Welcome to the Locate a Locum privacy notice.
Locate a Locum is in the business of providing a web and mobile based platform to help healthcare professionals find healthcare providers who want to engage their services, and healthcare providers find healthcare professionals who want to provide services. For the purposes of this privacy notice, such healthcare providers are referred to as “Clients” and healthcare professionals are referred to as “Locums”.
Locate a Locum respects your privacy and is committed to protecting your personal data. This privacy notice explains when and why we collect personal data about individuals, how this information is used, the conditions under which it may be disclosed to others and how it is kept secure.
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Locate a Locum collects and processes your personal data through your use of this website (locatealocum.com) and our mobile applications, as well as personal data that you give to us by entering information via our website, mobile applications, social media platforms, and/or corresponding with us by phone, email or otherwise.
Our website and our mobile application is not intended for children and we do not knowingly collect personal data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are processing personal data about you so that you are fully aware of how and why we are using your personal data. This privacy notice supplements the other notices and is not intended to override them.
Locum Match Limited trading as “Locate a Locum” (a company registered in Northern Ireland with company number Nl637219 and registered address at Unit 25, 8 Cromac Avenue, Belfast, BT7 2JA) is the data controller in relation to the processing activities described in this notice (collectively referred to as "Locate a Locum", "we", "us" or "our" in this privacy notice). This means that Locate a Locum is responsible for deciding why and how your personal data is processed.
Locate a Locum also acts as a data processor in certain instances where it processes personal data on behalf of Clients as part of its services and/or provision of its platforms. In these circumstances, the Client will act as data controller and Locate a Locum will process your personal data on their behalf as a data processor. This privacy notice only relates to personal data where Locate a Locum is the data controller. Where Locate a Locum is a data processor, it has contracts in place with the relevant data controller in accordance with data protection laws.
Changes to the privacy notice and your duty to inform us of changes
We keep our privacy notice under regular review. If we change our privacy notice we will post the changes on this page, and place notices on other pages of the website, so that you may be aware of the information we collect and how we use it.
Any changes will take effect 7 days after the date on which we post the modified terms. Please check this page occasionally to ensure that you’re happy with this privacy notice. If you do not agree with any aspect of the updated notice you must immediately notify us and cease using our services.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes by using the contact details at the end of this notice.
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 notices. When you leave our website, we encourage you to read the applicable privacy notice. In addition, if you linked to our website from a third party website, we cannot be responsible for that third party website and recommend that you check the applicable privacy notice.
2. The data we collect about you
Personal data means any information about an individual from which that person can be identified. It does not include data where the individual can no longer be identified (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name, maiden name, last name, photograph, username or similar identifier, marital status, title, date of birth and gender. • Contact Data includes email address and telephone numbers. • Professional Data includes employment history, professional qualifications, certifications, references, CV and any other information required by a Client to assess your ability to be engaged by them. • Screening Data includes the results of pre-employment screening or vetting checks (including the results of any police or similar checks and any information you provide relating to current and/or spent criminal convictions uploaded to the platform during registration. • Financial Data includes bank account details. • Transaction Data includes details about payments to and from you and other details of services you have purchased from us. • 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, session bookings, preferences, feedback and survey responses. • Usage Data includes information about how you use our website and services. • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. • Communications you send to us for example when you ask for support, send us questions or comments or report a problem. • Legal includes information relating to any legal claims made by you or against you or the claims process.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. If we combine Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat such combined data as personal data which will be used in accordance with this privacy notice.
We collect Special Categories of Personal Data about you (this includes details about your trade union membership, information about your health and genetic and biometric data). An example of special category data would be a Locum’s photograph and information about criminal convictions and offences. Information collected in relation to criminal convictions and offences is in accordance with the authorisation of UK law and is a requirement for healthcare professional s to be able to provide healthcare professional services in the UK.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect personal data from and about you including through:
• Direct interactions. You may give us personal data via our website, mobile applications, social media platforms, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide voluntarily when you: o apply for our services;
o create an account on our website;
o subscribe to our service or publications;
o report a problem with our website;
o request marketing to be sent to you; or o enter a competition, promotion or survey; or o give us some feedback.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources including professional registration bodies whose registers are publicly available and which we will use to verify your registration.
