Privacy Notice

 

Privacy notice – for members of the public

This Privacy Notice applies to anyone who access Bexley Health Limited’s (BHL) web page, a user or potential user of BHL’s services, or an applicant or potential applicant for a post at BHL.

This notice sets out how Bexley Health Limited (BHL) uses and protects any information that you give BHL when you use this website

How we use your information

This privacy notice tells you what to expect when BHL collects personal information. It applies to information we collect about:

  • visitors to our websites;
  • users of our services;
  • job applicants;

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For Visitors to our websites

This web site uses cookies for its effective operation & to record details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. Cookies are not left on your machine.

Legal basis: The legal basis we rely on for processing your personal data is legitimate interest under article 6(1)(f) of the GDPR.

If we do want to collect personally identifiable information through our website, this will be clear, & we will explain what we intend to do with it. This web site is hosted by ITRM who are bound by contract & law to maintain the confidentiality of any personal data collected via the web site.

Legal basis: The legal basis we rely on for processing your personal data is your consent under article 6(1)(a) of the GDPR.

BHL may use third party services to help maintain the security and performance of the BHL website. To deliver these services the IP addresses of visitors to the BHL website may be processed.

Legal basis: The legal basis we rely on for processing your personal data is legitimate interest under article 6(1)(f) of the GDPR.

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For people who email us

We will monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.

Legal basis: The legal basis we rely on for processing your personal data is legitimate interest under article 6(1)(f) of the GDPR.

People who use BHL’s services

BHL offers services to its clients who are various Clinical Commissioning Groups (CCGs), BHL does not contact patients until a referral has been made.

We have to hold the details of the people who have been referred for a clinical service in order to arrange an appointment. BHL receives & stores details about your referral, including your contact details, the specialty to which you have been referred, & relevant clinical data provided by your referrer, who is usually your GP. We only use these patient details in order to provide the referral management service and for other closely related purposes (such as managing the service).  Various Clinical Commissioning Groups (CCGs) contract with BHL for its services. BHL will pass on (i.e. share) the data with other healthcare organisations who will provide the appropriate clinical service for which the patient was referred.

The activities within BHL are all healthcare related (apart from processing employment data).

Patient data at BHL are stored in secure electronic databases within secure buildings.

Legal basis: The legal basis we rely on for processing your personal data is consent under article 6(1)(a) of the GDPR.

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For Job applicants

BHL is the data controller for the information you provide during the process unless otherwise stated. If you have any queries about the process or how we handle your information please contact us at the address below.

What will we do with the information you provide to us?

All of the information you provide during the process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary.

We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format.

We will use the contact details you provide to us to contact you to progress your application. We will use the other information you provide to assess your suitability for the role you have applied for.

What information do we ask for, and why?

We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary.

The information we ask for is used to assess your suitability for employment. You don’t have to provide what we ask for but it might affect your application if you don’t.

Application stage

If you use our online application system, this will be collected by a data processor on our behalf (please see below).

We ask you for your personal details including name and contact details. We will also ask you about your previous experience, education, referees and for answers to questions relevant to the role you have applied for. Our recruitment team will have access to all of this information.

You will also be asked to provide equal opportunities information. This is not mandatory information – if you don’t provide it, it will not affect your application. This information will not be made available to any staff outside of our recruitment team, including hiring managers, in a way which can identify you. Any information you do provide, will be used only to produce and monitor equal opportunities statistics.

Shortlisting

Our hiring managers shortlist applications for interview. They will not be provided with your name or contact details or with your equal opportunities information if you have provided it.

Assessments

We might ask you to participate in assessment days; complete tests or occupational personality profile questionnaires; and/or to attend an interview – or a combination of these. Information will be generated by you and by us. For example, you might complete a written test or we might take interview notes. This information is held by BHL.

If you are unsuccessful following assessment for the position you have applied for, we may ask if you would like your details to be retained in our talent pool for a period of six months. If you say yes, we would proactively contact you should any further suitable vacancies arise.

Conditional offer

If we make a conditional offer of employment we will ask you for information so that we can carry out pre-employment checks. You must successfully complete pre-employment checks to progress to a final offer. We are required to confirm the identity of our staff, their right to work in the United Kingdom and seek assurance as to their trustworthiness, integrity and reliability.

You will therefore be required to provide:

  • Proof of your identity – you will be asked to attend our office with original documents, we will take copies.
  • Proof of your qualifications – you will be asked to attend our office with original documents, we will take copies.
  • You will be asked to complete a criminal records declaration to declare any unspent convictions.
  • We will provide your email address to the Government Recruitment Service who will contact you to complete an application for a Basic Criminal Record check via the Disclosure and Barring Service, or Access NI, which will verify your declaration of unspent convictions.
  • We will contact your referees, using the details you provide in your application, directly to obtain references
  • We will also ask you to complete a questionnaire about your health. This is to establish your fitness to work. This is done through a data processor (please see below).

