Clinical Partners UK GDPR Privacy Notices
For job applicants to employed roles
Table of Contents
12. Who We Share Your Data With..................................................................... 6
1. Introduction
1.1. The Clinical Partners Group encourages a working environment where everyone can contribute as fully as possible. Our purpose is to improve the lives of our patients, their families and those who care about them, and to be a trusted provider of mental health and medical services. We therefore apply the same values and standards to our employees and are positive, compassionate and ambitious in our approach to all things.
1.2. In accordance with the UK implementation of the General Data Protection Regulation (UK GDPR), this policy informs you, as prospective employees, of the types of data that we process about you and the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.
2. Purpose
2.1. This policy explains how we handle your personal data during the recruitment process in line with UK GDPR requirements. It outlines what information we collect, why we collect it, the legal basis for processing, how long we retain your data, and the rights you have regarding its use. Our aim is to ensure transparency and protect your privacy throughout your engagement with us as a prospective employee.
3. Scope
3.1. This notice applies to job applicants applying and being considered for vacancies within the Clinical Partners Group, including Oxford ADHD and Autism Centre, in an employed capacity.
3.2. Data controller details.
3.3. For the purposes of this privacy notice, the Company is the data controller and is registered with the Information Commissioner’s Office (ICO) under registration number Z2868470. This means that we determine the purposes and processes to be used when collecting and processing your personal data. Our contact details are as follows: Governance@clinical-partners.co.uk or Clinical Partners Ltd, Unit 6 Chaldicott Barns, Tokes Lane, Semley, Wiltshire, SP7 9AW.
3.4. We have appointed a Data Protection Officer (DPO), who can also be contacted using these details. If you would like to contact the DPO, please add FAO: the Clinical Partners DPO in the subject header of your correspondence.
4. Data Protection Principles
4.1. Under UK GDPR, all personal data obtained and held by us must be processed according to a set of core principles. We will ensure that:
a. processing is fair, lawful and transparent;
b. data is collected for specific, explicit, and legitimate purposes;
c. data collected is adequate, relevant and limited to what is necessary for the purposes of processing;
d. data is kept accurate and up to date and if found to be inaccurate, will be rectified or erased without delay;
e. data is not kept for longer than is necessary for its given purpose;
f. data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures;
g. we comply with the relevant UK GDPR procedures for international transferring of personal data.
5. Types of Data Held
5.1. We keep several categories of personal data on our job applicants and prospective employees to carry out effective and efficient processes. This data is stored in recruitment files relating to each vacancy and we also hold the data within our computer systems, for example, our applicant tracking system.
5.2. Specifically, we hold the following types of data, as appropriate to your status:
a. personal details such as name, address, phone number(s), email address;
b. your photograph, gender, marital status, information of any disclosed disability or medical information;
c. right to work documentation;
d. information gathered via the recruitment process such as that entered onto a CV or included in a CV cover letter;
e. references from former employers;
f. details of your education and employment history etc;
g. driving licence (where required and provided);
h. criminal convictions;
i. details of your registration with or membership of any professional bodies required for you to be able to practice in your profession or meet the requirements of the role you have applied for, and details of any sanctions or restrictions placed upon you that
affect your ability to practice in that role.
6. Collecting your Data
6.1. We will retain several pieces of data provided to us directly during your recruitment period. In some cases, we will collect data about you from third parties, such as employment agencies, former employers when gathering references or credit reference agencies.
6.2. Personal data is kept in files or within the Company’s HR and IT systems.
7. Lawful Basis for Processing
7.1. The law on data protection permits us to process your data for certain reasons only where a lawful basis applies. In the main, we process your data to comply with a legal obligation or to manage the employment contract we have with you, including ensuring you are paid correctly. The information below categorises the types of data processing, appropriate to your status, we undertake and the lawful basis we rely on.
7.2. Activity requiring your personal data and lawful basis:
Activity requiring your personal data
Lawful basis (es)
Conducting checks in relation to your right to work
in the UK
Legal obligation.
Conducting checks in relation to your suitability for the role you applied for as required by the
Care Quality Commission (CQC
Legal obligation.
Conducting DBS checks as required by the CQC
Legal obligation.
Conducting checks into professional registration
status with General Medical Council (GMC) or other governing body
Legal obligation and Public task.