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:
• to keep your account secure and protect our services (including to verify the identities of creators and prevent fraud and abuse); • to enable us to provide you with our services, and to improve and promote our services; • to create and administer your account, contact you, and customize your experience on Locate a Locum (for example, to show you jobs or shifts that we think may interest you based on your previous use); and • to track and analyse use of the services so that we can improve how Locate a Locum is performing and provide users with the best experience possible.
__Purposes for which we will use your personal data __
Data protection law requires us to have a lawful ground for collecting and processing your personal data. The lawful bases on which we will process your personal data are:
• Performing the contract we have with you: we may use and process your personal data where we have supplied you (or continue to supply you) with any services or where you are in discussions with us about any new service. We will use this information in connection with the contract for the supply of services when it is needed to carry out that contract or for you to enter into it.
• Legal requirement: Sometimes the law says we need to collect and use your personal data. For example, tax laws require us to retain records of payments made through our services. • Legitimate interests: This is a technical term in data protection law which essentially means we have a good and fair reason to use your personal data and we do so in ways which do not hurt your interests and rights. We sometimes require your personal data to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and that does not materially impact your rights, freedom or interests. This includes: o for marketing activities; o for analysis to inform our marketing strategy, and to enhance and personalise your customer experience (including to improve the recommendations we make to you on our website); o to analyse how users interact with our site so we can understand better what elements of the design are working well and which are not working so well. This allows us to improve and develop the quality of the online experience we offer all our users; o to correspond or communicate with you; o to verify the accuracy of data that we hold about you and create a better understanding of you; o for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
o for prevention of fraud and other criminal activities; o to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing
purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request); o for the management of queries, complaints, or claims; and o for the establishment and defence of our legal rights. • Consent: we may use and process your personal data where you have consented for us to do so, including to contact you via email or text with marketing information about our services (other than where we rely on legitimate interests) or where we process Special Categories of Personal Data for certain purposes. You have the right to withdraw consent to marketing at any time by contacting us. 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 personal data.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in section 4 above.
• Group companies - we may share your information with other companies within the Locate a Locum group in connection with the services and for internal business purposes.
• Clients – if you apply for a shift or job provided by another company, we may receive and/or share your personal data with that company in order to manage and provide our services. We only disclose to them the personal data that is necessary.
• Our third party service providers - we may share your information with third party service providers, agents, subcontractors and other organisations for the purposes of providing services to us. Such services may include cloud service providers (such as hosting and email management), software or IT maintenance providers, CRM providers, API integration companies, data backup providers, advertising and marketing agencies, marketing platforms, IT developers, data analysis providers, security services providers, mailing houses, couriers, call centre providers, online behavioural advertising companies and administrative services. When we use third party service providers, we only disclose
to them any personal data that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions. • Payment processors – your bank details are processed by a third party payment processor who specialises in the secure online capture and processing of financial transactions. If you have any questions regarding secure transactions, please contact us using the details at the end of this policy. • Customer satisfaction surveys - as customer satisfaction is important to us, we may ask a third party research company to contact you for the sole purpose of gathering general information and specific information relating to us and our services. • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets or as part of a business restructuring or reorganisation. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. • Third parties for legal or compliance purposes - we may also transfer your personal data if we’re under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and clients.
We require all third parties to respect the security of your personal data and to treat 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 instructions.
6. International transfers
We occasionally transfer your personal data outside the United Kingdom (“UK”) and European Economic Area (“EEA”). By way of example, this may happen if any of our servers or those of our third party service providers are from time to time located in a country outside of the UK/EEA. These countries may not have similar data protection laws to the UK/EEA.
If we transfer your information outside of the UK/EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this notice. These steps include imposing contractual obligations on the recipient of your personal data or ensuring that the recipients are subscribed to ‘international frameworks’ that aim to ensure adequate protection. Please contact us using the details at the end of this notice for more information about the protections that we put in place and to obtain a copy of the relevant documents.
