Privacy notice for job applicants

We will review this Privacy Notice periodically and we advise you to check back on our website for the latest version.

Who has information about me?

Circle Health Group Limited is our main operating company and is part of the Circle Health Holdings Limited group of companies. Some of our hospitals (Southend Private Hospital, Three Shires Hospital and Syon Clinic) and some of the services in some of our hospitals (the oncology service at Beardwood Hospital and some imaging services at Mount Alvernia Hospital and Three Shires Hospital) are owned by partner companies, each of which has a management contract with Circle Health Group Limited (formerly BMI Healthcare Limited) and forms part of the Circle Health Group. A partner company also owns the CT and MRI scanners at The Meriden Hospital; this service is managed by UME.

All these companies are registered at Circle Health Group, 1^st Floor, 30 Cannon Street, London EC4M 6XH and their full names and registered company numbers are as follows:

Circle Health Group Limited (formerly BMI Healthcare Limited) - 02164270
Three Shires Hospital LLP - OC398963
Southend Private Hospital Limited - 05155289
Syon Clinic Limited - 05706302
North West Cancer Clinic Limited - 05706220 - The Beardwood Hospital oncology service
BMI Imaging Clinic Limited - 05706274 - imaging service at Mount Alvernia Hospital
The Pavilion Clinic Limited - 06061941 - imaging service at Three Shires Hospital
The Meriden Hospital Advanced Imaging Centre Limited - 05607465 - MRI and CT service at The Meriden Hospital
Circle Hospital (Reading) Limited - 06995585
Circle Rehabilitation Services Limited - 10527747
Circle Clinical Services Limited - 07714059
CHG Management Services Limited - 05042771

Each of these companies may, to the extent relevant, collect, retain and use information about you and we refer to these collectively as 'Circle Health Group', 'Circle' or 'CHG' in this document.

External websites

We may from time to time include on our websites links to and from the websites of other organisations. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies and notices before you submit any personal data to these websites.

Where did you get this information from and what information does Circle Health Group hold about me?

We have information about you which you have supplied to us as part of the recruitment process, either through uploading of this information to our website, by sending information to us by post or by email, or by providing this information to us over the telephone. On occasion, we may have been provided this information via a recruitment agency. This includes your name and contact details (postal and email addresses and phone numbers) as well as details of your current salary, confirmation of your right to work in the UK without sponsorship, an explanation of any gaps in your CV of more than one month and details of your experience. We ask you also to provide us with a copy of your CV and supporting information (such as professional qualifications), to confirm if you have any criminal convictions and if so, to provide details of these. We will also hold information about you and your suitability for the role which you have provided us during an interview.

To the extent you provide such information to us, we may also hold more sensitive information about you, such as your current or previous physical or mental health, your sex life and/or sexual orientation, your religion, nationality, race and/or ethnicity and genetic or biometric data relating to you. We refer to this as 'more sensitive information' in this Privacy Notice.

Should your application be successful (conditional on checks and other conditions, such as references, being satisfactory), we carry out checks such as confirming your previous employment, qualifications and professional registrations, your right to work in the UK and where appropriate, credit checks. This means we may obtain information about you from professional bodies such as the Nursing & Midwifery Council (NMC), the Health and Care Professions Council (HCPC) and on occasion, also from government agencies such as HMRC or the Home Office as well as from any educational establishments you advise you have a qualification from and previous employers you advise us about and credit checking agencies. We will ask you to complete an application with either the Disclosure & Barring Service (which covers England and Wales) or Disclosure Scotland (which covers Scotland) to confirm whether or not you have any criminal convictions and the results of that application will be sent to us and to you. We will also obtain references from individuals whose details you provide to us.

