This privacy notice explains how we use any personal information we collect about you.
Who is this privacy notice from?
If you have registered online or by phone or email with SW Locums, because you contacted us or we contacted you with regards to finding work. work. You may also be an employer, adviser or client who has passed us your details requiring our services. As required by data protection law, this privacy notice gives you information from the data controller who uses your personal data in the effort to meet your needs.
SW Locums Ltd is the data controller, SW Locums Ltd is the Recruitment agency business. SW Locums has been providing recruitment services since November 2009. The services we provide helps employers and to job seekers to find suitable employment.
What is this privacy notice about?
The privacy notice explains how SW Locums Ltd will use any personal data they collect from you. It also covers any personal data we collect from the employer, adviser or intermediary umbrella company who job seekers have appointed to managed their pay. The notice also explains how SW Locums Ltd will comply with data protection law.
SW Locums Ltd needs personal data about you and your employer to run the service and to pay and charge accurately. In legal terms, the SW Locums is a ‘data controller’ for this information. So, in this notice, the SW Locums must explain some things about the personal data it holds, and your rights regarding the data.
As provider of the service, SW Locums Ltd needs personal data about you to provide its support and administration services to its job seekers, HMRC and clients. SW Locums Ltd uses the data to act as a source of information for the clients, providing required information about the job seeker to meet compliance and safeguarding requirements of the client. SW Locums Ltd does this through research on the client vacancies available and then uses the job seekers information to fulfil its clients requirements within governance and regulatory standards. SW Locums Ltd also uses research to help it communicate with other clients, to raise their awareness of the job seekers availability to assess the suitability of options and vacancies offered to its clients and job seekers. As SW Locums Ltd has some control over how it carries out its processing, SW Locums Ltd is also a ‘data controller’. So, SW Locums Ltd also needs to tell you about the personal data it keeps about you, any processing activities it carries out separately from the SW Locums and your rights regarding SW Locums Ltd’s use of your data.
The privacy notice tells you about the personal data that SW Locums Ltd hold. Each staff member may hold different data, for different reasons. This means they each take their own decisions about your personal data and how they use it. They all work under the SW Locums Ltd data controller, which means they take decisions together. Examples could include sending communications to other staff members to raise their awareness of availability available to them, or whenever the staff member requires consent to consider a particular candidate for a possible role.
For simplicity, SW Locums Ltd give you just one point of contact. SW Locums Ltd Managing Director is the appointed Data Protection Officer for SW Locums Ltd and is responsible for monitoring SW Locums Ltd’s compliance with data protection law. So if you have a question or complaint about the processing of your data, or if you wish to use your rights under data protection law, then you should contact SW Locums Ltd’s Data Protection Officer. They will then liaise on your behalf.
What personal data do SW Locums hold about you?
Information SW Locums Ltd holds
If you are a candidate, SW Locums Ltd holds the following types of personal data about you:
- Your name, date of birth, national insurance number.
- Photographic ID
- Proof of eligibility to work in the UK
- Copy of enhanced DBS application/certificate and information about criminal convictions and offences
- Proof of address
- Bank account information if you accept a post via SW Locums Ltd.
- Qualification certificates
- Relevant membership body certification or membership number.
- Contact details, including your address, phone number and email address.
- Details of your employment history, how long you worked for them and your salary from time to time.
- Whether you are married or in a civil partnership and other information SW Locums Ltd may need to pay any death benefits should they be applicable.
- If your pay from SW locums forms part of a divorce settlement, details of it.
If you are an employer, intermediary or adviser, SW Locums Ltd holds the following types of personal data about you:
- Primary contact name, company address and job title, email and phone number.
- Intermediary/adviser contact name, company address, email and phone number.
- Employer’s bank account information.
SW Locums may sometimes use other information about you. This could include information about your health if it is relevant to, client requirements for a particular post,, or details about personal relationships to help decide if a post is appropriate.
Additional information SW Locums Ltd may collect about you:
SW Locums may also collect:
- References from previous employers/agencies.
- information on how your preferred payment method of Umbrella company.
- Alternative unique identifiers such as driver’s licence and proof of National Insurance registration, which help to confirm your identity.
Where do the SW Locums obtain your personal data?
Some of SW Locums Ltd information comes directly from you. SW Locums Ltd may also get information (such as your salary and length of service) directly from your current or previous employer/s or their representative/adviser.
Personal data in application forms will come from you as an applicant. Personal data about applicants dependants, will also come from you or an individual passing your details as a recommendation to SW Locums Ltd. If we ask you for other information in future (for example, about your health), SW Locums Ltd will explain whether you have a choice about providing it and any consequences if you don’t do so.
