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Scope and overview

This privacy notice is issued on behalf of ������������ Limited, company number 574 2788 (registered in England and Wales). Registered office: 9 Appold Street, London, EC2A 2AP.

������������ Limited is part of Acacium Group and all its group companies. A full list of all group companies and their trading names can be found at the end of this policy. The Acacium Group privacy policy can be found at

When we mention “we”, “us” or “our” in this policy, we are referring to any company in the Acacium Group that uses your personal data.

 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: dataprotection@proclinical.com; or
• By writing to: Data Protection Officer, The Acacium Group, 9 Appold Street, London, EC2A 2AP
• By writing to: Data Protection Officer, ������������ Limited, 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 . 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 12.04.2021.

At a glance:

This Policy explains when and why we collect personal information about people who enquire about roles we advertise. This policy also explains how we use that information, the conditions under which we may disclose information to others and how we keep personal information secure. At ������������ Limited we are committed to protecting and respecting your privacy and are transparent in everything we do. By using our website, you are agreeing to be bound by this Policy.

1. When will this privacy notice apply?

This privacy notice will apply to personal data that we collect from you when you:

• visit the ������������ website;
• make an initial job application on our website or through other advertising channels;
• register as a job seeker on our website;

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.

������������ Limited is registered as a data controller in the United Kingdom for the purposes of the Data Protection Act 2018. We ensure that the data you supply to us is processed fairly and lawfully. ������������ is a data controller in the USA and in compliance with the CCPA, we guarantee that we do not sell personal information, and that we support all consumer privacy rights introduced under CCPA.

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 the purposes below. These are commonly called the lawful basis for processing.

• Legitimate Interests – processing is necessary for the purpose of the legitimate interests pursued by ������������ Limited or a third-party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data.
• 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.

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.

3. What personal data must you provide to us to enable us to contact you or register your details for an account?

 We require certain personal data from you. Without this personal data, we would not be able to fulfil your request to contact you or for you to register an account with us for the purposes of finding you certain job opportunities. These fields have been marked with an “*”.

4. Why is your personal data shared across the Acacium Group of companies?

The personal data that you provide may be shared within the Acacium Group, to enable us to provide our services to you, increase the number of job opportunities available to you and improve the services of the Group. We work closely with our Life Science team at Hobson Prior, their privacy policy can be found at

The legal basis we rely upon to offer you these services are:

• Legitimate interest
• Consent
• Legal obligation
• Contractual obligation

Lawful Basis for Collecting Data
Annex A
a)       The lawfulness of processing conditions for personal data are:

1. Consent of the individual for one or more specific purposes.
2. Processing is necessary for the performance of a contract with the individual or in order to take steps at the request of the individual to enter into a contract.
3. Processing is necessary for compliance with a legal obligation that the controller is subject to.
4. Processing is necessary to protect the vital interests of the individual or another person.
5. Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller.
6. Processing is necessary for the purposes of legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the individual which require protection of personal data, in particular where the individual is a child.

b)       The lawfulness of processing conditions for sensitive personal data are:

1. Explicit consent of the individual for one or more specified purposes, unless reliance on consent is prohibited by EU or Member State law.
2. Processing is necessary for carrying out data controller’s obligations under employment, social security or social protection law, or a collective agreement, providing for appropriate safeguards for the fundamental rights and interests of the individual.
3. Processing is necessary to protect the vital interests of the individual or another individual where the individual is physically or legally incapable of giving consent.
4. In the course of its legitimate activities, processing is carried out with appropriate safeguards by a foundation, association or any other not-for-profit body, with a political, philosophical, religious or trade union aim and on condition that the processing relates only to members or former members (or those who have regular contact with it in connection with those purposes) and provided there is no disclosure to a third party without the consent of the individual.
5. Processing relates to personal data which are manifestly made public by the individual.
6. Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.
7. Processing is necessary for reasons of substantial public interest on the basis of EU or Member State law which shall be proportionate to the aim pursued, respects the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and interests of the individual.
8. Processing is necessary for the purposes of preventative or occupational medicine, for assessing the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of EU or Member State law or a contract with a health professional and subject to the necessary conditions and safeguards.
9. Processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of healthcare and of medicinal products or medical devices, on the basis of EU or Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the individual, in particular professional secrecy.
10. Processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard fundamental rights and interests of the individual.

5. Which third-parties is your personal data shared with?

We will share your personal data with the third-parties who provide operational services for us, for example, IT platforms, our recruiting CRM.

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.

• Our third-party suppliers include, but are not limited to, Bullhorn, Daxtra, RSM In Time, Keybridge Solutions and Fuze. 

6. 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.

7. Will we transfer your data outside of the European Economic Area?

As an international organisation, we may transfer your personal data globally within ������������ Limited and within the Acacium Group. Additionally, we may transfer your personal data to third-parties who are outside of the UK and European Economic Area (EEA).
Data, which we collect from you, may be stored and processed in and transferred to countries including but not limited to:

• Countries in the European Economic Area (EEA)
• USA
• Australia
• Singapore
• Japan

Please note that data is not transferred with our entity in China, in compliance with US Data Protection regulations.

Whenever we transfer your personal data out 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 the EEA, please contact us as dataprotection@proclinical.com / dpo@acaciumgroup.com

8. 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, 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.

9. How do we use cookies?

Information about how you use our website is collected automatically using “Cookies”. Cookies are small files that are recorded in temporary Internet Folders on your PC, they provide information regarding the computer used by a visitor. We may use cookies where appropriate to gather information about your computer to assist us in improving our website.

