Candidate Privacy Notice

What is the purpose of this notice?
Data protection principles
Who your personal information is collected from
The kind of information we hold about you
How we will use information about you
Candidates for a position as an employee at HBSUK
Candidates for a position in our Clinicians’ Network for Virtual Lucy or Insourcing
If you fail to provide personal information
How we use particularly sensitive personal information
Information about criminal convictions
Automated decision–making
Why we may share your personal information with third parties
Data Security
How long we retain your information
Your rights in connection with personal information
Questions or Complaints
Changes to the candidate notice and your duty to inform us of any changes

1. What is the purpose of this notice?

Healthcare Business Solutions (UK) Limited (HBSUK) is a “controller” in relation to personal data. This means that we are responsible for deciding how we hold and use personal information about you when you are applying for work with us whether as an HBSUK employee, contractor, or part of the clinicians’ network. It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the UK General Data Protection Regulation (UK GDPR).

2. Data Protection Principles

We will comply with data protection law and principles, which means that your data will be:

Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told you about.
Kept securely.

3. Who your personal information is collected from

We collect personal information about candidates from the following sources depending on the position you are applying for:

You, the candidate.
Our recruitment agencies, from which we collect the following categories of data: name, contact details, your CV and any other information relevant to your application for the role.
UCheck background check provider, from which we collect the following categories of data: a candidate’s criminal convictions history including any spent and unspent convictions, cautions, reprimands, or warnings.
Healthier Business UK Limited who provides Fit to Work Certificates (when required by certain NHS trusts). Where necessary we will obtain a health questionnaire and occupational health records from you to send to Healthier Business UK Limited who will have a clinician review the information and provide HBSUK with a Fit to Work Certificate.
Disclosure and Barring Service in respect of criminal convictions.
UK Home Office in respect of right to work status.
Your named referees, from whom we collect a reference.
Data about your professional qualifications from third parties from the following publicly accessible sources, the General Medical Council (GMC) medical register, the Nursing & Midwifery Council (NMC) register and the health & care professions council (HCPC) register.

4. The kind of information we hold about you

In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:

The information you have provided to us in your CV and covering letter.
The information you have provided on our website Onboarding Expression of Interest Form, including name, address, telephone number, personal email address, employment history.
Any information you provide to us during the interview process or the clinicians’ CV review process.
Information obtained from sources other than yourself previously referred to in this notice.

This may involve us collecting, storing and using the following types of more sensitive personal information:

Information about your race or ethnicity, religious or philosophical beliefs, trade union membership, sexual orientation and political opinions.
Information about your health, including any medical condition, health and sickness records.
Information about criminal convictions and offences.

5. How we will use information about you

We will use the personal information we collect about you to:

Assess your skills, qualifications, and suitability for the role.
Carry out background and reference checks, where applicable.
Communicate with you about the recruitment process.
Keep records related to our hiring processes.
Comply with legal or regulatory requirements.

It is in our legitimate interests to decide whether to appoint you to the role since it would be beneficial to our business to appoint someone to that role.

We also need to process your personal information to decide whether to enter a contract of employment, an Engagement Letter or a Practicing Privileges Letter with you. This will differ depending on the position you are applying for as follows:

6. Candidates for a position as an employee at HBSUK

Having received your CV and covering letter or your application form, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role, we will then take up references, carry out any necessary background checks including criminal record checks, right to work status, and any necessary GMC, NMC and HCPC checks before confirming your appointment.

7. Candidates for a position in our Clinicians’ Network for Virtual Lucy or Insourcing

Once we have reviewed your expression of interest whether received by our Expression of Interest Form, via email or recommendation, if we decide to offer you the role, you will then be sent an onboarding registration form whereby you will be asked to enter your personal details, professional registration details (if applicable) and upload your compliance documents.

Once the onboarding team have received your completed form, we will validate the information provided with the GNC, NMC, HCPC or the DBS. If necessary, we will also obtain a Fit to Work Certificate. We will contact you if any further information is required.

8. If you fail to provide personal information

If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

9. How we use particularly sensitive personal information

Where appropriate we will use your particularly sensitive personal information in the following ways:

We use information about disability to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during the interview process.
We use information about racial or ethnic origin, religious or philosophical beliefs, disability or sexual orientation to ensure meaningful equal opportunity monitoring and reporting.
Where required by an NHS Trust we will use health data contained in a Fit to Work Certificate to decide if you meet the requirements for the particular role.

10. Information about criminal convictions

We envisage that we will process information about criminal convictions.

We will collect information about your criminal convictions history if we would like to offer you the role (conditional on checks and any other conditions, such as references, being satisfactory). We are required to carry out criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. In particular:

We are legally required by a regulator (for example the Care Quality Commission), to carry out criminal record checks for clinicians working on the Virtual Lucy Platform.
We are contractually required by the frameworks we work within to meet a certain level of compliance.
As a healthcare provider all roles at HBS UK require a high degree of trust and integrity and so we require a disclosure of your criminal records history.
We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.

11. Automated decision–making

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

12. Why we may share your information with third parties

We will only share your personal information with the following third parties for the purposes of processing your application: your named referee, our recruitment agents, the GMC, NMC and HCPC, UCheck, DBS, the UK Home Office, Healthier Business UK Limited and in some circumstances the relevant NHS Trust.

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

13. Data Security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. Details of these measures may be obtained from our data protection officer (DPO).

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

14. How long we retain your information

Generally, we will retain your personal information, including your CV, for a period of 6 months after we have communicated to you our decision about whether to appoint you to the role. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations.

If we would like to retain your personal information on file, on the basis that we might be able to consider you for an opportunity that may arise in future, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period for that purpose.

In relation to clinicians applying via our clinician’s network, where you are not approved for a specific NHS Trust site or Virtual Lucy, we will hold your CV on file as there may be other future opportunities that you can be considered for. If you do not want us to continue to hold your CV, please contact us.

15. Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

Request access to your personal information (commonly known as making a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request rectification of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our data protection officer (DPO).

16. Questions or Complaints

If you have any questions or concerns about this privacy notice or how we handle your personal information, please contact our data protection officer (DPO) who has been appointed to oversee compliance with this privacy notice and whose contact details are compliance@hbsuk.co.uk

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) who is responsible for data protection issues in the UK and whose contact details are available here.

17. Changes to the candidate notice and your duty to inform us of any changes

We keep our privacy notice under regular review. This version was last updated on 25.02.2025. 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, for example a new address or email address.