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Privacy Policy Recruitment for Forward Health

Last updated: 8th October 2019

Forward Clinical Ltd (Forward) collects and processes personal data when you apply for a career with
us.
We are committed to being transparent about how we collect and use that data and to meeting our
data protection obligations.

 

Data Protection Officer

We have a designated Data Protection Officer (DPO) who provides advice and guidance around our
data protection obligations. Generally, questions you may have around privacy should be sent first
to dpo@forwardhealth.co You can also write to DPO at Forward Health, 113 Shoreditch High St,
Hackney, London E1 6JN.

 

What information do we collect?

Our online recruiting system collects details about you to aid in the hiring process. Information we
collect may include:

  • Your name
  • Your email address, mailing address and primary phone number
  • The name and address of your current employer
  • Names, contact information and addresses for previous employers
  • Information about your level of work experience and level of education
  • The type of job you are looking for, desired salary, and date of availability
  • Whether you are available for relocation if hired
  • Whether you are legally allowed to work in a country without sponsorship
  • How you heard about the open position
  • Your prior history, if any, of applying and/or interviewing positions at Forward
  • Additional questions specific to the requisition

We may collect this information in a variety of ways. For example, data might be contained in
application forms, CVs or resumes, your social media profiles, obtained from your passport or other
identity documents, or collected through interviews or other forms of assessment, including online
tests or psychometrics.

If we offer you a position, we have a legitimate interest to collect personal data about you from third
parties, such as references supplied by former employers and information from employment
background check providers where necessary. We will seek information from third parties only at
the point a job offer has been made to you and we will confirm that we are doing so.

 

Why do we process your personal data?

We use your personal information to determine your eligibility for specific career positions, for
related positions, to notify you of future job openings and hiring events, and to communicate with
you through the hiring process. We may need your personal data to ensure compliance with our
legal obligations. For example, we may be required to check a successful applicant’s eligibility to
work in the UK before employment starts.

We have a legitimate interest in processing personal data during the recruitment process and for
keeping records of the process. Processing data from job applicants allows us to manage the
recruitment process, assess and confirm a candidate’s suitability for employment and decide to
whom to offer a job. We may also need to process data from job applicants to respond to and
defend against legal claims.

We may process information about whether applicants are disabled to make reasonable
adjustments for candidates who have a disability. This is to carry out our obligations and exercise
specific rights in relation to employment.

If you accept a position with us, we may perform a background check that includes seeking
information on criminal convictions and offences. We have a legitimate interest in using this
information to comply with contracts with our customers and for confirming your suitability to the
position.

We will not use your data for any purpose other than the recruitment exercise for which you have
applied.

Where we rely on legitimate interests as a reason for processing your data, we considered whether
those interests are overridden by the rights and freedoms of you and other workers and have
concluded that they are not.

 

Who has access to your data?

Your information may be shared internally for the purposes of the recruitment exercise. This
includes members of the HR and recruitment team, interviewers involved in the recruitment
process, managers in the business area with a vacancy and IT staff if access to the data is necessary
for the performance of their roles.

We also contract with third-parties (“Data Processors”) to manage your personal information. We
only use third-parties who will process strictly according to our instructions and in a manner that
secures the confidentiality, integrity and availability of your personal data. We are responsible for any
data that is transferred to third parties.

Your personal information may be transferred out of your home country. For example, we store all
recruiting-related personal information in the United States. Data is transferred outside the EEA on
the basis of declaration of adequacy, or other safeguards (e.g., the Standard Contractual Clauses or
EU-US Privacy Shield Certification). You may request more details about those safeguards by sending
an email to dpo@forwardhealth.co

We may share your personal information with law enforcement authorities, government authorities,
or other third parties as necessary to comply with legal processes or to meet national security
requirements; protect the rights, property, or safety of Forward, its business partners, you, or
others; or as otherwise required by applicable law.

 

How does Forward protect your data?

We have internal policies and controls in place to try to ensure that your data is not lost, accidentally
destroyed, misused or disclosed, and is not accessed except by its employees in the performance of
their duties.

Where we engage third parties, they process your data based on written instructions, are under a
duty of confidentiality and are obliged to implement appropriate technical and organisational
measures to ensure the security of data.

You may request more details about those safeguards by sending an email to
dpo@forwardhealth.co

 

How long does Forward keep your data?

We will delete your personal information after one year of inactivity on your account (e.g., you have
not contacted us, or we have not contacted you about a specific career opportunity).

 

Your rights

You have several privacy rights. You can:

  • access and obtain a copy of your data within one month of receipt of a written request and
    free of charge;
  • require us to change incorrect or incomplete data;
  • require us to delete or stop processing your data, for example where the data is no longer
    necessary for the purposes of processing;
  • object to the processing of your data where Forward is relying on its legitimate interests as
    the legal ground for processing; and
  • ask Forward to stop processing data for a period if data is inaccurate, the processing is found to
    be unlawful and you object to your data being deleted, your data is no longer needed for
    processing or there is a dispute about whether or not your interests Forward’s legitimate
    grounds for processing data.
  • provide a copy of your data to you in an industry-standard format.
  • If you would like to exercise any of these rights, or if you have any questions or issues,
    please contact dpo@forwardhealth.co

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to us during the recruitment
process. However, if you do not provide the information, we may not be able to process your
application properly or at all.

 

Automated decision-making

Career-related decisions are not based solely on automated decision-making.

 

Dispute resolution

If you believe we have not complied with your data protection rights, please contact
dpo@forwardhealth.co 113 Shoreditch High St, Hackney, London E1 6JN.

If the DPO is not able to provide a satisfactory response, you may escalate to:
The Information Commissioner’s Office, Water Lane, Wycliffe House, Wilmslow – Cheshire SK9 5AF
Phone: +44 1625 545 745