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. However, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted to our website and any transmission is at your own risk. 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.
In some circumstances we may 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.
8. Data retention
How long will you use my personal data for?
If we collect your personal data, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We do not retain personal data in an identifiable format for longer than is necessary for the purposes for which we collect it unless we believe that the law requires us to preserve it.
If you have made an enquiry or contacted us (via our website or otherwise) in relation to our services, we will store your information for as long as is reasonably required to deal with your enquiry.
If you become a Locum and open an account with us, we will retain your personal data for as long as you are an active Locum.
If your account is closed and we cease providing you with services, we will retain your personal data in case of any queries from you or in case you decide to re-activate your account for a period of 12 months from the date your account is closed.
If your account is dormant or inactive for a period of 12 months, we will close your account and retain your personal data in case you decide to re-activate your account for a period of 12 months from the date your account is closed.
If you have contacted us with a complaint, we will store your personal data for as long as is reasonably required to resolve your complaint. If you have signed up to receive email marketing from us, we will store your personal data for as long as you are subscribed to our email marketing list (even if you are no longer an active customer). If you unsubscribe, we will keep your email address on our suppression list to ensure that we do not send you marketing emails.
For further information regarding our retention periods, please contact us using the details at the end of this notice.
When it is no longer necessary to retain your personal data, we will delete the personal data that we hold about you from our systems. After that time, we may aggregate the data (from which you cannot be identified) and retain it for analytical purposes.
The exceptions to the above are where: • we need your personal data to establish, bring or defend legal claims or to comply with a legal or regulatory requirement; • the law requires us to hold your personal data for a longer period, or delete it sooner; • you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law, or you exercise your right to require us to retain your personal data for a period longer than our stated retention period (see Erasing your personal data or restricting its processing in section 11 below); or • in limited cases, the law permits us to keep your personal data indefinitely provided we put certain protections in place.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may collect your preferences to receive marketing information directly from us by email, SMS, calls, or post when you register an account with us or sign up to our newsletter. If you make an enquiry or have used our services, we may contact you with marketing information in the ways mentioned in the notices presented to you, expect where you indicate you would prefer otherwise.
We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
We may contact you with targeted advertising delivered online through social media and platforms operated by other companies by using your personal data, or use your personal data to tailor marketing to improve its relevance to you, unless you object.
You can ask us to stop sending you marketing messages at any time by logging into the website or mobile application, and checking or unchecking relevant boxes to adjust your marketing preferences. Alternatively, you can click the unsubscribe or opt-out link on any marketing message sent to you. You can also contact us using the details at the end of this notice.
11. YOUR LEGAL RIGHTS
You have a number of rights in relation to your personal data under data protection law and these are set out below. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal data. Except in rare cases, we will respond to you within one month from either (i) the date that we have confirmed your identity or (ii) where we do not need to do this because we already have this information, from the date we received your request. You have the right to:
• Request access to your personal data (commonly known as a "data subject access request"). This enables you to ask for a copy of the personal data that we hold about you by emailing or writing to us at the address at the end of this notice.
• 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 personal data you provide to us. You can change certain personal data via your online account, or alternatively, please let us know by contacting us using the details at the end of this notice.
• Request erasure of your personal data by emailing or writing to us at the address at the end of this notice. 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 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 can object by emailing or writing to us using the details at the end of this notice. 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. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes.
• Request restriction of processing of your personal data by emailing or writing to us at the address at the end of this notice. 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 personal 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. • 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. If you wish to withdraw your consent, please contact us using the details at the end of this notice.
You have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), or other relevant data protection regulator, if you are concerned about the way we have processed your personal data. Please visit the ICO website for further details (www.ico.org.uk).
We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us for a copy of our Complaints Policy in the first instance.
13. CONTACT US
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below. Our full details are:
• Full name of legal entity: Locum Match Limited • Email address: firstname.lastname@example.org • Postal address: Unit 25, 8 Cromac Avenue, Belfast, BT7 2JA • Phone: +44 (0) 2078594613