Data Privacy Policy.
When HG HEALTH LIMITED processes your personal data, it is required to comply with the Data Protection
Act 2018 (“DPA”) and the UK GDPR (the DPA and UK GDPR are together referred to as the “Data Protection
Legislation”).
Your personal data includes all the information we hold that identifies you or is about you, for example, your
name, email address, postal address, date of birth, location data and in some cases opinions that we document
about you; as well as special categories of data, including but not limited to, medical and health records, Care
Plans and information about your religious beliefs, ethnic origin and race, sexual orientation and political views
[Update as necessary to reflect the personal data that is being processed about the Data Subjects to whom this
data privacy policy will be provided].
Everything we do with your personal data counts as processing it - including collecting, storing, amending,
transferring and deleting it. We are, therefore, required to comply with the Data Protection Legislation to make
sure that your information is properly protected and used appropriately.
This data privacy policy provides information about the personal data we process, why we process it and how
we process it.
Our responsibilities
HG HEALTH LIMITED is the data controller of the personal data you provide. We have appointed Hannah
Ahmed as Registered Manager and they will have day to day responsibility for ensuring that we comply with
the Data Protection Legislation and for dealing with any requests we receive from individuals exercising their
rights under the Data Protection Legislation.
What personal data do we process about you?
We process your personal data in order to provide you with the services you have requested, to fulfil the
contract we have entered into with you and/or to receive services or goods from you. We may also process your
personal data to respond to any queries or comments you submit to us and to correspond with you on a day-to-
day basis. [Note, this paragraph tries to cover all bases including provision and receipt of services. HG
HEALTH LIMITED may feel it is more appropriate to use more than one data privacy policy for non-
employees].
We may need personal data from you to be able to provide services to you, to meet our legal obligations, to
enter into a contract with you and/or to provide you with all the information you need. If we do not receive the
personal data from you, we may be unable to fulfil our obligations to you.
More information about the personal data we process is set out below:
• [Service Users]
[Personal data that we may process about you (depending on the extent of the information you have
provided to us) includes:
• Identity data such as your first name, middle names, last name, marital status, title, date of
birth and gender
• Contact data such as your address, email address and telephone numbers
• Financial data including your bank account and payment card details
• Special categories of data including information about your medical
background and health and diversity/equality information such as your race and
ethnicity]
We process most of your information on the grounds of consent from you, legitimate interests (such
as [please insert a description of the legitimate interests you are pursuing when you process personal
data], performance of a contract we have entered into with you, protection of the vital interests of a
Data Subject or, in the case of special categories of data, processing for the provision of health or social
care or treatment or the management of health or social care systems or services. [Please delete any
that are not appropriate, particularly if HG HEALTH
LIMITED chooses to use more than one data privacy policy depending on the type of Data Subject].
• [Suppliers]
[Personal data that we may process about you includes:
• Identity data such as your first name, middle names, last name, marital status, title, date of birth and gender
• Contact data such as your billing address and delivery address (whether residential or
your company address), email address and telephone numbers
• Financial data including your bank account and payment card details (except to the
extent the financial information is company rather than personal information); and
• Transaction data including details about payments made to you (where you are an
individual)]
We process most of your information on the grounds of our legitimate interests (including a
business relationship with you or the company for which you work) and fulfilment of our contract
with you (where you are an individual). Any information we process about the company for which
you work rather than you as an individual is not covered by this data privacy policy.
• [Candidates]
[Personal data that we are likely to process about you includes:
• Identity data such as your first name, middle names, last name, marital status, title, date of
birth and gender
• Contact data such as your postal address, email address and telephone numbers
• Background data such as your education, career background and work experience
• Personal information such as your skills and qualities
• Any other information that you include on any CV, application or covering letter you
send to us. If this information includes special categories of data we will process that
information on the grounds of consent, because you have chosen to provide it to us.]
We process most of your information on the grounds of our legitimate interests to determine whether
or not we have a suitable vacancy for you.
If we obtain consent from you to the processing of your personal data, you can withdraw your consent at any
time. This will not affect the lawfulness of any processing we carried out prior to you withdrawing your
consent.
Who will receive your personal data?
Please note - although the UK is no longer part of the EU, we still comply with the following:
We only transfer your personal data to the extent we need to. Recipients of your personal data include:
• [insert any potential recipients or categories of recipients]
We do not transfer your personal data outside of the EEA. [If HG HEALTH LIMITED transfers personal data
outside of the EEA, delete this sentence and include the paragraph below instead].
We may transfer your personal data outside of the EEA to [name of recipient of data outside EEA]. [A finding
of adequacy has been made in respect of [relevant country], which means the EU Commission is satisfied
that any data transferred to [relevant country] will be adequately protected]. [We will transfer your personal
data on the basis of a data transfer agreement that incorporates EU model clauses. The EU model clauses
mean that appropriate safeguards will govern the transfer of the data]. [We will transfer your personal data
on the basis of an intragroup agreement, which includes appropriate safeguards to protect your personal
data]. [This paragraph should be included if HG HEALTH LIMITED transfers personal data outside the
EEA. There are a number of optional clauses within this paragraph. HG HEALTH LIMITED will need to
consider the location of the recipient and the grounds on which personal data is transferred and update
this paragraph accordingly].
