Privacy Policy

We are dedicated to keeping the personal information of visitors to the website private. We will not use any information for any use beyond what is stated or the consent you give us.

Introduction

This privacy notice provides you with details of how we collect and process your personal data. Foxwell Associates Limited is the data controller (sometimes jointly with others) and we are responsible for your personal data.

Our contact details for data protection purposes are:

  • email address: hello@foxwellassociates.co.uk
  • post: Data Protection Administrator, Foxwell Associates Ltd
    Leigh Court Business Centre, Pill Road, Abbots Leigh. Bristol BS8 3RA

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). However, we would appreciate you contacting us first if you do have a complaint so that we can try to resolve it for you.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing hello@foxwellassociates.co.uk

Data Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place physical, electronic and managerial procedures to safeguard and secure the information we collect. In addition, we limit access to your personal data to those employees, contractors and other third parties who have a business need to know such data. 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.

How we use your personal data

We will only use your personal data when legally permitted. The legal reasons that we rely on are that:

  • We need to perform the contract between us, or
  • It is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, or
  • We need to comply with a legal or regulatory obligation, or
  • We have sought your explicit consent

Purposes for processing your personal data

The table below describes the ways we intend to use your personal data and the legal grounds on which we will process such data.

Purpose / Activity Type of data Lawful basis for processing
Gathering and presenting candidates to our clients
  • Client business contact details
Performance of contract
  • Candidate
    • Contact details
    • CV
    • Qualifications
Performance of contract where the candidate applies to an advert

Legitimate business interest where seeking new candidates and information is publicly available (e.g. Linked in)

  • Referees contact details
Legitimate business interest (we need these to obtain references)
Verifying that selected candidates meet the engagement requirements.

May include any or all of the data shown depending upon the nature of the role and whether the work falls within the non-medical non-clinical NHS framework

  • Candidate
    • Right to work documents (including passport and proof of residence)
    • Reference form documents
    • Occupational Health questionnaire
    • Qualifications
    • Criminal record declaration
Legal requirement (for right to work) and performance of contract
Remunerating assigned candidates

May include some or all of the following depending upon the organisation through which the candidate is employed

  • Candidate
    • National Insurance Number
    • Bank account details
Performance of contract
To enable us to work with business partners
  • Business contact details
Legitimate business interest (for the efficient running of the organisation)

Data privacy associated with staff data will be shared with those affected.

Sensitive Data

Sensitive data refers to data that includes details about 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. It also includes information about criminal convictions and offences. We only collect health and criminal information where we are obliged to do so by our clients. For example, we are required to collect this information for candidates being engaged under the NHS non-medical non-clinical framework.

Disclosures of your personal data

We may have to share your personal data with third parties:

  • Our clients
  • Service providers who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.

We will supply the minimum amount of data needed by the party. We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

Transfers outside of the EEA

No data is transferred outside of the EEA.

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see below for further information.

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.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulationgdpr/individual-rights/.  If you wish to exercise any of the rights set out above, please email hello@foxwellassociates.co.uk.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

How we use cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. The file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to member needs. We only use this information for statistical analysis purposes.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Links to other sites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Changes to your privacy policy

Any changes to our privacy policy will be posted on this page. Please check back frequently to see if there have been any updates or changes. Any substantial changes may be promoted on the website or through email notification.

Foxwell Associates Limited

Registered number: 7038726

Registered office: Leigh Court Business Centre, Pill Road, Abbots Leigh, Bristol BS8 3RA

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