Privacy Statement also applies to our candidates registering.
Healthcare Locums Limited (“We”) are committed to protecting and respecting your privacy.
This policy (together with our terms of and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. This website is governed by the laws of England and Wales and the English and Welsh Courts shall have exclusive jurisdiction over it.
INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following data about you:
- Information that you provide by filling in forms on this site. This includes information provided at the time of registering to use our site, subscribing to our service, posting material or requesting further services. We may also ask you for information when you enter a competition or promotion and when you report a problem with our site.
- If you contact us, we may keep a record of that correspondence.
- We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
- Details relating to our recruitment services and the supply of your services to our clients.
- Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
IP ADDRESSES AND COOKIES
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our site and to deliver a better and more personalised service. They enable us:
- To estimate our audience size and usage pattern.
- To store information about your preferences, and so allow us to customise our site according to your individual interests.
- To speed up your searches.
- To recognise you when you return to our site.
WHERE WE STORE YOUR PERSONAL DATA
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
USES MADE OF THE INFORMATION
We use information held about you in the following ways:
- To ensure that content from our site is presented in the most effective manner for you and for your computer.
- To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
- To carry out our obligations arising from any contracts entered into between you and us.
- To allow you to participate in interactive features of our service, when you choose to do so.
- To notify you about changes to our service.
We may also use your data, or permit selected third parties to use your data, to provide you with information about goods and services which may be of interest to you and we or they may contact you about these by email, post or telephone.
If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data or contact us to let us know at the time of registering with us.
DISCLOSURE OF YOUR INFORMATION
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may disclose your personal information to third parties:
In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
If Healthcare Locums Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
ACCESS TO INFORMATION
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
This statement sets out Healthcare Locums (HCL) Ltd’s commitment to continually improving its practices to combat slavery and human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1st January 2016 to 31st December 2016.
As a provider of health and social care workforce solutions, we and our supply chain recognise that we have a responsibility to take a robust approach to slavery and human trafficking.
HCL Group structure and supply chains
We are a provider of recruitment services in the health and social care sector. We are the parent company of the Healthcare Locums Ltd Group (Group). The Group has over 500 employees worldwide and operates in the UK and Australia. Under The Modern Slavery Act 2015 the Group is required to provide this statement. The Group operates with the following business units:
- Healthcare Locums Ltd (Parent company)
- HCL Healthcare Ltd
- HCL Doctors Ltd
- HCL Nursing Ltd
- HCL Social Care Ltd
- HCL Permanent Ltd
- HCL Managed Services Ltd
- JCJ Locums Ltd
- HCA International
Our supply chains include:
- Temporary workers for the health and social care sector
- Subcontracting suppliers of temporary workers for the health and social care sector
- Learning and development/training
- Laboratory Services
- Occupational Health Services
- Employment Background Checking Services
- Print Solution
- Cleaning & Janitorial
- Office furniture
- Confidential waste supplier
- Couriers & Postal Services
All of which are based in the UK.
Our supply chain outside of the UK includes:
- Supply of (temporary) workers
- Outsource providers
Some of which are based in North America, India and Europe.
The following is the process by which the company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:
- The Group confirms that prior to any supplier being included on our supply chain they have policies and procedures that are congruent with our intention to combat slavery and human trafficking.
- If suppliers do not have their own Modern Slavery policy, we will make our policy available and obtain assurances of the supplier’s commitment to follow prior to supply commencing.
- If, after supply commences, we believe there is an actual breach or risk of breach , we will investigate this following our Complaints & Serious Untoward Incident Policy.
Responsibility for the HCL Group’s anti-slavery initiatives is as follows:
Policies – In addition to the Modern Slavery policy, there are several other Group policies that are used to support the intention of combating slavery and human trafficking and identifying risk. These policies are:
Recruitment & Selection policy
All internal and temporary workers are screened and vetted in line with best practice and relevant legislation to ensure: Authentic and legal documentation, right to work in the UK and identity, as well as assessing for any concerning behaviours/fears/pay or banking irregularities or health issues that may require further review in line with combating Modern Slavery.
We encourage all of our workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the HCL Group. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The HCL Group’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns may raise them with the individuals identified within the policy or they can contact Public Concern at Work’s confidential helpline.
Employee Handbook – Code of Conduct
The HCL Group’s code makes clear to employees the actions and behaviour expected of them when representing the HCL Group. The HCL Group strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
Procurement & Authorisation Levels policy and procedure
The HCL Group is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. This includes the supplier confirming their business process conform to the Modern Slavery Act (2015). The HCL Group works with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. If there are breaches found in the supplier’s adherence to the Modern Slavery Act, or Code of Conduct expected, this will require improvement reviews and may result in the termination of the business relationship if the breaches cannot be resolved. We seek to confirm adherence to combating slavery and human trafficking in our supply chain by requesting this assurance on our supplier questionnaire prior to commencing supply.
Safeguarding of Children policy
Sets out the expectation of temporary workers in identifying, recording and reporting actual or potential safeguarding risk to children. This includes the identification of actual or potential risk of slavery and human trafficking. Internal staff use this policy when there is an allegation raised about safeguarding a child about a temporary worker, or a temporary worker makes contact to raise a concern occurring within their work placement.
