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Genepool Privacy Policy

This policy applies on and from 25th May 2018.

Keeping Your Data Safe.

At Genepool we are committed to keeping your personal data safe and secure and handling it in accordance with our legal obligations. This Privacy Policy sets out in detail the purposes for which we process your personal data, who we share it with, what rights you have in relation to that data and everything else we think it's important for you to know.

Who's in control?
It is important that you understand who is responsible for keeping your data safe. We are the "controller" of all personal data collected. This means that we are responsible for deciding how and why your data is used and for ensuring that your data is handled legally and safely.

What data do we collect and where from?

We collect some data directly from you when you register with Genepool. This data includes the following: 

Following initial registration, we then collect information for compliance purposes to ensure we are meeting the contractual and framework obligations of our Clients when placing an agency worker with them. The information we need for this are:

Data such as your name and telephone number will be stored on work mobile phones.
We also collect information that you voluntarily provide to us when you contact us with queries, complaints, comments or praise.
Other companies who have obtained your permission to share data with us, such as Mandatory Training Providers, DBS check services, Occupational Health Departments, Professional Body Registration Providers, Payroll Departments, Hospital Departments.

What do we use your data for?
It is important that you understand how and why we use the personal data that we hold for you. This section sets out the different purposes for which we process personal data and which types of personal data we need for each purpose. The reason we hold personal data on our candidates is for recruitment purposes and so we can lawfully operate an Employment Business for the purposes of supplying temporary staff to clients. We have an obligation to our clients to provide temporary staff with the correct compliance levels.

Managing your account and providing you with our services

How do we use your data for marketing and advertising purposes? 
As Genepool is a Healthcare agency much of our business relies on the recruitment of temporary staff and contacting current and previous employees. The below outlines how we use your details for marketing and advertising purposes.

Email marketing

Personalised advertising

What is our legal basis for using your data?
Data protection law says that we must tell you the legal basis that we rely on to process your personal data for the purposes that we have notified to you. This section tells you what that legal basis is in relation to each of the purposes set out above.

Except for email marketing, we process your personal data for all the purposes identified under What do we use your data for? and How do we use your data for marketing and advertising purposes?  on the basis that it is in our legitimate interests, or the legitimate interests of third parties with whom we share your data, to carry out these activities. Further information about what those interests are is set out below.

Who do we share your data with?

We do need to share your personal data with some third parties. The third-party suppliers we share your personal data with are as follows: 

We will also share your personal data with third parties in the following circumstances: 

We do not transfer or store your personal data outside the European Economic Area (EEA). If we do carry out any further transfers of your data outside the EEA, we will inform you and we will ensure that the recipient provides an adequate level of protection of your personal data.

You should also be aware that if you choose to share Genepool content on social media via the Facebook and Twitter share buttons, the relevant social media platform will know what page you are on to share that page. The use of that information will be governed by the social media platform's own privacy policy and click the "share" buttons does not result in any other personal data being shared between Genepool and the platform.

How long do we keep your data for? 

We will keep all your personal data for as long as required for Genepools recruitment needs until you inform us otherwise.  You can have this removed at any time by contacting us. If you do this, we will anonymise all your Account Data.

 We may need to keep your data after account closure for limited purposes, for example, if we need your data to respond to any complaints or claims that you make. If this is the case, we will only keep the data for as long as we need to fulfil those purposes.

What rights do you have?

You have several rights under data protection law. These rights and how you can exercise them are set out in this section. We will normally need to ask you for proof of your identity before we can respond to a request to exercise any of the rights in this section and we may need to ask you for more information, for example, to help us to locate the personal data that your request relates to.

We will respond to any requests to exercise your rights as soon as we can and in any event within one month of receiving your request and any necessary proof of identity or further information. If your request is particularly difficult or complex, or if you have made a large volume of requests, we may take up to three months to respond. If this is the case, we will let you know as soon as we can and explain why we need to take longer to respond.

A right to access your information.

You also have a right to ask us to send you a copy of your account data and all other personal data that we hold about you (subject to some exceptions). A request to exercise this right is called a "subject access request" and must be made in writing to dataprotection@genepoolmedical.com or Genepool Personnel 216-218 Main Road Biggin Hill Kent TN16 3BD.

