Privacy Notice for Self-Employed Personnel

Newson Health Limited

Privacy Notice for Self-Employed Doctors, Healthcare Professionals and other Service Providers

 

The following information forms part of our Privacy Notice for doctors and health care professionals who are self-employed, together with employees of service providers.  It sets out further important information about the personal data that Newson Health Limited , hold about you and  how that information may be used.

Links to other Websites

Our websites may contain 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 recommend that you read the Privacy Notice of any website you visit.

The Personal Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). The extent of the information we collect, and use will depend on what information you choose to provide to us or what information is provided to us on your behalf.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data: includes your name, marital status, title, date of birth and gender, name of next of kin;
  • Contact Data: includes billing address, delivery address, email address and telephone numbers, next of kin contact details;
  • Work background data: includes right to work permit details (if relevant), professional qualifications, work history and experience, a copy of your Curriculum Vitae, professional registrations and a copy of confirmation of qualifications;
  • Worker Records: includes interview records, references we have received about you and references we have written on your behalf, appraisal and training records, records of any grievance or disciplinary process that you have been involved in, holiday records, remuneration and benefits records;
  • Financial Data: includes bank account and payment card details, pension records, private medical insurance records, life assurance records;
  • Other Data: Car registration mark, CCTV images

Special Categories of Personal Data

Special Category Personal Data specifically means personal data relating your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data.

We may collect and hold the following special categories of information about you: Information about your health such as details of medical conditions, sickness records, blood test results, Occupational Health records; race; ethnicity; sex life or sexual orientation; religious or philosophical beliefs and details of trade union membership.

We require those applying to practice with us to provide details of hepatitis B vaccination and evidence of hepatitis B status and, where a practitioner is carrying out exposure prone procedures, also evidence of hepatitis C and HIV status. This information can be sent direct to our Occupation Health Service under separate cover.

We may also request and hold records relating to any criminal convictions (including offences and alleged offences and any court proceedings or sentence) if you have given this information to us or we have obtained it from a third party such as the Disclosure and Barring Service.

For employees of our service providers, we do not routinely collect special categories of personal data although we may process this if you choose to give it to us.

 

Where Do We Obtain Your Personal Data From?

  • Direct interactions. We will collect your personal information from you when you apply to practice with us or are employed by one of our service providers. Information may be collected from correspondence such as letters, telephone calls or email;
  • Third parties and publicly available sources. In most cases, the personal data we collect will come directly from you. However, we may receive information about you provided by a third party such as:
    • The Disclosure and Barring Service (for England and Wales and Northern Ireland) or Disclosure Scotland (which covers Scotland)  and overseas Police agencies (in the context of an application to practice with us);
    • Previous or current employers;
    • Referees that have sent us a reference about you;
    • Professional and educational bodies such as the General medical Council (GMC), Nursing and Midwifery Council (NMC), Health and Care Professions Council (HCPC) in the context of confirmation of qualifications or professional regulatory matters;
    • A family member or other person communicating with us on your behalf;
    • Occasionally, government agencies such as HMRC or the Home Office.

 

If You Provide Us with Personal Information About Others

If you provide personal information to us about other you should inform the individual about the contents of this Privacy Notice. We will process such information in accordance with this Privacy Notice.

 

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 when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services or to purchase your goods or services). In this case, we may have to cancel or not proceed with a contract, but we will notify you if this is the case at the time.

If you are applying to practice with us, we encourage you to disclose all the information that is relevant to your application. This forms an important part of our “Safer Recruitment” obligations. Although you do not have to share personal information with us which you feel uncomfortable about sharing, please be aware that if you choose to withhold relevant personal information from us during the application process we may be unable to progress your application. If you choose to withhold relevant information from us whilst you are practising with us, this may result in some or all of your practising privileges being suspended or withdrawn.

How we use your personal data

We will process your personal information in accordance with this Privacy Notice and only where we are legally permitted to do so. The main purposes for collecting and using your personal data are to facilitate your contract to practice with us or a contract for the supply of your goods and services and so that we can comply with our legal and regulatory requirements. More information about how we use your personal data is set out below.

Data protection law requires us to have a legal basis to justify using your personal data. The legal basis used will vary, depending on why we are using your personal data. If we process  "special categories of personal information", we must have an additional legal basis to justify using it.

You will find details of the "legal bases" we rely upon for each of our processing purposes set out below.

Purpose: When you practice with us or apply to practice with us

Newson Health will use your personal data to assess your suitability for practising with us and for maintaining that relationship, including your qualifications, skills and experience. We may carry out background checks, take up references, confirm your qualifications and, where relevant confirm that you have the right to work in the UK. We will use your name and contact details to correspond with you about your application, for monitoring outcomes generally and your services. Your information may be used to comply with our equal opportunity monitoring and reporting obligations are met. We will retain some of the recruitment records for a certain period of time in accordance with our Data Retention Policy.

