Registered office: Caledonia House, 223 Pentonville Road, London, N1 9NG.
Company registration number 07963501.
Registered in England and Wales.
Surgical People is a trading name of Surgical People Limited.
Scope and overview
This privacy notice is issued on behalf of the ICS Group and all its group companies. A full list of our group companies and their trading names can be found here, all reference to the ICS Group refers to these companies. If you require a printed copy of this privacy notice or our group companies, please contact us using the details below.
When we mention "we", "us" or "our" in this privacy notice, we are referring to any company in the ICS Group that uses your personal data.
The controller for your personal data is Surgical People Limited.
This privacy notice applies to you when you visit any of our websites across the ICS Group.
Please contact us using the details below if you have any questions about this privacy notice or personal data we hold about you:
• by email to: email@example.com; or
• by writing to: Data Protection Officer, ICSG Ltd, 223 Pentonville Road, London, N1 9NG
If you have any concerns about the personal data we use about you, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, by contacting them at www.ico.org.uk. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please feel free to contact us in the first instance.
We regularly review this privacy notice and will update it where necessary. We do recommend you regularly review this privacy notice to make sure you have the most up to date information. This privacy notice was last updated on 17/12/2019.
This privacy notice will apply to personal data that we collect from you when you:
• visit one of our websites across the ICS Group;
• make an initial job application on one of our websites;
• register as a job seeker on one of our websites;
• request a new password for an online account as a job seeker;
• recommend a friend via one of our websites;
• request a call back via one of our websites (please note when we call you back this may be on a recordable line, as we record our calls for quality and monitoring purpose); or
• comment on blogs or articles on our websites.
We are committed to ensuring that your privacy is protected. If you provide us with personal data, you can be assured that it will only be used in accordance with this privacy notice.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data for purposes below. These are commonly called the lawful basis for processing.
• Legitimate Interests - processing is necessary for the purpose of the legitimate interests pursued by Surgical People Limited or a third-party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data.
• Consent - you have given your consent to the processing of your personal data for the processing detailed in this privacy notice.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose in this privacy notice.
The table below sets out the personal data that we collect and use about you and the lawful basis we will rely on as set out above.
|Who does this apply to?
||Personal data we obtain
||Purpose for processing
|Visitors of the website who wish to register as a job seeker or be contacted by us
||Basic contact details: full name; telephone number; email address*
|| • Honour your request to be contacted
• To enable us to contact you by your preferred name
• To enable you to receive job alerts for suitable job opportunities
• To create an online account to store favourite jobs and speed up the application process
|Visitors of the website who wish to register as a job seeker or be contacted by us
|| • To enable a consultant in your preferred location to contact you
• To assess if we recruit in your preferred location
|Visitors of the website who wish to register as a job seeker or be contacted
• To enable a consultant who specialises in your preferred job role to contact you
• To assess if we recruit for your speciality and prioritise in demand roles and specialities
|Visitors of the website who wish to register as a job seeker
|| • To gain more detail about your experience, giving us a better opportunity to initially assess your suitability for work
|Visitors of the website who wish to recommend a friend to us
||Details of a friend who you would like to refer to us including their:
• Contact number;
• Speciality; and
| • To extend our services to other relevant professionals
• Offer you a financial incentive to refer our services and increase our workforce
|Visitors of the website who wish to be contacted by us
||Your message within the contact form
|| • To enable us to direct you to an appropriate person who can respond to your message/request
We require certain personal data from you. Without this personal data, we would not be able to fulfil your request to contact you or for you to register an account with us for the purposes of us finding you certain job opportunities. These fields have been marked with an “*”.
The personal data that you provide will be shared within the ICS Group, to enable us to provide our services to you, increase the number of job opportunities available to you and improve the services of the ICS Group.
We will share your personal data with the third-parties who provide operational services for us, for example, IT platforms.
We require all third-parties to respect the security of your personal data and to treat it in accordance with data protection laws. Where we share your personal data with third-parties who provide operational services to us, we only permit them to process your personal data for specified purposes in accordance with our instructions.