SW Locums Ltd may receive personal data about you when you contact us by doing any of the following:
- Registering using the SW Locums.com website.
- Applying via telephone, social media or via the website above.
- Contacting SW Locums Ltd via webchat, phone, email, post or otherwise.
- Response to advertising job portals such as indeed.com, Reed.com, CVLibrary etc
- Attending worksite presentations, roadshows or other events.
- Participating in competitions and promotions run by SW Locums Ltd.
What is the legal basis for SW Locums Ltd using your personal data?
SW Locums Ltd must by law provide a service in line with the client and job seekers requirements.
SW Locums Ltd will use your personal data to comply with these legal obligations, to establish and defend its legal rights, and to prevent and detect crimes such as fraud. It may need to share your personal data with other people for this reason, such as courts and law-enforcement agencies. SW Locums Ltd also has a legitimate interest in properly looking after clients and Job seekers. This includes ensuring that candidates are informed of suitable vacancies and obtaining candidate’s right to represent them should they wish to be considered. SW Locums Ltd will meet its obligation to pay both accurately and promptly ensuring that correct levels of contributions are deducted for holiday pay and that benefits are correctly calculated, and paid upon request.
To achieve this, SW Locums Ltd may share your personal data with various entities, including its outsourced payroll/back office partner Integra Back Office Solutions Ltd; employers; Integra Back Office Solutions Ltd professional advisers; auditors; insurers; HMRC; the Pensions Ombudsman; and IT and data storage providers and other service providers. If you choose to change your method of remuneration then you must inform SW Locums Ltd immediately so that the benefits are transferred to the new umbrella/method of payment supplier. SW Locums Ltd will also need to give the administrators of that scheme information about you.
When SW Locums Ltd need to use information about your health (or other very personal and private information), it may ask your consent. However, sometimes there may be reasons of public interest or law that enable SW Locums Ltd to use this information without consent. SW Locums Ltd will do this if it helps to reach both candidates and clients’ requirements sensibly. You can withdraw your consent at any time by contacting SW Locums by email or the contact details contained on the website. This may affect what SW Locums Ltd can do for you, unless it has another lawful reason for using your information.
SW Locums Ltd may also share your personal data with someone else if you have given your consent – for example, if you require a specific entity to utilise your data. Sometimes your personal data may be used for statistical research but only in a form that no longer identifies you.
How you can contact the other people SW Locums Ltd has given your personal data to
Some of the people mentioned above just use your personal data in the way SW Locums tells them. However, others may make their own decisions about how they use this information to perform their services or functions, or to comply with regulatory responsibilities as controllers in their own right. In this case, they are subject to the same legal obligations as SW Locums Ltd regarding this information.
The rights you have regarding your information apply to them too. If you want any more information from any of these recipients or to use any rights regarding the information they hold, please contact SW Locums Ltd and you will be put in touch with them.
What is the legal basis for SW Locums Ltd using your personal data including if SW Locums Ltd shares it?
SW Locums Ltd uses your personal data to use its experience and expertise to ensure you find the most suitable job. This also includes:
- processing your requests and queries
- verifying your identity and carrying out anti-fraud checks
- carrying out business processes and relevant activities including auditing, business planning, accounting and transactions.
SW Locums Ltd also has a legitimate interest in giving you high-quality service. Given the long-term nature of the market sector in which it operates, SW Locums Ltd and its customers’ lifecycle and changing needs, this interest extends to supporting you throughout and monitoring the suitability of the options you are offered. To do this, SW Locums Ltd may process your personal data for the following activities:
- Keeping your details updated, and reconnecting with you if you change address.
- Training, and improving SW Locums Ltd customer services – for example by recording telephone calls.
- Giving you additional information about current vacancies that are similar to and complement its current offering to you.
- Giving you information about other products and services you have consented to receive.
- Personalising the way information on SW Locums Ltd website is presented to you.
- Advertising that promotes SW Locums Ltd content and services to visitors over the internet or social media. People targeted by online advertising are anonymous to both SW Locums Ltd and its marketing service providers.
- Certain telephone calls may be received by a third-party administrator on SW Locums Ltd’s behalf. SW Locums Ltd may also use Calling Line Identification information to provide its services, offer help, and improve its efficiency.
SW Locums Ltd may share or disclose personal data when necessary to provide its services or conduct its business operations. When SW Locums Ltd shares personal data, it does so in line with data privacy and security requirements. Sharing information enables it to better understand your needs and manage the product or service it provides to you in the most efficient way. If you want any more information from any of the recipients or to use any rights regarding the information they hold, please contact SW Locums Ltd using the details at the end of this notice.
