Privacy Policy

Introduction

Welcome to the Primary Care Careers’ privacy policy.  This Privacy Policy also incorporates our Cookies Policy (see below).

Primary Care Careers (“we” or “us”). We are a hosted organisation, presently hosted by Suffolk and North East Essex Integrated Care Board. Our main trading address is Aspen House, Stephenson Road, Colchester, CO4 9QR.

To contact us, please email eoe.primarycarecareers@nhs.net or telephone on 07966 211098.

We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website and after you become a Registered User (see below).  This policy and tells you about your privacy rights and how the law protects you.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Primary Care Careers collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to become a Registered User.

We provide this website to allow primary care providers such as GP Practices and Primary Care Networks to be able to advertise temporary and permanent vacancies.   The website allows individuals to browse the vacancies, or other information that we provide.  Individuals may themselves become Registered Users in order to make applications for positions advertised on our website.

In order to become a Registered User as an individual, you can register through the website.  To become a Registered User on behalf of a primary care provider in order to place vacancies with us, you will need to request registration please contact us on the details above.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide 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 notices and privacy policies and is not intended to override them. Registered Users wishing to apply for roles your information will be stored on our Applicant Tracking System, which is integrated with our website. This system is delivered through External Third Parties (see below).

Data Controller

Primary Care Careers, as a part of  Suffolk and North East Essex Integrated Care Board, is the data controller and responsible for the personal data collected in relation to the services offered through this website and in relation to the Primary Care Careers activities.

Suffolk and North East Essex Integrated Care Board has a data protection officer (DPO) Paul Cook (IG) – email: dpo.neeccg@nhs.net.  The Privacy Policy for Suffolk and North East Essex Integrated Care Board as a legal entity can be found here: Privacy and cookies – NHS Suffolk and North East Essex ICB Primary Care Careers, as a hosted body within the Suffolk and North East Essex Integrated Care Board have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy and the Primary Care Careers activities.  If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Email address: eoe.primarycarecareers@nhs.net

Postal address: Primary Care Careers, Aspen House, Stephenson Rd, Highwoods, Colchester CO4 9QR

Telephone number: 07966 211098

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 16 November 2022 any historic versions can be obtained by contacting us.

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.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you for the delivery of the services of Primary Care Careers which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth, gender and registration deals with professional bodies such as the Nursing and Midwifery Council (NMC).
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, your interests, preferences, feedback and survey responses. 
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

If you fail to provide personal data

If you do not supply the requested information to become a Registered User, you will not be able to access restricted areas of the site.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your identity and contact data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • apply for our products or services;
    • create an account on our website;
    • subscribe to our service or publications;
    • request marketing to be sent to you; or
    • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
  • cookies on our website.
  • Identity and Contact data from publicly available sources such as Companies House, professional registration bodies (such as the NMC).

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

See below to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal grounds we are relying on to process your personal data where more than one ground has been set out in the table below.

We are a hosted part of public body, carrying out tasks in relation to primary care as part of our official authority, that is the main legal basis for our processing of data in relation to the activities concerning Primary Care Careers.

Purpose/ActivityType of dataLawful basis for processing including basis of performance of a task in the exercise of official authority
To register you as a new customer or Registered User(a) Identity (b) Contact(a) Consent (a) Performance of a contract with you (c) Exercise of official authority vested in Suffolk and North East Essex Integrated Care Board in carrying out tasks  
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey (c) Providing information about vacancies on the site (see further below concerning information to Registered Workers and Registered GP Practices(a) Identity (b) Contact (c) Profile (d) Marketing and Communications(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Exercise of official authority vested in Suffolk and North East Essex Integrated Care Board in carrying out tasks.
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity (b) Contact (c) Technical(a) Necessary for exercise of official authority vested in Suffolk and North East Essex Integrated Care Board in carrying out tasks (for running our organisation, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical(a) Exercise of official authority vested in Suffolk and North East Essex Integrated Care Board in carrying out tasks and to ensure that use of the services are beneficial to Registered Users
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences(a) Technical (b) Usage(a) Exercise of official authority vested in Suffolk and North East Essex Integrated Care Board in carrying out tasks and to ensure that use of the services are beneficial to Registered Users
To make suggestions and recommendations to you about goods or services that may be of interest to you(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications(a) Exercise of official authority vested in Suffolk and North East Essex Integrated Care Board in carrying out tasks and to ensure that use of the services are beneficial to Registered Users

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you relating to the services. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You may receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing.

Integrated Care Boards and other bodies with whom we have funding arrangements may receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies & Cookie Policy

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
  • Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Change of purpose

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. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data with the External Third Parties as defined out in the glossary set out below for the purposes set out in the table above.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

6. International transfers

We will not transfer your personal data outside of the UK.

7. 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 breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably 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 keep basic information about our customers and Registered Users (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for legal purposes (defence and establishment of claims).

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we will 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.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month 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.

Glossary

LAWFUL BASIS

Exercise of official authority vested in the controller means processing necessary to carry out the functions of providing the services related to the Primary Care Careers activities and in conducting and managing this service to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for these purposes. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). 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.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

External Third Parties

  • Service providers acting as processors who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in England who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

We use third parties, such as service providers, to collect, store and process personal data on our behalf. Such service providers are only allowed to process your personal data to the extent necessary for them to provide the service we have requested from them. As a main rule, they are not allowed to use your personal data for the benefit of their own business. Our key partners include KAT Marketing https://katmarketing.co.uk/ who deliver our website maintenance and development, marketing, promotion and events; and Eploy Ltd who provide vacancy pages integrated with our website and the candidate registration / application portal – Applicant Tracking System https://www.eploy.co.uk/.

If you are applying for a vacancy, your information will be stored on our Applicant Tracking System, which is integrated with our website. The system is delivered by ITS Software Systems Limited (also known as Eploy®) and their hosting partner Rackspace UK. Rackspace facilities are SAS 70 Type II certified demonstrating that it has adequate controls and safeguards when it hosts and processes data belonging to Eploy. Rackspace engage qualified third-party auditors to perform examinations of its systems and services in accordance with: the best practice recommendations of ISO 27002, for auditing Rackspace’s compliance with ISO27001; SSAE 16 and ISAE 3402 compliance frameworks.

The website is hosted on Gyron Internet Ltd’s servers, certified as providers of secure, resilient and environmentally controlled facilities for hosting of customers business critical IT equipment certified by ISO27001

Where your information is stored will depend on your relationship with us. We may store your personal data locally on servers that are maintained by our IT provider, AGEM CSU, you can access their privacy notice on their website at https://www.ardengemcsu.nhs.uk/

For Individuals

When you enquire about job / training opportunities, we may share your information with the relevant local training hub / workforce teams working alongside us at the local level, to support you in securing the role you are looking for or to provide you with further information about the training and funding opportunities that exist locally. You can update your preferences regarding this within the candidate portal.

When you apply for a role advertised on our website, your application and subsequent onboarding details will be sent to organisation to which you are applying. You should read the relevant organisation’s privacy notices prior to applying for a job. The organisation may contact you directly in relation to your application.

When you enter your CV to our talent pool we may seek your consent to share your CV with Registered Users if we feel you match their existing or upcoming requirements. We will always seek your consent permission before sharing your CV with any organisation (where you apply for a job with a specific practice your will be consenting to the transfer of data as a part of that application).

For Primary Care Providers

We will share the details of relevant individuals at your organisation with individuals seeking to make contact with your organisation for the purpose fulfilling a role advertised through our website.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

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 (see below), 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.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular 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.

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:

  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need 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 the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent 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.