The “Westgate Practice”, “we”, “us”, “our”, “practice” for the purposes of this notice means The Westgate Practice, which is a data controller in its own right for the purposes of data protection law.

As part of our candidate application and recruitment activities we collect, process and store personal and special categories of data which may directly or indirectly identify you (together “personal information”). We process personal information for a range of purposes relating to general recruitment activities as well as the recruitment process and this may include your application, assessment, pre-employment screening, and your worker permissions. This Candidate Privacy Notice (“Privacy Notice”) sets out:

• why we collect your personal information;
• what information is collected and;
• how it is processed within the recruitment process.

Throughout this Privacy Notice we use the term “processing” to cover all activities involving your personal information, including collecting, handling, storing, sharing, accessing, using, transferring and disposing of the information.

Why do we collect your personal information?

We only process your personal information where we are lawfully permitted for one or more of the purposes set out below. Not all of the purposes set out below will apply to you all of the time.

a) Application: activities carried out in the course of receiving and assessing candidate applications, including reviewing general applications or applications for specific jobs. This may involve the processing of your CV, application, name, address, employment history, academic and professional
qualifications, age, diversity data including gender, ethnicity, disability, sexual orientation, nationality and previous disciplinary matters;

b) Assessment: activities carried out in the course of assessing candidate suitability for roles at the practice, which may involve the processing of your CV, psychometric tests (such as a situational judgement test, ability or personality test), interview (face to face or telephone ), behavioural assessments (such as a role play, group exercise or presentation), technical assessments;

c) Pre-employment screening (PES): 2 a pre-employment screening activities carried out for the purposes of DBS checks;

d) Candidate searches: In the course of our search activities, we use personal information that we have collected concerning candidates to identify professional opportunities that we think may be of interest. We may contact potential candidates from time to time regarding such opportunities.

e) General recruitment activities: specific or speculative recruitment-related activities.

What personal information might we process and how we collect it?

Generally, we collect personal information directly from you in circumstances where you provide personal information to us by applying directly for a role at the practice, or information that we learn about you through your interactions with us, or with third parties (e.g. recruitment agencies).

We may also collect personal information about you from third parties, including, for example, when a referee provides information about you, when a colleague recommends that we consider you for a position or from other sources where you have made your personal information publically available for the purposes of recruitment on jobs boards, LinkedIn (or other publically available social media
networks and databases). Here are some examples of the type of information we may process about you. There’s a full list in the schedule at the end of this notice.

a) Your Personal Information

• Personal details such as name, address, email address and date and place of birth;
• Work history/job data; previous employers, positions, dates, etc.;
• Basic salary, benefits, pension, etc.;
• Education and work history including professional qualifications and skills;
• Employer feedback / references, to include regulated references where necessary;
• Nationality / visa / right to work permit information; (e.g. passport, driving licence, National Insurance numbers);
• Identity Photographs;
• Results of pre-employment screening checks (e.g. DBS checks)
• Assessment results e.g. psychometric assessment results, presentation results, interview score sheets.
• Professional Registration status

b) Your Special Categories of Information

During the process we may also inadvertently capture some special categories of personal information about you (e.g. information relating to your racial or ethnic origin, religious of philosophical beliefs, physical or mental health or condition, sexual orientation), where this has been provided or made publically available by you or can be inferred from your CV. We may also process certain special categories of information about you (e.g. information about a physical or mental
health or condition) in order to make reasonable adjustments to enable our candidates to apply for jobs with us, to attend interviews/assessment centres, to prepare for starting at the practice (if successful) and to ensure that we comply with regulatory obligations placed on us with regard to our hiring. We may also process information relating to criminal convictions and offences (e.g. as part of
pre-employment screening checks). We will only process special categories of information or information about criminal convictions and offences where we have obtained your explicit consent or where permitted by applicable laws (and then only when necessary for the purposes mentioned above). Where we are processing personal information based on your consent, you have the right to
withdraw that consent at any time where there is no other legal basis for the processing.

Legal basis for the processing

The Westgate Practice’s entitlement to process your personal information is governed by a number of processing conditions. This means that we may rely on more than one of these conditions in order to process elements of your personal information throughout the recruitment process.

• It is in the legitimate interests of the practice to process your personal information in the administration of your application and for general recruitment purposes;
• We will also process your personal information where it is required by law or regulation. This processing will always be fair and lawful and will at all times comply with the principles of applicable privacy laws in the country where you have applied to be employed;
• During the course of your application it may also be necessary for us or suppliers to process special categories of information about you (as per the detail in section 2(b) and Schedule 1 of this notice) where we have obtained your explicit consent or where permitted by applicable laws.
• Who do we share your personal information with?

The practice will need to share your personal information internally and may be required to share it with some external parties, such as Inland Revenue. In all cases, however, we will ensure that any transfer of your personal information is compliant with applicable data protection law. Your information will only be shared if it is necessary or required (for example in order to carry out preemployment screening).

The recruitment process will involve:

• Assessing and progressing your application;
• Assessing your suitability (skills, strengths, behaviours for the role);
• Activities needed to complete the screening process should your application be successful.

To enable these processes your personal information may be shared internally, but the information shared is limited to what is required by each individual to perform their role in the recruitment process.