Making any required reasonable adjustments during the recruitment process
Legal obligation.
Making recruitment decisions, including salary
offers
Contract and Legitimate interests.
Obtaining expert medical opinion about your
fitness to work
Legal obligation and Legitimate interests.
Handling legal claims
Legal obligation and Legitimate interests.
Fraud prevention.
Legal obligation and Legitimate interests.
8. Processing of Special Category Data
8.1. Where we process special category personal data (e.g. data concerning health, racial or ethnic origin, religious beliefs, or trade union membership), we do so only where a lawful basis under Article 6 of the UK GDPR applies and one of the conditions under Article 9 is met. We rely on the following condition:
· Employment, social security and social protection law – processing is necessary for legitimate interests and the purposes of carrying out our obligations and exercising specific rights in the field of employment, as authorised by the Data Protection Act 2018 (Schedule 1, Part 1, Paragraph 1). This includes ensuring health and safety, administering statutory sick pay, and making reasonable adjustments.
8.2. Where required, we maintain an appropriate policy document outlining our procedures for securing and retaining special category data, in accordance with the Data Protection Act 2018.
9. Special Categories of Data
9.1. Special categories of data may relate to your:
a. Health;
b. sexual orientation;
c. race;
d. ethnic origin;
e. Religion;
f. genetic and biometric data.
9.2. We carry out processing activities using special category data:
a. for the purposes of equal opportunities monitoring;
b. in our sickness absence management procedures;
c. to determine reasonable adjustments.
9.3. Most commonly, we will process special categories of data when the following applies:
a. you have given explicit consent to the processing;
b. we must process the data to carry out our legal obligations;
c. we must process data for reasons of substantial public interest;
d. you have already made the data public.
10. Failure to Provide Data
10.1. Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering a contract with you. This could include being unable to offer you a contract.
11. Criminal Conviction Data
11.1. We will collect criminal conviction data where appropriate given the nature of your role and where the law permits. This data will usually be collected at the recruitment stage and may also be collected during your employment/contract term.
11.2. We use criminal conviction data to determine your suitability, or your continued suitability for the role.
11.3. We rely on the lawful basis of legal obligation given our status as a CQC registered company to process this data.
12. Who We Share Your Data With
12.1. Employees within our company who have responsibility for recruitment, administration of payments and benefits and the carrying out performance related procedures, will have access to your data only where necessary for their role. All employees with such responsibility have been trained in ensuring data is processed in line with UK GDPR.
12.2. Data is shared with third parties for the following reasons:
a. to conduct an occupational health assessment to determine reasonable adjustments to be made (explicit consent will be obtained prior to processing any health-related data);
b. to conduct checks on your right to work;
c. to conduct checks on any criminal record;
d. to conduct checks on your professional registration.
12.3. Where required for the purposes of due diligence, or for the purposes of ensuring the practitioners are on the Private Practitioners Register (PPR) or are individually registered with the third-party clients to whom we supply services, for example, AXA, Cigna or Healthcode. The following may be shared with those third-party clients:
· Clinician names
· Professional body and professional registration number
· Date of birth
· Re-validation date and name of Responsible Officer.
12.4. Such sharing is limited to what is necessary and proportionate for the stated purpose.
12.5. We have a data processing agreement in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data. We do not share your data with bodies outside of the United Kingdom unless appropriate safeguards are in place in accordance with UK GDPR Chapter V.
12.6. Your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.
13. Protecting Your Data
13.1. Your data is protected against accidental loss or disclosure, destruction and abuse and we have implemented processes to guard against such.
14. Retention Periods
14.1. We only keep your data for as long as we need it for, which, in relation to unsuccessful candidates, is a period of 12 months from the end of the recruitment exercise and is then securely
destroyed. Some data retention periods are prescribed by law or regulatory guidance. If your application is not successful and we have not sought consent or you have not provided consent upon our request to keep your data for the purpose of future suitable job vacancies, we will keep your data for six months once the recruitment exercise ends.
14.2. If we have sought your consent to keep your data on file for future job vacancies, and you have provided consent, we will keep your data for 12 months once the recruitment exercise ends.
14.3. At the end of the retention period, we will delete or destroy your data, unless you have already withdrawn your consent to our processing of your data, in which case it will be deleted or destroyed upon your withdrawal of consent.
