Scope and overview
This privacy notice is issued on behalf of Acacium Group and all its group companies. A full list of our group companies and their trading names can be found here, all reference to Acacium Group refers to these companies. If you require a printed copy of this privacy notice or our group companies, please contact us using the details below.
When we mention “we”, “us” or “our” in this privacy notice, we are referring to any company in Acacium Group that uses your personal data.
The controller for your personal data is Acacium Group
This privacy notice applies to you when you apply to join us as an agency worker.
Please contact us using the details below if you have any questions about this privacy notice or personal data we hold about you:
• by email to: email@example.com; or
• by writing to: Data Protection Officer, Acacium Group, 9 Appold Street, London, EC2A 2AP
Thornbury Nursing Services is a trading name of Independent Clinical Services Limited.
Company registration number: 4768329. Registered in England and Wales.
Registered office address: 9 Appold Street, London, EC2A 2AP
If you have any concerns about the personal data we use about you, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, by contacting them at www.ico.org.uk. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please feel free to contact us in the first instance.
We regularly review this privacy notice and will update it where necessary. We do recommend you regularly review this privacy notice to make sure you have the most up to date information. This privacy notice was last updated on 12/01/2021.
For information in relation to our processing of your data relating to COVID-19 vaccinations and testing, please click here.
1. When will this privacy notice apply?
This privacy notice will apply to personal data that we collect from you when:
- you complete an application form via the website for a job opportunity
- you meet us at a recruitment fair and give us your details to start the recruitment process;
- you speak to us on the telephone (which may be recorded for quality and monitoring purposes) in relation to applying for a job opportunity and we take you through the recruitment process;
- you email your CV or documents relating to a job opportunity to one of our recruitment team and we contact you to start the recruitment process.; or
- you provide your details on a social media site or job board site, indicating that you are looking for job opportunities and we contact you to start the recruitment process.
We are committed to ensuring that your privacy is protected. If you provide us with personal data, you can be assured that it will only be used in accordance with this privacy notice.
2. What is the lawful basis for using your personal data?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data for purposes below. These are commonly called the lawful basis for processing.
- Performance of a Contract – processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering a contract.
- Legitimate Interests – processing is necessary for the purpose of the legitimate interests pursued by Acacium Group or a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data.
- Legal Obligation – processing is necessary for our compliance with a legal obligation and/or regulatory obligation to which Acacium Group is subject to.
- Consent – you have given your consent to the processing of your personal data for the processing detailed in this privacy notice.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose in this privacy notice.
Please note that throughout the recruitment process and while you are an agency worker you will not be subject to any automated decision making.
The table below sets out the personal data that we collect and use about you and the lawful basis we will rely on as set out above.
Who does this apply to? Personal data we obtain Purpose for processing Lawful basis Agency Workers Basic contact details:
full legal name;
email address; and
- To enter into a contract with you for our services
- To enable you to have a preference as to how we contact you
- To enable us to communicate and manage our relationship with you while finding you suitable job opportunities and while you work with us
- To enable you to receive job alerts for suitable job opportunities
- To enable us to send you business communication relating to working with Acacium Group
- To enable us to identify you when placing you into a potential job opportunity
Performance of a Contract
- To conduct background checks to ensure you are safe to work with Acacium Group’s clients and individuals
- To enable us to send you any legal or regulatory changes that may affect you, for example changes to tax regulations
Legal Obligation Agency Workers Identity documents:
driving licence; or
- To verify that your identity is correct
Legal Obligation Agency Workers Proof of address documents:
utility bills; or
- To verify your address is correct
Legal Obligation Agency Workers Date of birth*
- To verify your identity against required documentation
- To conduct background checks to ensure you are safe to work with Acacium Group’s clients and individuals
Legal Obligation Agency Workers Next of kin
- To be able to contact someone on your behalf in the event of an emergency
Legitimate Interests Agency Workers Proof of your immigration status and legal right to work*
- To demonstrate that you can legally work in the country where the job opportunity is
Legal Obligation Agency Workers Proof of a change of name*
- To verify your identification for legal and regulatory requirements if other documents are in a different name
- To confirm that we have the most accurate and up to date information
Legal Obligation Agency Workers Proof of a valid registration with your required regulatory body*
- To verify professional qualifications and fitness for you to legally work in your profession
- To be able to place you as a qualified professional in suitable job opportunities
Performance of a Contract Agency Workers Previous employment history with other agencies*
- To assess criteria to determine if you qualify for Agency Worker Regulation rights
Legal Obligation Agency Workers Full employment history and evidence of relevant qualifications*
- To find you suitable job opportunities in your preferred and experienced profession
- To verify professional qualifications and relevant employment history
Performance of a Contract Agency Workers Evidence of professional skills checklists*
- To conduct background checks to ensure you are safe to work with Acacium Group’s clients and individuals
- To verify professional skills to ensure that you are placed in a position where you can safely meet the required competencies
- To suitably match you to a role
Performance of a Contract Agency Workers Answers to competency interview questions*
- To verify professional qualification and experience
- To ascertain the type of role you require