Your personal information may be shared internally within the practice with the following people:

• Those employees who would have managerial responsibility for you or are acting on their
  behalf;
• HR Officer who have responsibility for certain HR processes (for example, recruitment, assessment, pre-employment screening);
• Employees with responsibility for investigating issues of policies and contractual requirements;
• IT Officer and system owners who manage user access;

The practice may also need to share your information with certain external third parties including:

• Suppliers who undertake background screening on behalf of the practice (criminal checking
  bureaus, etc.);
• Academic institutions (Universities, colleges, etc.) in validating information you’ve provided;
• Individuals and companies that you have previously worked for who may provide references/recommendations to the practice;
• Other third-party suppliers (or potential suppliers), who provide services on our behalf.

How do we protect your information?

Our HR/payroll systems are protected to ensure that unauthorised or unlawful processing of personal information, accidental loss or destruction of, or damage to, personal information does not occur. This is done in accordance with our Security Policy.

The practice also requires its third party suppliers or recipients of personal information to guarantee the same level of protection as provided by the practice. In addition to using your personal information for the position for which you have applied, we may retain and use your personal information to consider you for other positions. If you do not want to be considered for other positions or would like to have your personal data removed, you may contact us as specified under
Inquiries, Complaints and Objections below. Unless required for tax or other legal purposes or in connection with employment as specified above, your personal information will be retained in accordance with our with our Recruitment Policy (which means that we may hold some information after your application to the practice is complete).

Your Rights

a) Access, correction and deletion

You are entitled to see the personal information the practice holds about you. You can also request changes to be made to incorrect personal information and can ask for your personal information to be deleted or blocked if you legitimately think that we shouldn’t be processing that information or we have processed incorrectly, except where retention of that personal information is required in the context of a legal dispute, or as otherwise required by law. If access, correction or deletion is
denied, the reason for doing so will be communicated to you.

b) Inquiries, objections and complaints

If you have any queries about this notice or your personal information generally, including questions about accessing your personal information or correcting it, you should contact the Business Manager in the first instance. You may also withdraw consent to the processing of your personal information or submit complaints and/or objections to the processing of your personal information by sending a
request in writing to: Elizabeth Kilgallon. Alternatively, there is information available on our internet about accessing your personal information, please search for “subject access requests”.

It is your responsibility to keep your personal information up to date so that accurate application records can be maintained. You should contact Elizabeth Kilgallon, HR Officer if you notice information held is inaccurate.

When asked to remove a record from our files, the practice will retain minimal personal information in order to prevent future contact and where required in accordance with legal / regulatory requirements.

c) Automated processing

We do not make recruiting or hiring decisions based on automated decision-making. In the event that the practice relies solely on automated decision-making that could have a significant impact on you (e.g. automated psychometric and behavioural testing), we will provide you an opportunity to express your views and will provide any other safeguards required by law.

e) Changes to this Privacy Notice

As this Privacy Notice is updated, the current version will be posted on the intranet.

Screening checks

As part of the Selection process, the practice performs a number of screening checks, where permitted by local law. These checks are only performed on candidates who have been selected for a role. Your consent will be requested before screening checks are performed.

Criminal records checks

Given the nature of our business, we have legal and regulatory obligations to ensure that the people we employ can be relied upon to deal with confidential health care data and information responsibly. We therefore ask questions about any prior civil or criminal proceedings you may have been subject to and may also conduct criminal record checks.

Schedule 1: Full list of information we may process

• Name, work and home contact details
• Date and place of birth
• Education and work history
• *Individual demographic information in compliance with legal requirements (such as marital status, national identifier, passport/visa information, nationality, citizenship, military service, disability, work permit, date and place of birth or gender)
• *Health issues requiring adaptations to working environment
• Job title, grade and job history
• Employment contract related information (including compensation, location, hours of work and so on)
• Reporting and managerial relationships
• *Leaves of absence (such as maternity leave, sickness absence)
• Photograph(s)
• Disciplinary / grievance records
• Time and attendance details
• *Bank account details for salary payment purposes
• 7* Expenses such as travel and expenses claimed from the practice
• Personal information contained in CVs (e.g. name, address, telephone number, e-mail address, employment history, degree(s) and other qualifications, languages and other skills). These may also include, without limitation: age, nationality and race (only to the extent allowed by law), compensation details, a record of our contact history with you and comments from third parties
• Skills and qualifications
• Personal information which you have made available for the purposes of recruitment on jobs boards, LinkedIn (or other publically available social media networks) and to third parties such as recruitment agencies that we work closely with
• Training history and plans
• Results of original and ongoing employee screening, where relevant (see section 7)
• Details provided in relation to Conduct policies (such as conflicts of interest, personal account dealing, indemnity membership and so on)
• 8* Health & safety incidents, accidents at work and associated records
• Building CCTV images
• Audio recordings of telephone conversations
• Notes from face to face interviews
• Psychometric test results and associated reports (where used)
• Results from behavioural assessments (e.g. Assessment Centre exercises) (where used)
• Results from technical assessments (where used)
• References and recommendations

*These categories of information might potentially include some special categories of information.

Special categories of information are not routinely collected about all applicants, but may be collected where the practice has a legal obligation to do so, or if you choose to disclose it to us during the course of your relationship with the practice.