14.4. Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data and there will be no consequences of withdrawing consent.
14.5. If your application is successful, your data will be kept and transferred to the systems we administer for employees. We have a separate privacy notice for employees, which will be provided to you.
15. Automated Decision Making
15.1. Automated decision-making refers to decisions made about you by a computer or electronic
system, without any human involvement, for example, using digital filtering tools. We will never make significant decisions about you solely through automated means, without input or oversight from a human.
16. Job Applicant Rights
16.1. You have the following rights in relation to the personal data we hold about you:
a. the right to be informed about the data we hold about you and how we use it;
b. The right of access to your personal data. More information can be found in our separate policy on Subject Access Requests;
c. the right to rectification of any inaccurate or incomplete personal data. This is also known as ‘rectification’;
d. the right to erasure of your personal data in certain circumstances. This is also known as ‘erasure’;
e. the right to restrict the processing of your personal data;
f. the right to data portability, allowing you to obtain and reuse your personal data for your own purposes across different services. This is also known as ‘portability’;
g. the right to object to the processing of your personal data in certain circumstances;
h. The right to not to be subject to automated decision-making, including profiling, where it has a legal or significant effect on you.
16.2. If you wish to exercise any of the rights explained above, please contact hr@clinical-partners.co.uk
17. Consent
17.1. Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data.
18. Making a Complaint
18.1. If you think your data rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO). You can contact the ICO at:
Information Commissioner's Office Wycliffe House
Water Lane Wilmslow Cheshire SK9 5AF
or by telephoning: 0303 123 1113 (local rate) or 01625 545 745.
19. Compliance and Ethics
19.1. Our Data Protection Officer can be contacted at: Data Protection Officer
Clinical Partners
Unit 6 Chaldicott Barns Tokes Lane
Semley SP7 9AW
20. Review
20.1. This policy will be reviewed every three years unless policy or legislative changes necessitate an earlier review.
21. Definitions
Term
Definition
UK GDPR
United Kingdom General Data Protection Regulation – data protection law governing the processing of personal data.
22. References
22.1. Primary Legislation
a. UK General Data Protection Regulation (UK GDPR)
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For job applicants to self-employed roles
Table of Contents
10. Who we share your data with...................................................................... 8
12. Automated decision making........................................................................ 9
16. Data protection compliance....................................................................... 10
1. Introduction
1.1. The Clinical Partners Group encourages a working environment where everyone can contribute as fully as possible. Our purpose is to improve the lives of our patients, their families and those who care about them, and to be a trusted provider of mental health and medical services. We therefore apply the same values and standards to our employees and are positive, compassionate and ambitious in our approach to all things.
1.2. In accordance with the United Kingdom General Data Protection Regulation (UK GDPR), we have implemented this privacy notice to inform you, as a self-employed individual providing services to Clinical Partners, of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.
1.3. Data controller details. The Company is a data controller and is registered with the Information Commissioner’s Office (ICO) under registration number Z2868470, meaning that it determines the processes to be used when using your personal data. Our contact details are as follows Governance@clinical-partners.co.uk or Clinical Partners Ltd, Unit 6 Chaldicott Barns, Semley, Wiltshire, SP7 9AW.
2. Purpose
2.1. This notice applies to current and former self-employed Consultants, independent Contractors or other individuals providing services to Clinical Partners, any subsidiary Company, including but not limited to Oxford ADHD and Autism Centre
3. Data Protection Principles
3.1. Under UK GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:
a. processing is fair, lawful and transparent;
b. data is collected for specific, explicit, and legitimate purposes;
c. data collected is adequate, relevant and limited to what is necessary for the purposes of processing;
d. data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay;
e. data is not kept for longer than is necessary for its given purpose;
f. data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures;
g. we comply with the relevant UK GDPR procedures for international transferring of personal data.
4. Types of Data Held
4.1. We keep several categories of personal data on our self-employed service providers, this includes consultants and contractors, to carry out effective and efficient processes. We keep this data in a file relating to each service provider and we also hold the data within our computer systems, for example (but limited to), Sales Force, and SharePoint.