Below are the parties with whom SW Locums Ltd may share personal data and why:
Within SW Locums Ltd
Personal data may be shared with other staff within SW Locums Ltd to allow it to efficiently carry out various activities including administration, customer and technical support, marketing and business and product development. All SW Locums Ltd employees and contractors must follow its data privacy and security policies when handling personal information.
Third-party service providers
SW Locums Ltd provides personal data to these third parties when they need it to fulfil their services to SW Locums Ltd. Their services include software, systems, and platform support; print and mailing services; data-quality services; payroll; overflow call centre; investment management; archiving and destruction services; auditors and actuaries; cloud hosting services; and data analytics.
SW Locums Ltd third-party service providers are not permitted to share or use personal information that SW Locums Ltd makes available to them for any other purpose than to provide their service. When SW Locums Ltd outsources any process, it will ensure any supplier or contractor has adequate security measures in place.
Third-parties for legal reasons
SW Locums Ltd will share personal data when it believes this is needed to comply with legal obligations and to respond to requests from government agencies, including law-enforcement and other public authorities such as regulators. Personal data may also be shared with your employer or their adviser but only as required to comply with pension or automatic-enrolment requirements.
Marketing from SW Locums Ltd
SW Locums Ltd will only use your personal data to manage your requirements or services and to communicate with you about information that may be of interest. However, sometimes SW Locums Ltd would like to contact you with details of other vacancies or services it provides. You can choose to receive these types of communications by contacting us – see ‘Managing your preferences with SW Locums Ltd”.
Managing your preferences with SW Locums Ltd
SW Locums Ltd aims to ensure you only receive communications about information that is of interest to you or that enhances its services to you.
You can opt out of marketing or communications that are not required by law or not required to efficiently manage your product and service.
You may also opt out of certain data processing activities such as research and data analysis.
To do this, call SW Locums Ltd on 01920 823775.
Children’s privacy and how SW Locums Ltd will approach this
SW Locums Ltd may process personal data about children. But this is only likely if the children are named as a next of kin or make direct contact with SW Locums Ltd or if they feel they may be applicable to receive any benefits on your death.
If SW Locums Ltd finds personal data about a child/children in an application form, SW Locums Ltd will (if necessary) issue its separate ‘child facing’ privacy notice to the child/children.
(SW Locums Ltd looks at such forms when it needs to use its discretion) to decide who is a beneficiary after your death. The ‘child facing’ privacy notice would be sent ‘care of’ the surviving parent or guardian if that is appropriate. SW Locums Ltd will usually only do this if it decides to make the award to the nominated child beneficiary – for example, if it is anyway going to write to the child (or the surviving parent or guardian) to give the Child a favourable decision.
SW Locums Ltd may ask for consent (including from the surviving parent or guardian) to process the child’s personal data on the application form, where relevant. However, there may be reasons of public interest or law that enable SW Locums Ltd to use the personal data about the child without consent. If possible, the SW Locums Ltd will rely on those alternatives to act in the most sensible way.
For how long do the SW Locums Ltd keep your personal data?
SW Locums Ltd needs to keep some of your personal data long enough to make sure it can satisfy its legal obligations regarding its obligations to its clients.
SW Locums Ltd will keep your information for long enough to ensure that, if a query arises in the future about your application, it has enough information to deal with it if it has a legal obligation to do so. To meet this aim, most of the personal data that SW Locums Ltd holds will be kept for 15 years from the end of the final placement or initial registration.
However, some information may be kept for more or less time depending on how long the SW Locums Ltd sensibly thinks it needs it to deal with its legal obligations mentioned above, and any queries or complaints. (These may come from you or the clients or a third party/others who may ask SW Locums Ltd.)
When SW Locums Ltd no longer needs personal data, it will dispose of it in line with approved company processes. These will ensure all reasonable efforts and precautions are taken to protect the confidentiality of the data. If data is kept as evidence of payment, it will be archived and reduced to the minimum information needed to allow identification and confirmation of any claim or payment.
Keeping your personal data safe
When SW Locums Ltd passes your information to another person, it seeks to ensure that the other person has appropriate security measures in place to keep your information safe and to comply with general principles regarding data protection.
Some of the people (this includes organisations) that SW Locums Ltd shares your information with may process it overseas. This means your personal data may sometimes be transferred outside the UK and the European Economic Area. Some countries already provide adequate legal protection for your personal data. In other countries, additional steps will be needed to protect it.
You can contact SW Locums Ltd for more information about its safeguards for ensuring that your personal information is adequately protected in these circumstances (including how to get copies of this information).