Legal Bases:

  • Where the use is necessary in connection with a contract for services that you may have with us.
  • Where the use is necessary in order for us to comply with our legal obligations. For example, we may have a legal duty to carry out background checks before you can practice with us.
  • Where the use is necessary for our legitimate interests including carrying out our assessment to see if you are suitable for the practicing role you have applied for and for complying with our legal obligations,  providing these interests are not overridden by your privacy rights and freedoms.
  • On occasion, where you have consented to providing us with your personal data.

Additional legal bases for special categories of personal data:

  • Where the use is necessary for reasons of substantial public interest based upon law. For example, where we are required us to carry out criminal records checks or assess your fitness to carry out the relevant tasks, to deal with insurance-related matters or fraud prevention and detection.
  • Occasionally, where the use is necessary to establish, exercise or defend our legal rights.
  • For the provision of healthcare and the overall management of  our healthcare systems.
  • Where you have provided your explicit consent.

Purpose: To Administer the Practising Arrangements Between you and Newson Health

Where you are delivering healthcare services to our patients, Newson Health will collect and use your personal data in order to administer and manage our relationship, fulfil any contractual obligations we owe you,  and to comply with our legal and regulatory obligations. Your personal data may be used in the context of running our business and sites generally including CCTV footage and IT records. We will also use your information to maintain records relating to those that work for us and to investigate issues raised with us regarding your work or role.

Legal Bases:

  • Where the use is necessary in connection with our contractual arrangements. For example, ensuring you are remunerated.
  • Where the use is necessary in order for us to comply with our legal obligations. For example, we may have a legal duty to carry out background checks or report certain concerns that are raised with us about you,  to a regulatory body.
  • Where the use is necessary for our legitimate interests including administering your practicing arrangements and any contract between us, and investigating, and where appropriate, sharing, concerns or complaints regarding you or your work,  assist with the GMC revalidation process, providing these interests are not overridden by your privacy rights and freedoms.
  • On occasion, where you have consented to providing us with your personal data.

Additional legal grounds for special categories of personal data:

  • Where the use is necessary for reasons of substantial public interest based upon law. For example, where the law requires us to require you to produce medical evidence such as blood tests or report concerns relating to you to a third party body.
  • Occasionally, where the use is necessary to establish, exercise or defend our legal rights. For example, in connection with legal proceedings.
  • For the provision of healthcare and the overall management of  our healthcare systems.
  • Where you have provided your explicit consent.

Purpose: Complying with our legal obligations and regulatory requirements

Legal Basis:

  • Where the use is necessary for us to comply with a legal obligation. For example, we may have a legal duty to retain records relating to you in order to comply with legal or accounting obligations.
  • Where the use is necessary for fulfilling our legitimate interests including running our business generally and in order to comply with relevant statutory, regulatory or legal requirements, providing those interests are not overridden by your privacy rights and freedoms.

Additional legal bases for special categories of personal data:

  • Where the use is necessary in order for us to establish, exercise or defend our legal rights.
  • Where the use is necessary for reasons of substantial public interest on the basis of law. For example, where it is necessary to process your personal information for the purposes of crime prevention or safeguarding purposes or to protect any individual from neglect or harm.
  • For the provision of healthcare and the overall management of  our healthcare systems.

 

Who Do We Share Your Personal Data With?

We may share your personal data with third parties listed below for the purposes set out above. Where your personal data is shared, we only share the minimum amount of relevant information required to fulfil the purpose of sharing. It is shared securely and strictly in accordance with the law.

  • Other internal staff that are involved in the recruitment process, management of staff including self-employed doctors and health care professionals and record keeping;
  • Occupational Health staff  (who may not be directly employed by Newson Health);
  • Your previous employers, referees, other current or previous employers, staffing agencies, educational establishments and professional bodies such as NMC and HCPC;
  • Disclosure and Barring Service or Disclosure Scotland;
  • Patients, visitors, doctors, nurses, other staff and our advisors in order to deal with questions, complaints or claims, including those made by yourself;
  • HM Revenue and Customs, our regulators such as the Care Quality Commission and the Information Commissioner’s Office (ICO) and other authorities based in the UK and other relevant jurisdictions who require us to report processing activities in certain circumstances.
  • The police and other regulatory third parties in connection with the prevention and detection of crime or for safeguarding purposes;
  • Our third party service providers such as our IT services provider, document storage providers, digital dictation service, website hoster, marketing and email providers (Mailchimp and Microsoft). These third party service providers are required to process your personal data only on our instructions, securely and in accordance with relevant EU or UK data protection laws;
  • Third party professional advisors including lawyers, accountants, auditors and  insurers;
  • Anyone that has been appointed or you have asked to communicate with us on your behalf such as your insurer,  individuals you have named as an emergency contact, such as your next of kin;
  • Third parties to whom we may sell, transfer or merge parts of our business or assets.

 

Other General Information About How We Process Your Personal Data

For general information about we collect and process your personal data including for example, how we keep it secure,  how long it is retained, your legal rights and who to contact if you have any questions about this Privacy Notice or your personal data . Please click here.