A right to object to us processing your information.

You have a right to object to us processing any personal data that we process where we are relying on legitimate interests as the legal basis of our processing. This includes all your personal data that we process for all the purposes set out in this Privacy Policy, with the exception of our use of your email address to send you marketing communications with your consent (but you can withdraw your consent to this at any time). 

If we have compelling legitimate grounds to carry on processing your personal data, we will be able to continue to do so. Otherwise, we will cease processing your personal data. 
You can exercise this right by emailing dataprotection@genepoolmedical.com 

Remember that you can always delete your account at any time by contacting the Genepool team.

A right to ask us not to market to you
You can ask us not to send you direct marketing or advertising. You can do this by opting out of the advertising you no longer want to receive. In relation to email marketing, you can also opt out by responding to any of our email marketing communications. 
Please note that it can take a short time for opt-out requests to take effect.
 

How do we use your data for marketing and advertising purposes? 

A right to have inaccurate data corrected
You have a right to ask us to correct inaccurate data that we hold about you. If we are satisfied that the new data you have provided is accurate, we will correct your personal data as soon as possible. 
You can update your own personal data at any time by speaking with a member of the Genepool team.

A right to have your data erased
You have a right to ask us to delete your personal data in certain circumstances, for example, if we have processed your data unlawfully or if we no longer need the data for the purposes set out in this Privacy Policy. 
We will fully anonymise any personal data we hold about you when you close your account, as set out under 

How long do we keep your data for? 

If you ask us to delete your personal data and you are happy for your account to be closed, we will close your account and fully anonymise your personal data as set out above. If you ask us to delete your personal data but you do not want your account closed, we may not be able or obliged to comply with this as we will usually need to keep processing your data in a personally identifiable form to keep your account open.

If you would like to make a request to exercise this right, please email dataprotection@genepoolmedical.com.

If we are required by law to comply with your request, we will fully anonymise your data it so that it is no longer personal data and cannot be used to identify you.

A right to have processing of your data restricted
You can ask us to restrict processing of your personal data in some circumstances, for example, if you think the personal data is inaccurate and we need to verify its accuracy, or if we no longer need the data but you require us to keep it so that you can exercise your own legal rights. 

Restricting your personal data means that we only store your personal data and don't carry out any further processing on it unless you consent, or we need to process the data to exercise a legal claim or to protect a third party or the public.

 How can you contact us? 
If you have any questions or concerns about this Privacy Policy and/or our processing of your personal data, you can get in touch with us using: dataprotection@genepoolmedical.com

 What if you have a complaint?
You have a right to complain to the Information Commissioner's Officer (ICO), which regulates data protection compliance in the UK if you are unhappy with how we have processed your personal data. 
You can find out how to do this by visiting www.ico.org.uk (opens in a new window).

What if this policy changes?
We may make changes to this Privacy Policy from time to time. Any changes we make will be posted on this page. We may also notify you by email if significant changes are made.

Our Website.

Minors

The Genepool Medical website (www.genepoolmedical.com)is not intended for children and we ask that no one under the age of 18 submits personal information to us or uses the site without supervision of a parent or guardian.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over others website and therefore cannot take any responsibility for it.

Cookies

Cookies are tiny text files stored on your computer when you visit certain web pages. None of our cookies store personal information. We're giving you this information as part of our initiative to comply with recent legislation, and to make sure we're honest and clear about your privacy when using our website.

Our cookie policy

To make your experience on our websites as specific to your needs as possible you will need to accept cookies. Our cookies do not store sensitive information such as your name or address they simply inform us of your past and current browsing behaviour i.e. what browser you use and how many times you visit the site. If you'd prefer to restrict, block or delete cookies from our website, or any other website, you can use your browser to do this. Each browser is different, so check the 'Help' menu of your browser (or your mobile phone's handset manual) to learn how to change your cookie preferences.

How to turn cookies off using your browser

If cookies aren't enabled on your computer, it means that we won't be able to customise your web experience on our website. Regardless, if you wish to turn cookies off in your browser please consult your browser documentation

Further information about cookies

If you'd like to learn more about cookies in general and how to manage them, visit www.aboutcookies.org.