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1.1 We are committed to safeguarding the privacy of our software platform and mobile application users; in this policy we explain how we will treat your personal information.
2. Collecting personal information
2.1 We may collect, store and use in accordance with Section 3 of this policy the following kinds of personal information:
(a) Information that you provide when completing your profile on our website or mobile application (including your name, profile picture, gender, date of birth, relationship status, educational details and employment details);
(b) Information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters;
(c) Information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths);
(d) Any information gathered when you click on any Locums Nest content/advertisement through a third party. We will record the various points of entry individuals and organisations go through when viewing Locums Nest. We may operate alongside third party suppliers who are contracted to work with us;
(e) Information that is generated in the course of the use of those services (including but not limited to the timing, frequency and pattern of service use);
(f) Information relating to any job listings you make on our software platform or any other transactions that you enter into through our website;
(g) Information that you post to our platform by the locum (“Employee”) or the NHS organisation (“Employer”), including but not limited to details of the locums registered in your Staff Bank, all details of job posts of vacancies advertised, any direct communication with Locum’s Nest and electronic timesheets;
(h) Information contained in or relating to any communication that you send to us or send through our website and mobile application (including the communication content and metadata associated with the communication); and
(i) any other personal information that you choose to send to us in the course of receipt of Locum’s Nest services.
3. Using personal information
3.1 Personal information submitted to us through our website and mobile application will be used for the purposes specified in this policy or on the relevant pages of the website and mobile application.
3.2 We may use your personal information to:
(a) administer our website, applications and business;
(b) personalise our website and applications for you;
(c) enable your use of the services available on our website and applications;
(d) send statements, invoices and payment reminders to you, and collect payments from you;
(e) send you non-marketing commercial communications;
(f) send you emails and/or in-app notifications that you have specifically requested;
(g) send you our email newsletter (you can inform us at any time if you no longer require the newsletter);
(h) send you marketing communications relating to our business or the businesses of carefully selected third parties, whom we think may be of interest to you, by email or similar online technology (you can inform us at any time if you no longer require marketing communications);
(i) provide our analytics department and third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);
(j) deal with enquiries and complaints made by or about you relating to our website or mobile application;
(k) keep our website and application secure and prevent fraud; and
(l) verify compliance with the terms and conditions governing the use of our website and application (including monitoring private messages sent through our website and application private messaging service).
3.3 We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party's direct marketing other than the direct transfer of information to and from the Employer and Employee.
4. Disclosing personal information
4.1 We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.
4.2 We may disclose your personal information to any of each of our subsidiary companies, our ultimate holding company, and all its subsidiaries (each a “Group Member”) insofar as reasonably necessary for the purposes set out in this policy. We may also, with the Employee’s explicit consent, disclose locum information to any financial or tax advisor to the Employee (“Umbrella Companies”).
4.3 We may disclose your personal information to the extent that we are require to do so by law in the following circumstances:
(a) in connection with any ongoing or prospective legal proceedings;
(b) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
(c) to the purchaser or prospective purchaser of any business or asset that we are or are contemplating selling; and
(d) to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
4.4 Except as provided in this policy, we will not provide your personal information to third parties.
5. International data transfers
5.1 Information that we collect may be stored and processed in and transferred between any of the countries in which we operate within the European Economic Area (“EEA”) in order to enable us to use the information in accordance with this policy.
6. Retaining personal information
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
6.2 Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 Without prejudice to Section 6.2, we will delete personal user details such as profile pictures, location data, usage history and personal messages within 24 hours of a user closing his or her account.
6.4 Without prejudice to Section 6.2, we will delete the following personal data within five years of a user closing his or her account:
(a) Locum history in terms of shifts fulfilled following a match by Locums Nest; and
(b) Organisational data such as total spend on locums, total number of shifts fulfilled via Locums Nest and details (confined to name and GMC number) of internal StaffBank members.
6.5 Notwithstanding the other provisions of this Section 6, we will retain documents (including electronic documents) containing personal data to the extent that we are required to do so by law in the following circumstances:
(a) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
(b) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
7. Security of personal information
7.1 We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
7.2 We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
7.3 All electronic financial transactions entered into through our website and application will be protected by encryption technology.
7.4 You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
7.5 You are responsible for keeping the password you use for accessing our website and applications confidential; we will not ask you for your password (except when you log in to our website and/or applications) and your password will remain invisible to us.
7.6 Locums Nest will report incidents to the ICO and all Contractors within 48 hours of detection of the incident.
8.1 We may update this policy from time to time by publishing a new version on our website.
8.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
8.3 We may notify you of changes to this policy by email or through the private messaging system on our website and or application.
9. Your rights
9.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) the payment of a fee (currently fixed at GBP 10); and
(b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
9.2 We may withhold personal information that you request to the extent permitted by law.
9.3 You may instruct us at any time not to use in accordance with section 3 of his policy your personal information for marketing purposes.
9.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
10. Third party websites
10.1Our website includes hyperlinks to, and details of, third party websites.
10.2We have no control over, and are not responsible for, the privacy policies and practices of third parties.
11. Updating information
11.1Please let us know if the personal information that we hold about you needs to be corrected or updated.
12.2A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
12.3Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
12.4Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
12.5We use both session and persistent cookies on our website.
12.6The purposes of the cookies that we use on our website are so that they can be analysed to create improvements in our upcoming versions of the software platform and mobile application.
12.7Most browsers allow you to refuse to accept cookies; for example:
(a) in Internet Explorer (version 11) you can block cookies using the cookie handling override settings available by clicking "Tools", "Internet Options", "Privacy" and then "Advanced";
(b) in Firefox (version 44) you can block all cookies by clicking "Tools", "Options", "Privacy", selecting "Use custom settings for history" from the drop-down menu, and unticking "Accept cookies from sites"; and
(c) in Chrome (version 48), you can block all cookies by accessing the "Customise and control" menu, and clicking "Settings", "Show advanced settings" and "Content settings", and then selecting "Block sites from setting any data" under the "Cookies" heading.
12.8Blocking all cookies will have a negative impact upon the usability of many websites. With Locum’s Nest it will have an adverse effect on the quality of the data we collate from our users. This data would normally be analysed to create improvements in our upcoming versions of the software platform and mobile application.
13. Data protection registration
13.1We are registered as a data controller with the UK Information Commissioner's Office.
13.2Our Data Protection Officer is Dr Ahmed Shahrabani, 62 Pursewardens Close, W13 9PW.
13.3Our data protection registration number is ZA198860.
14. Our details
14.1This website is www.locumsnest.co.uk.
14.2We are registered in England and Wales under registration number 09976456 and our registered office is at 62 Pursewardens Close, London, W13 9PW.
14.3You can contact us via:
(a) post, using the postal address given above;
(b) our website contact form; and
(c) email, using the email address email@example.com