1. Introduction

We are Interact Medical Ltd (“we” or “us”), a company registered in England and Wales. Our company registration number is 03082906 and our registered office is at Metropolitan House, Building 900, 321 Avebury Boulevard, Milton Keynes, MK9 2GA.

We are committed to protecting your personal data. This privacy policy gives you detailed information on when and why we collect your personal data, how we use it and how we keep it secure. Please read this policy carefully alongside any applicable Terms & Conditions to understand our views and practices regarding your personal data and how we will treat it.

More information can be provided on request. Definitions, and words in bold type, are defined in the Appendix at the end of this privacy policy.

2. Legal bases for processing

As a recruitment business the Company collects and processes both personal data and sensitive personal data. It is required to do so to comply with other legislation. It is also required to keep this data for different periods depending on the nature of the data.

The Company will only process personal data where it has a legal basis for doing so (for more information please refer to the company data protection policy). Where the Company does not have a legal reason for processing personal data any processing will be a breach of the Data Protection Laws.

The Company will review the personal data it holds on a regular basis to ensure it is being lawfully processed and it is accurate, relevant and up to date.

Before transferring personal data to any third party (such as past, current or prospective employers, suppliers, customers and clients, intermediaries such as umbrella companies, persons making an enquiry or complaint and any other third party (such as software solutions providers and back office support)), the Company will establish that it has a legal reason for making the transfer.

3.  Our responsibilities

For the purpose of the applicable Data Protection Legislation, we are the data controller of any personal data we process. As a data controller, we are responsible for ensuring our systems, processes, suppliers and People comply with Data Protection Legislation in relation to the personal data we handle.

We require our employees to comply with this privacy policy and our data protection policy when dealing with personal data.

We take Personal Data Breaches very seriously and are required to notify the Information Commissioner’s Office in the event of such a breach as appropriate.

When using, collecting and disclosing personal data, we follow the key data protection principles required under the General Data Protection Regulations.

We have policies, procedures and records to demonstrate compliance with the principles, as further detailed in our Data Protection Policy.

4. How we collect, use and disclose your personal data

Generally, we collect your personal data when you interact with us (for example, when entering into a relationship with us as a Temporary Worker, Customer or Employee). However, from time to time we also need to collect personal data from other third parties in connection with our relationship with you. We also look at how our users access and use our Website, so we can offer the best possible experience. The following tables summarise how we collect, use and disclose your personal data:

Temporary Workers (including prospective Temporary Workers)

Types of personal dataCollectionPurposeDisclosureRetention Period
Information such as:
• your name, address,
contact details,
education and
employment history;
• identification
documentation;
• right to work status;
• information relating to
next of kin/
dependants;
• financial information
including bank details
and identifiers (e.g.
National Insurance
numbers);
• images/photographs of
you; and
• reviews/feedback
relating to your ability
as/to become a
Temporary Worker.
We may also process
sensitive personal data
such as health details,
medical details, your
gender and racial origin.
Your personal data will be
collected from various sources
including:
• your application form, CV and
various associated regulatory
& mandatory application
criteria and processes;
• when you contact us via email
or telephone
• providers of background
checks
• notes and records kept for
the duration of your
engagement with as a
Temporary Worker (including
details of any complaints,
breaches of the terms of your
contract with us and
meetings with us regarding
our relationship and your
engagement as a Temporary
Worker
• CCTV while on our premises;
• from our clients (including
reviews and feedback
• providers of Occupational
Health Services
• Professional Regulators
including the GMC, GDC,
NMC and HPC
Your personal data will be
used for the following
purposes:
• internal administration
and management
purposes;
• assessing
suitability/eligibility
and/or fitness as a
Temporary Worker;
• fulfilling our contractual
obligations to you;
• fulfilling our contractual
obligations to our Clients;
and
• fulfilling our legal
obligations.
Your personal data may be
transferred to:
• our third-party service
providers who support the
operation of our business;
• our Clients, for the purposes
of fulfilling our contractual
obligations;
• our Affiliate Employment
Agencies; and
• other third parties such as
our legal and other
professional advisers and
government departments.
We shall only transfer personal
data to third parties which is
limited to the relevant purpose
and is adequately protected.
Temporary Worker personal
data shall be kept for 10
years and we shall not keep
your personal data for longer
than is necessary.
We will ensure we keep all
personal data up to date and
shall immediately and
permanently delete any
personal data which is not
necessary for the purpose.