We will only keep your personal data for as long as is necessary for the purposes for which it was collected. In order to determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of your personal data and the likelihood of a suitable job opportunity arising.
As an international organisation, we may transfer your personal data globally within the ICS Group. Additionally, we may transfer your personal data to third-parties who are outside of the European Economic Area (EEA).
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
• Where we use third-parties outside of the EEA, we may use specific contracts approved by the European Commission, these are sometimes known as standard contractual clauses which give personal data the same protection it has in the EEA; or
• Where we use third-parties based in the US, we may transfer your personal data to them, providing that they are signed up to the EU/US Privacy Shield. This requires the third-party to provide a similar level of protection to personal data shared as is applicable in the EEA.
If you would like more information about the methods used to transfer your personal data outside of the EEA, please contact us at firstname.lastname@example.org.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to only those employees, agents, contractors and other third-parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Information about how you use our website is collected automatically using “Cookies”. Cookies are small files that are sent to your device when you visit a website or app. They stay on your device and are sent back to the website or app they came from when you visit it again. For more information about cookies please visit www.allaboutcookies.org. You can control and delete cookies through your browser settings for more information on how to do this please visit www.allaboutcookies.org/manage-cookies.
We use the following Cookies on our website:
|Type of Cookie
||How we use that Cookie
||A Cookie that will only be stored on a device’s memory during the current browser session. Once the session has been closed the Cookie will be deleted
||These Cookies will allow a more streamlined use of our website. You will be able to navigate around our website and we’ll remember the pages you visited so you can easily find and reach them again
||A Cookie that will be permanently stored on your device’s and will remember information each time you revisit a website
||These Cookies will allow you to save login details for your next visit. These cookies are enabled through your web browser, not our website. You can view your Permanent Cookies within your web browser settings
|Targeted Advertising Cookies
||A Cookie that will remember the things you’re interested in on our website and remind you of these things through targeted adverts, sent via third-party platforms
||After you have visited our website we may send you personalised adverts via third-party platforms such as Facebook, Google or LinkedIn. These adverts are delivered to you so we can continue to engage with you and display new opportunities that may be of interest
|Site Analytical Cookies
||A Cookie that will allow an anonymised analysis of how visitors navigate and use a website
||We use Google Analytics to receive anonymised reports on how long visitors stay on our website, whether they apply for jobs and which of our jobs and web pages are getting the most views and interactions. This information allows us to improve user experience and make sure the content is relevant and interesting
||A Cookie that will appear in third-party embedded content on a website, enabling the third-party to monitor engagement with that content
||We may embed third-party content onto our websites if we believe it is of interest to our website visitors or to improve their experience. This third-party content will carry a Cookie so that the content owner can measure how many people are engaging with that piece of content. We don't control the settings of these Cookies. We recommend you check the third-party websites for more information about their cookies policy and how to manage them
Our website may contain links to other websites provided by third-parties not under our control. When following a link and providing personal data via that link please be aware that we are not responsible for the information provided by that third-party. When you click on links to other websites you should read their privacy notices.
You have the following data protection rights when we use your personal data:
a) Your right to request access to your personal data – this enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
b) Your right to request correction of the personal data that we hold about you – this enables you to have any incomplete or inaccurate personal data we hold about you corrected, though we may need to verify the accuracy of the new personal data you provide to us.
c) Your right to request erasure of your personal data – this enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing under Section (d) where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
d) Your right to object to processing of your personal data – this enables you to object to the processing of your personal data where we are relying on legitimate interests (or those of a third-party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
e) Your right to request restriction of processing of your personal data – this enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the personal data is unlawful but you do not want us to erase it; (c) where you need us to hold the personal data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it.
f) Your right to withdraw consent – this right arises at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you would like to exercise any of these rights, please email email@example.com. In most cases we will deal with your request as soon as possible and at the latest within one calendar month of the request. If we need to extend the time period for responding to your request, we will let you know within the one-month period. We do not charge a fee for any such requests, unless there are exceptional circumstances.