How long will we keep your personal data?
We will retain your personal data for [confirm retention period – there must be valid reasons to retain the
personal data for the chosen period of time. Personal data must not be retained “just in case” it is needed in the
future. Valid reasons may be, for example, 6 years in case a contract claim arises. HG HEALTH LIMITED
may need to refer to numerous retention periods particularly if this policy covers a number of different types
of individuals]. Your information will be kept securely at all times.
Following the end of the relevant retention period, your files and the personal data covered by the retention
period will be permanently deleted or destroyed.
What are your rights?
You benefit from a number of rights in respect of the personal data we hold about you. We have
summarised the rights which may be available to you below, depending on the grounds on which we
process your data. More information is available from the Information Commissioner’s Office website
(https://ico.org.uk/for-organisations/guide-to-the-general- data-protection-regulation-gdpr/individual-
rights/). These rights apply for the period in which we process your data.
1. Access to your data
You have the right to ask us to confirm that we process your personal data, as well as having the right to request
access to/copies of your personal data. You can also ask us to provide a range of information, although most of
that information corresponds to the information set out in this data privacy policy.
We will provide the information free of charge unless your request is manifestly unfounded, excessive or
repetitive, in which case we are entitled to charge a reasonable fee. We may also charge you if you request more
than one copy of the same information.
We will provide the information you request as soon as possible and in any event within one month of
receiving your request. If we need more information to comply with your request, we will let you
know.
2. Rectification of your data
If you believe personal data we hold about you is inaccurate or incomplete, you can ask us to rectify that
information. We will comply with your request within one month of receiving it unless we do not feel it is
appropriate, in which case we will let you know why. We will also let you know if we need more time to comply
with your request.
3. Right to be forgotten
In some circumstances, you have the right to ask us to delete personal data we hold about you. This right is
available to you:
• Where we no longer need your personal data for the purpose for which we collected it
• Where we have collected your personal data on the grounds of consent and you withdraw that consent
• Where you object to the processing and we do not have any overriding legitimate interests to continue processing the data
• Where we have unlawfully processed your personal data (i.e. we have failed to comply with UK
GDPR); and
• Where the personal data has to be deleted to comply with a legal obligation
There are certain scenarios in which we are entitled to refuse to comply with a request. If any of those apply,
we will let you know.
4. Right to restrict processing
In some circumstances, you are entitled to ask us to suppress processing of your personal data. This means we
will stop actively processing your personal data but we do not have to delete it. This right is available to you:
• If you believe the personal data we hold is not accurate – we will cease processing it until
we can verify its accuracy
• If you have objected to us processing the data – we will cease processing it until we have
determined whether our legitimate interests override your objection
• If the processing is unlawful; or
• If we no longer need the data but you would like us to keep it because you need it to establish,
exercise or defend a legal claim
5. Data portability
You have the right to ask us to provide your personal data in a structured, commonly used and machine-readable
format so that you are able to transmit the personal data to another data controller. This right only applies to
personal data you provide to us:
• Where processing is based on your consent or for performance of a contract (i.e. the right does
not apply if we process your personal data on the grounds of legitimate interests); and
• Where we carry out the processing by automated means
We will respond to your request as soon as possible and in any event within one month from the date we receive
it. If we need more time, we will let you know.
6. Right to object
You are entitled to object to us processing your personal data:
• If the processing is based on legitimate interests or performance of a task in the public interest
or exercise of official authority
• For direct marketing purposes (including profiling); and/or
• For the purposes of scientific or historical research and statistics
In order to object, you must have grounds for doing so based on your particular situation. We will stop processing
your data unless we can demonstrate that there are compelling, legitimate grounds which override your
interests, rights and freedoms or the processing is for the establishment, exercise or defence of legal claims.
Automated decision making
Automated decision making means making a decision solely by automated means without any human
involvement. This would include, for example, an online credit reference check that makes a decision based
on information you input without any human involvement. It would also include the use of an automated
clocking-in system that automatically issues a warning if a person is late a certain number of times (without
any input from HR, for example).
We do not carry out any automated decision making using your personal data. [If HG HEALTH LIMITED
carries out automated decision making, delete this sentence and complete the section below].
We carry out the following types of automated decision making using your personal data: [If HG HEALTH
LIMITED does not carry out automated decision making, delete this sentence and include the sentence
above. If it does carry out automated decision making, provide further information here].
Your right to complain about our processing
If you think we have processed your personal data unlawfully or that we have not complied with UK GDPR,
you can report your concerns to the supervisory authority in your jurisdiction. The supervisory authority in
the UK is the Information Commissioner’s Office (“ICO”). You can call the ICO on 0303 123 1113 or get
in touch via other means, as set out on the ICO website: https://ico.org.uk/concerns/.
Any questions?
If you have any questions or would like more information about the ways in which we process your data,
please contact Hannah Ahmed, hr@hansongrey.com