Safeguarding of Vulnerable Adults policy
Sets out the expectation of temporary workers in identifying, recording and reporting actual or potential safeguarding risk to vulnerable adults. This includes the identification of actual or potential risk of slavery and human trafficking. Internal staff use this policy when there is an allegation raised about safeguarding an adult, raised about a temporary worker, or a temporary worker makes contact to raise a concern occurring within their work placement.
Diversity & Inclusion policy
Sets out the expectations we have of all our employees, temporary workers and suppliers to embrace diversity and inclusion. In cases where we believe this is not the case we will be mindful of considering whether actual or potential slavery and human trafficking may be a contributing factor. Should there be any cause for concern the policy identifies possible courses of action.
Health & Safety (including Lone Worker) policy
In accordance with its duty under Section 2(3) of the Health and Safety at Work Act 1974 and in fulfilling its obligations to both staff and other persons who may be affected by its activities, HCL group aims to achieve a working environment which is free of work related accidents and ill-health and to this end we will pursue continuing improvements from year to year. This includes any actual or potential risk to health & safety identified with slavery and human trafficking assessments and investigations.
Data Protection policy
The Group is registered with the Information Commissioner’s Office (ICO). This policy ensures the Group adheres to its data protection obligations under the DPA and appropriate action to take where a breach or suspected breach has taken place. The aim of the policy, in line with its DPA obligations, is to ensure all information including sensitive information is processed lawfully, subject’s data is held with their knowledge, consent and for a particular purpose. Subjects are also entitled to request their information by making a subject access request.
Corporate Social Responsibility Policy
Sets out to ensure we behave in a thoughtful and meaningful way in all of our work related transactions. Being mindful of the actual or potential risk of slavery and human trafficking is factored in to all of our transactions.
Quality Assurance Policy
Provides the overview of the Group’s commitment to continued improvement, as well as monitoring and measuring adherence to policy and procedures through scheduled audit, policy updates and reviews. Where risk or actual breaches are found, the policy outlines the various actions that can be used to correct, reduce or mitigate future risk.
An initial risk assessment is completed with a new supplier via a supplier questionnaire; confirming adherence to policy intent and new employees/temporary worker recruitment and vetting process. Scheduled audits are completed to identify risks. At any time where a breach or potential breach is identified, either internally or in the supply chain, it is reviewed using the Complaints & Serious Untoward Incident policy.
At any time where a breach or potential breach is identified, either internally or in the supply chain, it is reviewed using the HCL Complaints & Serious Untoward Incident policy, in conjunction with the National Referral Mechanism framework: http://www.gov.uk/government/publications/human-trafficking-victims-referral-and-assessment-forms/guidance-on-the-national-referral-mechanism-for-potential-adult-victims-of-modern-slavery-england-and-wales
A referral to the Home Office is made using the National Referral Mechanism when referral thresholds are met. This allows for national action to combat modern slavery and provides potential victims with the appropriate support.
HCL Group undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. HCL Group’s due diligence and reviews include assessing the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking in areas which may include but not limited to;
- evaluating the modern slavery and human trafficking risks of each new supplier [this may be part of a more general human rights or labour rights assessment];
- reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
- conducting supplier audits or assessments with a focus on slavery and human trafficking where general risks are identified;
- taking steps to improve substandard suppliers’ practices, including providing advice to suppliers and requiring them to implement action plans to include specific amendments to be made and adhered to. This will be confirmed through a re-auditing process;
- participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking
using, where available, ethical supplier databases, where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular; and
- invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the suspension or termination of the business relationship and reporting to the authorities as appropriate.
- The HCL Group requires new internal personnel to complete an online modern slavery training course within three months of their commencement date. For existing personnel training, an annual refresher must be completed.
- Modern Slavery Assessment Questionnaire for supply chain and subcontractor verification expected to be in place by 1 April 2017, whereby the HCL Group evaluates potential suppliers before they enter the supply chain; and
- reviewing its existing supply chains and subcontractors against the Modern Slavery Assessment Questionnaire expected to be completed by 30 June 2017, whereby the HCL Group evaluates all existing suppliers.
The HCL Group’s modern slavery training will be the main mechanism for raising awareness about the Modern Slavery Act, which will include:
- our business’s purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country’s national minimum wage, or the provision of products by an unrealistic deadline;
- how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
- how to identify the signs of slavery and human trafficking;
- what initial steps should be taken if slavery or human trafficking is suspected;
- how to escalate potential slavery or human trafficking issues to the relevant parties within the HCL Group;
- what external help is available, for example through the Modern Slavery Helpline, Gangmasters Licensing Authority and “Stronger together” initiative;
- what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
- what steps HCL Group should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the HCL Group’s supply chains.
HCL Group has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, the HCL Group’s temporary worker supply is provided with Safeguarding Children and Vulnerable Adult training to equip them to identify all types of abuse. Guidance on Safeguarding Children and Vulnerable Adults, including slavery and human trafficking, and professional responsibility to report accordingly is also provided in the temporary worker’ handbooks. This training is updated annually.
This statement has been approved by the HCL Group’s board of directors, who will review and update it annually.
Chief Executive Officer