Successful applicants (conditional on checks and satisfactory references) will also be asked to complete an occupational health assessment. Members of the recruitment team at Circle Health Group start the process and can view the date the assessment has completed but, will not have access to any of the information within the assessment. That information will be visible only to members of our occupational health service involved in providing occupational health assessments within Circle Health Group. Our occupational health service will make an assessment of the information provided (in terms of confirming your fitness to work and whether there are any reasonable adjustments required to be made to enable you to perform the role) and will make this available to the relevant manager and the employee compliance coordinator at the hospital or corporate site where the role is based.

In order for us to process your application, we ask that you provide as much information to us as you can. You are of course free not to disclose information to us and you should only provide such information as you feel comfortable doing so. Please bear in mind, however, that if you are only willing to share limited information, we may not be able to take forward your application.

How will Circle Health Group use the information it holds about me?

We use information about you in connection with your application for a role with Circle Health Group; including:

Assessing your skills, qualifications and suitability for the role
Carrying out background and reference checks
Communicating with you about the recruitment process
Keeping records related to our recruitment processes
Complying with legal or regulatory requirements

It is necessary for us to use information about you as described above in order to pursue our legitimate interest of considering whether or not you are suitable to be appointed to the role for which you have applied.

We may use more sensitive information to advise if any reasonable adjustments need to be made so you can attend an interview and, should you be successful (conditional on checks and satisfactory references), to confirm your fitness to work and any reasonable adjustments that may need to be made to enable you to carry out the role. Where the role for which you are applying entitles us or requires us to do so, we carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history that makes you unsuitable for the role. The level of check will depend on the particular role and we have in place appropriate safeguards which we are required by law to maintain when processing such information.

We may also use more sensitive information to ensure meaningful equal opportunity monitoring and reporting.

We may use your phone number and email address to contact you in relation to your application.

We may also use information about you for maintaining our business records and developing and improving our recruitment processes and monitoring outcomes where we believe there is a business need to do so and our use of information about you does not cause harm to you.

We may also use information about you where there is a legal or regulatory obligation on us to do so (such as the prevention of fraud) or in connection with legal proceedings. In particular cases, it may be necessary for us to use more sensitive information about you in order for us to establish, exercise or defend our legal rights.

We may also use information about you where you have provided your consent to us doing so.

Please see also the more detailed information in the sections below.

Will Circle Health Group share information about me with others?

Yes; we set out these reasons below and assure you that in each case, we share only such information as is appropriate.

Sharing information with our staff who are involved in the recruitment process, including administrative staff, and if you are successful, also with our occupational health team

We will share information relating to you with those of our staff involved in the recruitment process, including administrative staff. Should you be successful (conditional on checks and satisfactory references), information about you will also be shared with our occupational health team (some of whom are not employed by Circle but work with us under contracts which contain strict confidentiality provisions).

Sharing information with previous employers, educational establishments and professional bodies and, where relevant, credit agencies

We may share information relating to you with previous employers, educational establishments and/or professional bodies (and where relevant also credit agencies) to verify information you tell us about your previous experience, qualifications and professional registrations.

Sharing information with third parties whose details you provide as referees

We may share information relating to you with previous employers and individuals whose details you provide to us to request a reference on your suitability for the role you have applied for.

Sharing information with the Disclosure & Barring Service and Disclosure Scotland

Where we are required or entitled (in each case relevant to the role in question), we may share information relating to you with the Disclosure & Barring Service or Disclosure Scotland to confirm whether you have (and the details of) any criminal convictions.

Sharing information with third parties who are not involved in the recruitment process or any of our checks

We may share information about you with external organisations such as our lawyers, auditors, financial, tax and public relations advisors and NHS organisations. We may also share information about you with third party suppliers, which provide us with document scanning and storage facilities. We may also share information about you with those providing us with information technology systems, this includes a recruitment administration management system as well as other non-clinical software applications (and related services) and website hosting. In each case, we would share only such information as was relevant.