Clients (including prospective Clients)

Types of personal dataCollectionPurposeDisclosureRetention Period
Information such as your:
• Name and business
information;
• Identification
documentation;
• Payment details
Collection
• Your personal data will be
collected for relationship
management, booking
process and invoicing of
services.
• Further information may be
collected from third parties
which may include credit
reference checking services
and other publicly available
sources.
When you contact us via email or
telephone, we may collect any
personal data you provide to us.
All additional personal data is
collected when supplied to us or
created by us in connection with
a particular matter on which we
are engaged.
Your personal data will be
used for relationship
management and file opening.
Data will be used for providing
locum booking services,
administration, commercial
purposes (e.g.
creditworthiness) and as
required by law (e.g. anti-money laundering).
All other personal data will be
used for the purposes of
providing general recruitment
services and to comply with
our statutory and regulatory
obligations.
Your personal data may be
disclosed to:
• our third party service
providers who support the
operation of our business;
• Our Temporary Workers for
the purposes of fulfilling our
contractual obligations; and
• Other third parties as
required for us to comply
with our statutory and
regulatory obligations.
We shall only transfer personal
data to third parties which is
limited to the relevant purpose
and is adequately protected.
Client personal data shall be
kept for 10 years and we
shall not keep your personal
data for longer than is
necessary.
We will ensure we keep
personal data up to date and
shall immediately and
permanently delete and
personal data which is not
necessary for the purpose.

Subscribers to our promotional material

Types of personal dataCollectionPurposeDisclosureRetention Period
Information such as your:
• Name
• Email address
• Job title
• Grade
• Specialty
Additional information may
be processed where it is
provided by you, for
example in
correspondence, in
connection with any
Temporary Worker
placement or potential
placements or in letting us
know your interests and
how or when you wish to
be contacted by us.
Your personal data is collected
when you first register with us
and thereafter on an ongoing
basis as updated information is
provided from you as part of the
recruitment process.
By providing this personal data,
you agree to receive:
• information and updates
about our Temporary Worker
opportunities;
• details of events and courses
You can contact us at any time to
amend your preferences or opt
out of all or part of
communications from us.
You will also be sent the option to
opt out of future communications
in every communication you
receive from us (any statutory
and regulatory obligations are
exempt from this option).
Where you have engaged us in
a clear and unambiguous
manner for the purposes of
sourcing Temporary Worker
services on your behalf, your
personal data will be used to:
• contact you about and
provide you with, the
communications we think
are relevant to your
interests, needs and
preferences; and
• understand our
subscribers’ preferences
and interests so we may
improve our services,
communications and
marketing material.
Your personal data may be
transferred to our third party
service providers who support
the operation of our business.
This may include the transfer of
your personal data outside of
the European Economic Area
(EEA). Where personal data is
transferred outside of the EEA,
it will be done so in a secure
and proper manner and in
accordance with best practice
data protection guidelines.
We shall only transfer personal
data to third parties which is
limited to the relevant purpose
and is adequately protected.
Your personal data shall
be kept for 10 years and
we shall not keep your
personal data for longer
than is necessary.
We will ensure we keep
personal data up to date
and shall immediately
and permanently delete
any personal data which
is not necessary for the
purpose.