4.2. Specifically, we hold the following types of data, as appropriate to your status:
a. personal and/ or limited company details such as name, address, phone number(s), email address.
b. name and contact details of your next of kin.
c. your gender, information of any disclosed disability you have or other disclosed medical information.
d. right to work documentation.
e. information on your race and religion for equality monitoring purposes.
f. information gathered via the relevant procurement of services (onboarding) process such as that entered onto a CV, or tender documents.
g. references from former employers / service users where relevant.
h. details on your education and employment history etc. if required
i. bank account details.
j. tax codes.
k. Passport, or driving licence (where required and provided).
l. DBS Certificate details
m. information relating to your engagement for services with us, including:
n. type(s) of service(s) provided.
o. Associated rates of pay
p. your wider terms and conditions of engagement.
q. Documentation of formal and informal matters relating to your self-employed professional activities, including personal notes, client feedback, correspondence regarding concerns, and records of self-assessment or performance reviews.
r. internal and external training modules undertaken.
s. building access card records. (where applicable)
t. IT equipment uses including telephones and internet access.
u. Registration details with professional bodies (where applicable).
5. Collecting your Data
5.1. You provide several pieces of data to us directly during the onboarding period and subsequently upon the start of your contract for services.
5.2. In some cases, we will collect data about you from third parties, such as employment agencies, former employers when gathering references or credit reference agencies.
5.3. Personal data is kept in files or within the Company’s IT systems.
6. Lawful Basis for Processing
6.1. The law on data protection allows us to process your data for certain reasons only. In the main, we process your data to comply with a legal requirement or to effectively manage the contract for services that we have with you, including ensuring you are paid correctly.
6.2. The information below categorises the types of data processing, appropriate to your status, we undertake and the lawful basis we rely on.
6.3. Activity requiring your data and lawful bases.
Activity requiring your data
Lawful basis
Carry out the contract that we have entered into with you e.g. using your name, contact details, education history, information on any disciplinary, grievance procedures involving you
Performance of the contract
Ensuring you are paid
Performance of the contract
Ensuring tax and National Insurance is paid
Legal obligation
Carrying out checks in relation to your right to work in the UK
Legal obligation
Making reasonable adjustments for disabled employees
Legal obligation
Making recruitment decisions in relation to both initial and subsequent employment e.g. promotion
Our legitimate interests
Making decisions about salary and other benefits
Our legitimate interests
Ensuring efficient administration of contractual benefits to you
Our legitimate interests
Effectively monitoring both your conduct, including timekeeping and attendance, and your performance and to undertake procedures where necessary
Our legitimate interests
Maintaining comprehensive up to date personnel records about you to ensure, amongst other things, effective correspondence can be achieved and appropriate contact points in the event of an emergency are maintained
Our legitimate interests
Implementing grievance procedures
Our legitimate interests
Assessing training needs
Our legitimate interests
Implementing an effective sickness absence management system including monitoring the amount of leave and subsequent actions to be taken including the making of reasonable adjustments
Our legitimate interests
Gaining expert medical opinion when making decisions about your fitness for work
Our legitimate interests
Managing statutory leave and pay systems such as maternity leave and pay etc
Our legitimate interests
Business planning and restructuring exercises
Our legitimate interests
Dealing with legal claims made against us
Our legitimate interests
Preventing fraud
Our legitimate interests
Ensuring our administrative and IT systems are secure and robust against unauthorised access
Our legitimate interests
Providing employment references to prospective employers, when our name has been put forward by the employee/ex-employee, to assist with their effective recruitment decisions
Legitimate interest of the prospective employer
Carrying out DBS checks as required by CQC
Legal obligation
Checking Professional Registration status with GMC or other governing body
Legal obligation
Carrying out our responsibilities as Responsible Officer (in relation to revalidation of doctor licences)
Legal obligation
We monitor IP addresses and device location information when you access our systems. This is done to confirm the country from which work is being carried out, to comply with our legal and regulatory obligations, and to ensure that work is not completed from locations where we are not authorised to operate. This monitoring is limited to what is necessary for these purposes and is carried out in line with data protection law.
Our Legitimate interest and legal obligation
Enabling due diligence to be carried out by third party clients to whom we will be (as part of a tender process or prior to contract commencement) or do provide services
Our legitimate interests
Processing for recognised legitimate interests under Schedule 4 of the Data (Use and Access) Act 2025, including safeguarding, emergency response, and disclosures to public bodies
Our legitimate interests
7. Special categories of data
7.1. Special categories of data are data relating to your:
a. health.
b. sexual orientation.
c. race.
d. ethnic origin.
e. Religion.
f. trade union membership.
g. genetic and biometric data.