- To find you suitable job opportunities in your preferred profession
Performance of a Contract Agency Workers Proof of a valid professional indemnity insurance*
- To ensure you have adequate professional indemnity insurance in place
- A requirement for us to obtain and maintain insurance policies
Legitimate Interests Agency Workers Referee details and contents of a reference*
- To conduct background checks to ensure you are safe to work with Acacium Group’s clients and individuals by gaining at least two references
- To verify your experience and fitness to work in your chosen profession
- To confirm that you can work for an agency by ensuring that you are not exceeding working hours or are not claiming any other statutory benefits whilst working for us, for example sick pay or maternity pay
- To find you suitable job opportunities in your preferred profession and match your experience and skills
Performance of a Contract Agency Workers Evidence of core competency assessments*
- To verify your compliance in core competencies to enable us to find you suitable job opportunities
- To offer you the opportunity to achieve core competencies
Performance of a Contract Agency Workers Photographs or digital images*
- To provide you with an ID badge to wear while you are working, to evidence your identity and safeguard our vulnerable clients
Legitimate Interests Agency Workers Financial information:
umbrella company details;
limited company details;
evidence of a tax code; or
evidence of statutory benefits*
- For us to meet legal requirements around tax and payment including payment for the work that you do, payment of expenses and payment of annual leave
Legal Obligation Agency Workers Details relating to:
- To provide you with appropriate time off
- To provide you with any required statutory pay
- To ensure that you are placed in a safe working environment
Legal Obligation Agency Workers Details of your availability to work and a record of shifts or placements completed with us*
- To ensure that you are meeting Working Time Regulations requirements and are taking/planning sufficient rest breaks and annual leave
- To enable us to find you suitable employment when you wish to work
Performance of a Contract Agency Workers Card payment details*
- To process your payment for criminal checks if conducted through Acacium Group
- To process your payment for core competency assessment certificates if conducted through Acacium Group
- To allow you to purchase required uniforms to enable you to represent us at work
Performance of a Contract Agency Workers Appraisal details*
- To allow us to assist in processing revalidation requirements (nurses and doctors)
- To continually assess your suitability to perform your role
- To offer support to you and continue to offer you employment
Performance of a Contract Agency Workers Details of incidents and complaints prior to joining Thornbury Nursing Services or while working with us*
- To conduct background checks to ensure a safer recruitment process
- To ensure that you are fit to work in your chosen profession
- To carry out or assist with any legal or regulatory investigations
Legal Obligation Agency Workers Market research
- To improve our services
- To find out how you heard of us
- To recommend other relevant professionals to us
3. What personal data must you provide to us to enable us to contact you or register your details for an account?
In certain circumstances you will be obliged to provide us with personal data for a legal/statutory requirement or to enter into a contract. Where this is the case we have identified these instances in the table above with an “*.” If you fail to provide the personal data when requested, we may not be able to accept you as an agency worker or continue to place you into job opportunities.
4. What special category or criminal data does Acacium Group process about you?
Through your application and throughout your time as an agency worker, it will be necessary for us to collect and use personal data about your medical history and any illnesses that you have. This information is called “special category data.” Depending on the job opportunity we will also process criminal conviction information about you via a criminal records bureau. When we collect special category data and criminal conviction data about you we will provide you with additional information about how we will use your special category data and criminal conviction data.
5. What additional personal data do we use and process about you throughout your working time with us?
Whilst you are registered with us we may be required to collect and use further personal data. This personal data may be obtained from you directly or from third parties as set out below:
- Clients – we may obtain feedback forms post placement or to support an investigation;
- Occupational health providers – to assess your suitability to remain working once you are an agency worker;
- Providers of criminal background checks – to assess your suitability to remain working once you are an agency worker;
- Umbrella companies – to facilitate payment for work completed and to ensure you are being paid correctly;
- Referees – to obtain updated references to assess your suitability to remain working once you are an agency worker;
- Regulatory bodies – to ensure you can legally remain practising in your chosen profession; or
- Law Enforcement Agencies – to comply with any requests for access to personal data.
6. Why is your personal data shared across Acacium Group of companies?
The personal data that you provide will be shared within Acacium Group, to enable us to provide our services to you and to ensure that our legal and regulatory obligations are achieved.
7. Which third parties is your personal data shared with?
We will share your personal data with the third parties set out below:
- Providers of criminal checks;
- Occupational health providers;
- Potential clients and clients (corporate and individuals);
- Our professional advisors, including accountants, solicitors, insurers;
- Training providers;
- Secondary recruitment agencies, managed services providers and master vendors;
- Third parties who provide operational services for us, for example payroll providers, IT providers and call centres;
- Regulatory or law enforcement agencies; or
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them.
We require all third parties to respect the security of your personal data and to treat it in accordance with data protection laws. Where we share your personal data with third parties who provide operational services to us, we only permit them to process your personal data for specified purposes in accordance with our instructions.
8. How will your personal data be used for marketing?
As an agency worker or someone who has shown an interest in working with us, we will occasionally send you information we feel would be of interest to you, help secure you a new role and show you the benefits of working with us.