Sharing with regulators or because of a legal obligation

We may share information about you with our regulators, including the Care Quality Commission, Healthcare Improvement Scotland and Healthcare Inspectorate Wales (which inspect our hospitals in England, Scotland and Wales respectively). Other regulators with whom we may share information about you include the Human Fertilisation and Embryology Authority (which regulates and inspects all our clinics providing fertility services or which store eggs, sperm or embryos), NHS England (which leads the NHS in England) and the Department of Health (the government department responsible for health and adult social care policy).

Sometimes, we are required to disclose information about you because we are legally required to do so. This may be because of a court order or because a regulatory body has statutory powers to access applicants records as part of their duties to investigate complaints, accidents or health professionals' fitness to practise. Before any disclosure will be made, we will satisfy ourselves that any disclosure sought is required by law or can be justified in the public interest. Information about you may also be shared with the police and other third parties where reasonably necessary for the prevention or detection of crime. On occasion, this may include the Home Office and HMRC.

Audits, surveys and initiatives

In common with other employers, we also look at the quality of our recruitment processes and, separately, at the numbers of historical and current vacancies and applicants for these for trend purposes. We also provide NHS organisations with information to fulfil our obligations under the NHS Workforce Race Equality Standard, which helps ensure employees from black and minority ethnic backgrounds have equal access to career opportunities and receive fair treatment in the workplace. We can assure you that your personal information remains under our control at all times and we ensure any information we provide outside of Circle will not contain any information in which any applicant can be identified, unless it is required by law. Any publishing of this data will be in anonymised statistical form.

Change of hospital ownership

If we were to sell or transfer a hospital or part of our business to another organisation, your records would also transfer to the new owner. Limited information may also be shared, where required, with legal and other professional advisors involved in that transaction.

The reason we would transfer your records is to minimise the disruption to any recruitment process and to ensure we and a new owner were able to comply with our legal obligations regarding the retention of such records.

Where and for how long does Circle Health Group store information about me?

The information about you that we hold and use is held securely in the United Kingdom and stored in paper format and on our secure servers (or those of our third party information technology provider). However, where a referee, previous employer, educational establishment or professional body is based overseas, we may transfer information about you to these, for the reasons described above. In addition, our third-party information technology provider uses some third parties based overseas to support its web hosting service and related software. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice.

We retain your records for certain periods (depending on the particular type of record) under our retention of records policy. For both successful and unsuccessful applications, we retain these records in our recruitment system for one year, with the information for successful candidates subsequently then transferred to our employment records (staff should see our Staff Privacy Notice accessible through our intranet system for further information) and the information relating to unsuccessful candidates then being securely destroyed. These timeframes may be extended in the event of a complaint, legal proceedings or where we are required to do so by a regulatory body. These timeframes are to ensure that information is properly managed and is available whenever and wherever there is a justified need for that information, including to support our legitimate interests, and to meet legal requirements.

If you ask us to retain your information in case of a future suitable vacancy, we will do so for a further period of one year.

If you would like more detailed information on this, please contact our Head of Information Governance & Data Protection Officer (contact details below).

What rights do I have?

The law provides you and other candidates with certain rights in relation to the information about you that we hold. You may exercise these at any time by contacting our Head of Information Governance & Data Protection Officer (contact details below) or as otherwise noted below.

There will not usually be a charge for handling a request to exercise your rights and if we cannot comply with your request, we will usually tell you why. If you make a large number of requests or it is clear it is not reasonable for us to comply with a request, then we do not need to respond or we can charge for doing so.

Right of access

You have the right to access information held about you. This includes details of what information we hold about you and a copy of that information. The information will be provided free of charge and, unless there are grounds for extending the statutory deadline, the information will be provided to you within one month of receipt of your request. Please note we will generally also ask for confirmation of your identity and may need further information from you in order to locate the information, in which case the time period starts from the date we have that detail. Please note that in some cases we may not be able to comply fully with your request, such as where your request also involves information about someone else and it would not be fair to that other person to provide the information to you.