7.2. We carry out processing activities using special category data:
a. for the purposes of equal opportunities monitoring.
b. to determine reasonable adjustments
7.3. Most commonly, we will process special categories of data when the following applies:
a. you have given explicit consent to the processing.
b. we must process the data to carry out our legal obligations.
c. we must process data for reasons of substantial public interest.
d. you have already made the data public.
8. Failure to provide data
8.1. Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering a contract for services with you. This could include being unable to offer you a self-employed contract for services.
9. Criminal conviction data
9.1. We will only collect criminal conviction data where it is appropriate given the nature of the service(s) you are providing and where the law permits us. This data will usually be collected at the onboarding stage, however, may also be collected during your contract term. We use criminal conviction data to determine your suitability, or your continued suitability to provide the agreed service(s) on a self-employed basis. We rely on the lawful basis of legal obligation given our status as a CQC registered company to process this data.
10. Who we share your data with
10.1. Some of our employees have responsibility for onboarding, administration of payment, booking, and the carrying out of performance related procedures and will have access to your data, which is relevant to their role in the management of self-employed service providers. All employees with such responsibility have been trained to ensure that data is processed in line with UK GDPR.
a. Data is shared with third parties for the following reasons:
b. for the administration of payment(s).
c. to carry out checks on your right to work.
d. to carry out checks on any criminal record.
e. to carry out checks on your professional registration.
f. to carry out any relevant surveys.
g. We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us.
h. Where required for the purposes of due diligence, or for the purposes of ensuring the self-employed Clinicians are on the Private Practitioners Register (PPR) or are individually registered with the third-party clients to whom we supply services, for example, AXA, Cigna or Healthcode.
10.2. The following may be shared with those third-party clients:
a. clinician names;
b. professional body and professional registration number;
c. date of birth;
d. re-validation date and name of Responsible Officer.
10.3. We have a data processing agreement in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data. We do not share your data with bodies outside of the United Kingdom.
11. Protecting your data
11.1. We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse and have implemented processes to guard against these risks.
12. Automated decision making
12.1. Automated decision-making means making decision about you using no human involvement e.g. using computerised filtering equipment. In accordance with the Data (Use and Access) Act 2025, we may use automated decision-making tools where appropriate. Where such decisions have legal or similarly significant effects, we will ensure meaningful human intervention is available and provide you with the opportunity to contest the decision.
12.2. No decision will be made about you solely based on automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.
13. Individual rights
13.1. You have the following rights in relation to the personal data we hold about you:
a. the right to be informed about the data we hold about you and what we do with it;
b. the right of access to the data we hold about you. Further details regarding this
c. process can be found in the relevant Data Subject Access Request Policy for self-employed contracted personnel;
d. the right for any inaccuracies in the data we hold about you, however they may come to light, to be corrected. This is also known as ‘rectification’;
e. the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
f. the right to restrict the processing of the data;
g. the right to transfer the data we hold about you to another party. This is also known as ‘portability’;
h. the right to object to the inclusion of any information;
i. the right to regulate any automated decision-making and profiling of personal data;
j. the right to request a review of any exemptions applied to your data access request, including legal privilege or confidentiality, under the DUAA 2025.
13.2. If you wish to exercise any of the rights explained above, please contact hr@clinical-partners.co.uk
14. Consent
14.1. Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data.
15. Making a complaint
15.1. We are required to provide a clear complaints procedure, including an electronic form, and response within 30 days. You may also escalate concerns to the ICO. If you think that your data rights have been breached at:
Information Commissioner's Office Wycliffe House
Water Lane Wilmslow Cheshire SK9 5AF
or by telephone: 0303 123 1113 (local rate) or 01625 545 745.
16. Data protection compliance
16.1. Our Data Protection Officer can be contacted at the following address: Data Protection Officer
Clinical Partners
Unit 6 Chaldicott Barns Tokes Lane
Semley SP7 9AW
17. Review
17.1. This policy will be reviewed every three years unless policy or legislative changes necessitate an earlier review.