Users of our Website

Types of personal dataCollectionPurposeDisclosureRetention Period
Information such as:
• technical information, including
the Internet Protocol (IP) address
used to connect your computer to
the Internet, your login
information, browser type and
version, time zone setting, browser
plug-in types and versions,
operating system and platform,
type of device used to access our
Website and the location of where
you access our Website via a
mobile device;
• information about your visit,
including the full Uniform
Resource Locators (URL)
clickstream to, through and from
our Website (including data and
time), pages you viewed or
searched for, page response times,
download errors, length of visits to
certain pages, page interaction
information (such as scrolling,
clicks and mouse-overs), and
methods used to browse away
from the page and any phone
number used to call us.
• Your name and email address,
other contact/application details.
Your personal
data is collected
when you:
• use our
Website (e.g.
browsing.
Searching);
• Provide us
with personal
information to
enable us to
contact you
and let us
know of your
marketing
preferences
and
• Contact us via
email
Your personal information is
used to:
• tailor and enhance your
user experience;
• Improve the
functionality of our
Website;
• ensure our Website
caters to our users’
preferences;
• contact you about and
provide you with the
communications we
think are relevant to
your interests and
requirements and;
• contact you and
provide you with
information about our
services.
Your personal data may be
transferred to our third
party providers who support
the operation of our
business.
This may include the
transfer of your personal
data outside of the
European Economic Area
(EEA). Where personal data
is transferred outside of the
EEA, it will be done so in a
secure and proper manner
and in accordance with best
practice data protection
guidelines.
We shall only transfer
personal data to third
parties which is limited to
the relevant purpose and is
adequately protected.
Our Website users’ personal
data shall be kept for 10
years and we shall not keep
your personal data for
longer than is necessary.
We will ensure we keep
personal data up to date
and shall immediately and
permanently delete any
personal data which is not
necessary for the purpose.

Our Employees

Types of personal dataCollectionPurposeDisclosureRetention Period
Personal data such as:
• your name, address,
contact derails,
education history;
• background checks
(reference and criminal);
• identification
documentation;
• right to work status;
• information relating to
next of kin and/or
dependants and
• financial information
including bank details
and identifiers (e.g.
National Insurance
numbers).
We may process sensitive
personal data such as health
details, racial origin,
religious beliefs and
information about offences
or alleged offences.
Your personal data will be
collected from various
places including:
• your application form
and CV;
• providers of background
checks;
• notes and records kept
for the duration of your
employment (including
absences, appraisals,
disciplinary action);
• providers of
Occupational Health
services; and
• CCTV and security
access devices
Your personal data will be
used for the following
purposes:
• human resources
administration;
• assessing
suitability/eligibility
and/or fitness to work;
• security; and
• training
Photographs and images of
you, your name and
information about your
education and employment
may be used in our
marketing and promotional
material including our
Website and pitches to
Clients.
Your personal data may be
transferred to:
• our third party service
providers who support
the operation of our
business;
• our Clients for the
purposes of fulfilling
our contractual
obligations.
We shall only transfer
personal data to third
parties which has been
limited to the relevant
purpose.
Our employees’ personal
data shall be kept for the
duration of employment
and for 10 years thereafter.
We shall not keep your
personal data for longer
than is necessary.
We will ensure we keep all
personal data up to date
and shall immediately and
permanently delete any
personal data which is not
necessary for the purpose.

 4. Transfer of Data between Jurisdictions

Personal data may be transferred to one of our affiliate companies for the purposes of fulfilling our obligations to our Clients. We also use a number of suppliers in connection with the operation of our business and they may have access to the personal data we process. For example, an IT supplier may see our personal data when providing software support, or a company which we use for a marketing campaign may process contacts’ personal data for us. When contracting with suppliers and/or transferring personal data to a different jurisdiction, we take appropriate steps to ensure that there is adequate protection in place and that the principles are adhered to.

5. Your rights

Personal data must be processed in line with an individual’s rights, including the right to:

  • request a copy of their personal data;
  • request that their inaccurate personal data is corrected;
  • request that their personal data is deleted and destroyed when causing damage or distress; and
  • opt out of receiving electronic communications from us.

Should you wish to make a request in line with your rights as an individual, please forward it to us using the contact details provided at the end of this privacy policy.

Our Employees must notify or inform Richard Moses immediately if they receive a request in relation to personal data which the company processes.

The Data Protection Legislation gives you the right to access information held about you. Your right of access can be exercised in accordance with the Data Protection Legislation (as applicable).

6. Security

Information security is a key element of data protection. We take appropriate measures to secure personal data and protect it from loss or unauthorised disclosure or damage. Our policy and approach to information security is contained within our Data Protection Policy.

7. Cookies

Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website.

8. Changes to our privacy policy

Any changes we may make to this privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

9. Contacts and complaints

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to us by writing to us at info@interactmedical.co.uk.

You should direct all complaints relating to how the company has processed your personal data to Richard Moses.

Alternatively, you can contact the ICO directly on 0303 123 1113 or at https://ico.org.uk/global/contact-us/email/