Customer Data held directly by SW Locums Ltd is stored on secure servers, managed by Nasstar, see their separate GDPR policy on the relevant tab. They do not transfer customer data outside the European Economic Area. SW Locums Ltd holds data in various forms, including electronic databases and minimal paper files. It takes all reasonable steps necessary to ensure your data is adequately protected and processed in line with this privacy notice.
SW Locums Ltd work with third party organisation during their business activities and it is sometimes necessary for these suppliers to receive and store data on SW Locums Ltd’s behalf. SW Locums Ltd does detailed checks (‘due diligence’) on these organisations that includes detailed questionnaires about their information security, data protection and encryption policies and procedures.
SW Locums Ltd take data security seriously. Their data security policies and procedures are regularly reviewed internally and independently. A summary of their data governance processes is published externally.
How you can help to keep your personal data up to date
SW Locums Ltd need to ensure your personal data is accurate and up to date. Please tell them if your details change (for example, if you move address). In addition, you have rights under data protection law to have inaccurate personal data corrected and incomplete data completed.
For more details about your rights, please see below.
Your rights as a data subject against SW Locums Ltd
You have the right to lodge a complaint directly with the supervisory authority, the Information Commissioner who can be contacted on 0303 123 113. You may be asked to provide proof of identity when making these requests.
You have other rights under data protection law that you can exercise against SW Locums Ltd but these do not apply in all circumstances. You can exercise those rights free of charge except in very limited circumstances, which will be explained to you if relevant.
For more information about all these rights, and how to exercise them against SW Locums Ltd, please contact SW Locums Ltd who will be able to tell you more.
Here are short descriptions of your rights:
Right of access – you have a right to request access to your personal data, to obtain confirmation that it is being processed, and to obtain certain prescribed information about how it is processed.
Right of rectification (correction) – in certain circumstances you have a right to ask for your personal data to be corrected if it is inaccurate, and completed if it is incomplete. Where your personal data in question has been disclosed to organisations, they must be informed of the rectification if possible.
Right to be forgotten – in certain circumstances, you can ask to have your personal data erased. It is unlikely to be possible to accept your request if, for example, SW Locums and/or its partner organisations has a legal duty to retain or process your information.
Right to restriction of processing – if certain conditions apply, you have a right to restrict the processing of your information. This includes when you contest it as being inaccurate (until the accuracy is proved); if you have objected to the processing (when it was necessary for legitimate interests) and SW Locums Ltd (as relevant) is considering whether its legitimate interests override your own; if you consider that the processing is unlawful (and if this is true) so that you can oppose erasure and request restriction instead; or if SW Locums Ltd no longer need the personal data for the purposes they held it but you require them to continue to hold it to establish, make or defend legal claims.
Right of portability – in certain circumstances, you have the right to move, copy or transfer your personal data to another organisation or to yourself. This right is only relevant if personal data is being processed based on a consent (or for performance of a contract) and is done automatically. This right is different from the right of access (see Your rights as a data subject against SW Locums Ltd above) and the types of information you can get under the two separate rights may be different. Using the data portability right, you cannot get all the personal data you can get using the right of access.
Right to object – in certain circumstances, you have the right to object to certain types of processing of your personal data when it is based on legitimate interests, when it is processed for direct marketing (including profiling relevant to direct marketing) or when it is processed for the purposes of statistics. Your rights to object may be relevant if you wish to find out more about what legitimate interests SW Locums Ltd rely on (as are listed in their respective parts of this privacy notice) or about what profiling SW Locums Ltd does regarding its direct marketing. Please note that SW Locums Ltd does not do direct marketing. You can adjust your preference settings by contacting SW Locums Ltd.
Automated decision making – SW Locums Ltd does not make automated decisions. SW Locums Ltd may profile your data for marketing and communication purposes, which you can opt out of. It does not do any automated decision-making that would produce legal or other significant effects on you. You can also withdraw consent if you have provided it and if this is being relied on as the legal basis for using your personal data – as previously described.
Changes to this privacy notice
This notice was last updated 27th February 2018. SW Locums Ltd may amend this privacy notice from time to time to keep it up to date or to comply with legal requirements. If you have access to the internet, you should regularly check this privacy notice for updates. If necessary, you may be notified of changes. Your contact details (as previously described) would be used for this purpose, based on the legal basis of compliance with legal obligations or legitimate interests (or both, as relevant).
How to contact SW Locums Ltd
If you wish to make a complaint, find out more information about how your personal data is being processed by or on the behalf of SW Locums Ltd as your data controller, or exercise your rights, you can contact SW Locums Ltd (below).
You can write to the Data Protection Officer, SW Locums Ltd, 3 Hamels Park Barns, Buntingford, SG9 9NE.