate purposes with: other companies within the PSR Group of companies; a Client where you have expressed an interest in being introduced to such Client or are being supplied to such Client on an assignment; any third-party which is engaged by the Client to assist them in the recruitment process including a managed service company, Recruitment Process Outsourcing provider or IT platform provider; a Client auditor; a third-party intermediary company through which you are contracting or to which you have asked to be introduced; background checking services such as the DBS; your professional regulatory body; our Suppliers, bankers and financiers; and governmental departments and agencies.

We may need to share sensitive personal data relating to you with our Clients if there is a legitimate reason to do so. For example, information about any medical condition which you have if it is relevant for health & safety purposes or relevant to your assignment. Likewise, we will share information about any convictions which you disclose.

8. Where We Process Personal Data

Your personal data is held and processed by us in the United Kingdom. We have put in place appropriate safeguards to ensure that your data is only transferred to jurisdictions with enforceable data subject rights and effective legal remedies in respect of data privacy breaches.

We will only transfer your personal data to jurisdictions outside of the UK where: the transfer is to a country within the European Economic Area; there is an adequacy decision or UK government regulation in respect of that jurisdiction; the transfer of data is subject to an approved international data transfer agreement (IDTA); or you have expressly given informed consent to the transfer of such data.

9. Automated Decision Making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. All decisions which are made in the course of our business processes involve human intervention. We do not make any decisions using automated means.

10. Data Security

We 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. If you require further information about these measures, please let us know.

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.

11. Data Retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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 requirements.

Our standard data retention period is two years from the last date on which you log into the App. After this time, we will usually delete your personal data from our records. Where we are required to keep any information (i) for auditing or compliance purposes (ii) to comply with our contractual obligations to third parties or (iii) in respect of any potential or actual legal proceedings, we shall keep your data for as long as is strictly necessary for these purposes, which is typically for seven years in respect of audit data which we may be required to produce for HRMC or to prove compliance with our contractual obligations.

12. Your Duty To Inform Us Of Changes.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

13. Your Rights In Connection With Personal Information.

Under certain circumstances, you have the right to: 

• Request access to your personal information (a 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. You will not usually have to pay a fee to access your personal information but we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with the request in such circumstances. 
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. 
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed or you have objected to the processing and there is no overriding legitimate interest for continuing the processing. 
• Object to processing of your personal information where we are relying on a legitimate interest and you object on “grounds relating to your particular situation.” 
• Request the restriction of processing of your personal information. This enables you to ask us to block or suppress the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it or if you have also objected to the processing as above. 
• Request the transfer of your personal information to another party when the processing is based on consent and carried out by automated means. This right is not usually applicable to any data processing carried out by us.

If you want to exercise any of the above rights, please contact our Data Protection Officer in writing using the details at the end of this Privacy Notice. We will consider your request and confirm the actions which we have taken in response to such request.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is an appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

14. Regulatory Complaints

If you are unhappy with any aspect of the manner in which we have processed your personal data or dealt with your decision to exercise any of the rights set out in this section, you have the right to complain to the Information Commissioners Office in the United Kingdom. Their details are:

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Tel: 0303 123 1113 (local rate) or 01625 545 745 
Email: casework@ico.org.uk

15. Definitions

This Privacy Notice uses the following defined terms: 

• App means the Novello web-application or device software which is used by Candidates in connection with the administration of temporary assignments including shift booking, timesheets and payment for completed services. 
• Candidate means a person who is registered in the App as potentially seeking a temporary assignment with a Client. 
• Client means a healthcare organisation which has engaged us to provide recruitment services. 
• Data Protection Legislation means the Data Protection Act 2018, the retained UK version of the General Data Protection Regulation ((EU) 2016/679) and all other applicable legislation in the United Kingdom relating to data protection, together with any successor legislation. 
• Supplier means a business which provides services to us and which may process personal data in the course of performing such services including our: professional advisers, insurers; IT services providers and software providers; and independent consultants and subcontractors.

16. Contact Us

If you have any questions about this Privacy Notice, please write to our Data Protection Officer at 120 Bark Street, Bolton, BL1 2AX. Alternatively, you may contact them on 0333 307 8897 or by email at hello@novellohealthcare.com.