If we make a final offer, we will also ask you for the following:

  • Bank details – to process salary payments
  • Emergency contact details – so we know who to contact in case you have an emergency at work

 

Use of data processors by BHL

Data processors are third parties who provide elements of our recruitment service for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.

How long is the information retained for?

If you are successful, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment plus 6 years following the end of your employment. This includes your criminal records declaration, fitness to work, records of any security checks and references.

If you are unsuccessful at any stage of the process, the information you have provided until that point will be retained for 6 months from the closure of the campaign.

Information generated throughout the assessment process, for example interview notes, is retained by us for 6 months following the closure of the campaign.

Equal opportunities information is retained for 6 months following the closure of the campaign whether you are successful or not.

How we make decisions about recruitment?

Final recruitment decisions are made by hiring managers and members of our recruitment team. All of the information gathered during the application process is taken into account.

You are able to ask about decisions made about your application by speaking to your contact within our recruitment team or by emailing  bhl@nhs.net or via the web page http://bexleyhealthlimited.co.uk/contact .

Legal basis: The legal basis we rely on for processing your personal data is legitimate interest under article 6(1)(f) of the GDPR.

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Your rights

Under the Data Protection Act (2018), aligned with the General Data Protection Regulation, you have rights as an individual which you can exercise in relation to the information we hold about you. In all cases we would encourage you to discuss any of your concerns with us first. Please make your requests in writing or verbally, and we are required to respond within 1 month in most cases.

1.     The right to be informed

You have the right to be informed about the collection and use of your personal data. This is to ensure that BHL is open about what data it holds & what it does with your information. This is why this document exists.

2.     The right of access, often known as Subject Access Request (SAR)

You have the right to see what data we hold about you.

BHL seeks to be as open as it can be in terms of giving people access to their personal information. Individuals can find out if we hold any personal information by making a ‘subject access request’ under the Data Protection Act. For patients the data can be complex & full or technical terms. So we will discuss this with you to ensure that you understand what we have recorded.

If we do hold information about you we will:

• give you a description of it;

• tell you why we are holding it;

• tell you who it could be disclosed to; and

• let you have a copy of the information in an intelligible form.

3.     The right to rectification

If you think that data we hold about you is incorrect or incomplete you can ask for it to be corrected. However, in certain circumstances BHL can refuse a request for rectification. A difference of opinion is then likely to be placed on file.

4.     The right to erasure

You have the right to ask for your information to be erased. This can have a marked impact on the services we can provide to patients, so if at all possible please discuss this with us first. This is also known as ‘the right to be forgotten’. Please note that the right only applies in certain circumstances. See the link below for details.

5.     The right to restrict processing

You have the right to request the restriction or suppression of your personal data. This means that you could restrict who sees certain parts of your record. Like the right to erasure this can have quite an impact on the services we can provide so please discuss first. Please note that the right only applies in certain circumstances. When processing is restricted, BHL can still hold your personal data, but not use it.
 

6.     The right to data portability

This right allows you to obtain and reuse your personal data for your own purposes across different services. It allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without affecting its usability. This only applies to information you have provided to us.
This does not apply for paper records.
For health data, using the right of access may be more effective.

7.     The right to object

You have the right, in certain circumstances, to object to us processing your information.

8.      Rights in relation to automated decision making and profiling

This applies only if an organisation is making decisions based on your data using a computer without any human involvement. At present BHL does not do this.

You can read more about these rights here – https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/

 

 

 

Disclosure of personal information

In most circumstances we will not disclose personal data without consent. However, when we investigate a complaint, for example, we will need to share personal information with the organisation concerned and with other relevant bodies.

We can provide further information on:

• agreements we have with other organisations for sharing information;

• circumstances where we can pass on personal data without consent for example, to prevent and detect crime and to produce anonymised statistics;

• our instructions to staff on how to collect, use and delete personal data; and

• how we check that the information we hold is accurate and up to date.

 

 

Complaints or queries

BHL seeks to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.

This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of BHL’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.

Also, if you want to make a complaint about the way we have processed your personal information, you can contact us:

River House (the site of the Old Mill),

Bexley High Street,

Kent, DA5 1JX

Tel: 020 8269 3444

 

Or by e-mail to  bhl@nhs.net orusing the web page at  http://bexleyhealthlimited.co.uk/contact

 

You have a right to complain to the Information Commissioners Office (ICO) if you are in any way dissatisfied with the way that BHL has handled your data. We are committed to cooperating with the ICO and respect the work that they do. They can be contacted by:

  • their online portal ,
  • their helpline on 0303 123 1113 ,
  • by mail: Information Commissioner's Office
    Wycliffe House
    Water Lane
    Wilmslow
    Cheshire
    SK9 5AF

 

 

 

Links to other websites

This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.

Changes to this privacy notice

We keep our privacy notice under regular review. This privacy notice was last updated in April 2019.

 

River House (the site of the Old Mill), Bexley High Street, Kent, DA5 1JX Tel: 020 8269 3444 Fax: 013 2231 5373