The types of communication we may send you will include information about:
- Discounts that could be available to you while working for us
- Competitions, incentives and promotions
- Referral schemes
- Exclusive events and training
- Charities that we support
- Relevant job opportunities from our group companies
We appreciate you may not want to receive this information and whilst we’d hate for you to miss out, you can opt out by:
- Clicking on the unsubscribe link at the bottom of any marketing emails we send you
- Emailing us at firstname.lastname@example.org.
Please note that legal and service updates relating to you working with us are not direct marketing and cannot be opted out of.
We endeavor to respond to your request to stop marketing as soon as possible but this can take a few days to action. Whilst we work on your request, there is a small chance you may still receive some marketing communication.
9. Job opportunity messages
We will need to contact you to let you know what job opportunities we have available and to see if you are available for work. As this is not classed as direct marketing, you will not be able to opt-out of receiving this type of communication from the company you are registered with.
10. How long do we keep your personal data for?
We will only keep your personal data for as long as is necessary for the purposes for which it was collected. In order to determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of your personal data and the likelihood of a suitable job opportunity arising. We will also consider legal and regulatory requirements, for example where the law says we must keep your personal data for a certain period.
11. Will we transfer your data outside of the European Economic Area?
Whenever we transfer your personal data outside of the EEA, we ensure a similar 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 European Commission;
- Where we use third parties outside of the EEA, we may use specific contracts approved by the European Commission, these are sometimes known as standard contractual clauses which give personal data the same protection it has in the EEA;
If you would like more information about the methods used to transfer your personal data outside of the EEA, please contact us at email@example.com.
12. How do we safeguard 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, altered or disclosed. In addition, we limit access to your personal data to only 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 regulator of a breach where we are legally required to do so.
’Cookies are small files that are sent to your device when you visit a website or app. They stay on your device and are sent back to the website or app they came from when you visit it again.
For more information about cookies please visit www.allaboutcookies.org. You can control and delete cookies through your browser settings for more information on how to do this please visit www.allaboutcookies.org/manage-cookies.
We use the following Cookies on our website:
Type of Cookie Definition How we use that Cookie Session Cookies A Cookie that will only be stored on a device’s memory during the current browser session. Once the session has been closed the Cookie will be deleted These Cookies will allow a more streamlined use of our website. You will be able to navigate around our website and we’ll remember the pages you visited so you can easily find and reach them again Permanent Cookies A Cookie that will be permanently stored on your device and will remember information each time you revisit a website These Cookies will allow you to save login details for your next visit. These cookies are enabled through your web browser, not our website. You can view your Permanent Cookies within your web browser settings Targeted Advertising Cookies A Cookie that will remember the things you’re interested in on our website and remind you of these things through targeted adverts, sent via third party platforms After you have visited our website we may send you personalised adverts via third party platforms such as Facebook, Google or LinkedIn. These adverts are delivered to you so we can continue to engage with you and display new opportunities that may be of interest Site Analytical Cookies A Cookie that will allow an anonymised analysis of how visitors navigate and use a website We use Google Analytics to receive anonymised reports on how long visitors stay on our website, whether they apply for jobs and which of our jobs and web pages are getting the most views and interactions. This information allows us to improve user experience and make sure the content is relevant and interesting Third Party Cookies A Cookie that will appear in third party embedded content on a website, enabling the third party to monitor engagement with that content We may embed third party content onto our websites if we believe it is of interest to our website visitors or to improve their experience. This third-party content will carry a Cookie so that the content owner can measure how many people are engaging with that piece of content. We don’t control the settings of these Cookies. We recommend you check the third-party websites for more information about their cookies policy and how to manage them
14. Who is responsible for external links on our websites?
Our website may contain links to other websites provided by third parties not under our control. When following a link and providing personal data via that link please be aware that we are not responsible for the information provided by that third party. When you click on links to other websites you should read their privacy notices.
15. What rights do you have in relation to your personal data?
You have the following data protection rights when we use your personal data:
a) Your right to request access to your personal data – this enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
b) Your right to request correction of the personal data that we hold about you – this enables you to have any incomplete or inaccurate personal data we hold about you corrected, though we may need to verify the accuracy of the new personal data you provide to us.
c) Your right to request erasure of your personal data – this enables you to ask us to delete or remove personal data where there is no good reason for us continuing 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 under Section (d) where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
d) Your right to object to processing of your personal data – this enables you to object to the processing of your personal data where we are relying on legitimate interests (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
e) Your right to request restriction of processing of your personal data – this enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the personal data is unlawful but you do not want us to erase it; (c) where you need us to hold the personal data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it.
f) Your right to withdraw consent – this right arises at any time where we are relying on 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.
g) Your right to data portability – You have the right to ask that we transfer the personal data you gave us to another organisation, or to you, in certain circumstances.
If you would like to exercise any of these rights, please email firstname.lastname@example.org. In most cases we will deal with your request as soon as possible and at the latest within one calendar month of the request. If we need to extend the time period for responding to your request, we will let you know within the one-month period. We do not charge a fee for any such requests, unless there are exceptional circumstances.