We may gather information about your general internet use by using the cookie. Where used, these cookies are downloaded to your computer and stored on the computer's hard drive. Such information will not identify you personally. It is statistical data which does not identify any personal details whatsoever.

You don’t have to accept cookies. Most browsers allow you to refuse cookies by activating the relevant setting, (please check the help menu of your browser for more details) however, selecting this setting may mean you are unable to access certain parts of our site. You can adjust the settings on your computer to decline any cookies if you wish. This can easily be done by activating the reject cookies setting on your computer.

Further Detail on Cookies

Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies do lots of different jobs, like letting you navigate between pages efficiently remembering your preferences, and generally improve your web site experience. They can also help to ensure that adverts you see online are more relevant to you and your interests.

We can split cookies into 4 main categories:
Category 1: strictly necessary cookies
Category 2: performance cookies
Category 3: functionality cookies
Category 4: targeting cookies or advertising cookies

Category 1 – Strictly necessary cookies

These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies, services you have asked for, like registering for job alerts, can not be provided.

Please be aware our site uses this type of cookie.

Category 2 – Performance Cookies

These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get an error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.

By using our website and online services, you agree that we can place these types of cookies on your device.

Category 3 – Functionality Cookies

These cookies allow the website to remember choices you make (such as your user name and password) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymous and they can not track your browsing activity on other websites.

By using our website and online services, you agree that we can place these types of cookies on your device.

Category 4 – targeting cookies or advertising cookies

These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisations.

We do have links to other web sites and once you access another site through a link that we have provided it is the responsibility of that site to provide information as to how they use cookies on the respective site.

You can find more information about cookies by visiting  or  . Google also have a brief video which explains the use of cookies.

10. Who is responsible for external links on our website?

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.

11. What is Profiling?

We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively. We may also use your personal information to detect and reduce fraud and credit risk.

12. What Social media features are on our website?

Our website includes social media features, such as the Facebook Like button, and widgets, such as the Apply with LinkedIn button or interactive mini-programs that run on our sites. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. This Privacy Policy does not apply to these features.

Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.
  

13. What log files do we collect?

We may collect demographic information, such as your postcode, age, gender, preferences, interests and favourites using log files. There is also information about your computer hardware and software that is automatically collected by us, including your IP address, browser type, domain names, access times and referring website addresses. This information is used by ������������ to maintain quality of service to individuals and provide general statistics regarding use of the website. For these purposes, we do link this automatically-collected data to personal information such as name, email address, address, and phone number.

14. Telephone recording and monitoring

Telephone calls may be recorded by ������������ for quality monitoring, training, compliance and security purposes. External calls made by employees may also be recorded by ������������. These recordings will only be used for the purposes specified in this policy.
We shall ensure that the use of these recordings is fair and that we comply with the requirements of the relevant legislation. This includes: 

• The Privacy and Electronic Communications Regulations 2003
• The Regulation of Investigatory Powers Act 2000
• The Telecommunications (Lawful Business Practice) (Interception of Communications Regulations) 2000
• The Telecommunications (Data Protection and Privacy) Regulations 1999
• The Data Protection Act 2018
• The Human Rights Act 1998

Under normal circumstances a call will not be retrieved or monitored unless: 

• It is necessary to investigate a complaint
• It is part of a management 'spot check' that customer service standards are being met
• There is a threat to the health and safety of staff or visitors or for the prevention or detection of crime
• It is necessary to check compliance with regulatory procedures

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:

1. 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.
2. Your right to request correction of the personal data 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.
3. 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.
4. Your right to object to the 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 overrides your rights and freedoms.
5. 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.
6. 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.
7. 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 dataprotection@proclinical.com. 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.

Acacium Group Limited Structure of Companies
Companies located within the Economic European Area
Accident and Emergency Limited
Frontline Staffing Limited
Trading as:

• Frontline Nursing
• Frontline Social Work

General Medicine Group Limited
GP World Limited
Health Personnel Solutions Limited
Hobson Prior International Limited
Hobson Prior Europe GMBH
ICS Ingage Limited
ICS Operations Limited
Trading as:

• Xyla Health and Social Services
• Xyla Diagnostics
• Xyla Digital Therapies
• Xyla Elective Care

Independent Clinical Services Limited
Trading as:

• Scottish Nursing Guild
• Thornbury Community Services
• Thornbury Nursing Services

Liquid Personnel Limited
Maxxima Limited
Pathology Group Limited
������������ Limited 
������������ GmbH – Germany
������������ AG – Switzerland
Pulse Healthcare Limited
Trading as:

• Bank Partners
• Espirita
• Xyla Health and Wellbeing
• Pulse Allied Health Professions
• Pulse Doctors
• Pulse Health Science Services
• Pulse Nursing
• Pulse Nursing at Home
• Pulse Psychiatry
• Pulse Psychological Therapies
• Pulse Social Work

Surgical People Limited
Titan Recruitment Solutions
Locations Outside of the EEA
������������ Staffing Inc US (New York, Boston, Philadelphia, San Francisco, Los Angeles)
ICS US Healthcare Staffing LLC t/a/ Thornbury Nursing Services (USA)
������������ Consultancy China
������������ Limited KK – Japan
������������ Pte Ltd Singapore
Pulse Staffing Australia Pty Limited
Trading as:

• Pulse Child Care Crew
• ������������ (Australia)
• Pulse Nursing