Recruitment – Privacy Notice

How HCML processes your personal data

Health & Case Management Ltd (HCML) collects and processes personal data relating to job applicants as part of its recruitment process. HCML is committed to being transparent about how data is collected and used, and demonstrating this is done in in accordance with the General Data Protection Regulations (“GDPR”) or other Data Protection legislation that may be in force. This privacy notice sets out how HCML does this.

What information does HCML collect and how?

HCML collects a range of information about you. This includes:

  • your name, address and contact details, including email address and telephone number;
  • details of your qualifications, skills, experience and employment history;
  • Information from interviews and phone-screenings you may have;
  • information about your current level of remuneration, including benefit entitlements;
  • information about your entitlement to work in the UK; and
  • equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.
HCML may collect this information in a variety of ways. For example, data might be contained in application forms or CVs (including when these are sent to us as part of speculative applications or queries), obtained from your passport or other identity documents, or collected through interviews or other methods of assessment.

HCML may also collect personal data about you from third parties, such as references supplied by former employers. HCML will only seek information from third parties only once a job offer has been made to you.

Data will be stored in a range of different places, including on your application record, in HCML’s HR management systems and email system.

Why does HCML process personal data?

HCML collects and process your data where it is necessary for a number of purposes and where there is lawful basis to do so, as follows.

Legitimate Interests: HCML has legitimate interests in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows HCML to manage the recruitment process, assess and confirm a candidate’s suitability for employment, decide to whom to offer a job, and maintain a pool of candidates should similar or related positions become . HCML may also need to process data to establish, exercise or defend against legal claims.

Legal Obligations: In some cases, HCML needs to process data to ensure compliance with our legal and/ or statutory obligations. For example, we are required to check a successful applicant’s eligibility to work in the UK before employment starts. HCML may process information about whether or not applicants are disabled  in order to identify reasonable adjustments for candidates who have a disability, and to demonstrate compliance with laws related to employment and discrimination.

Your Consent: Where HCML processes other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes, and will only be processed with your consent.  Processing of these types of data will be carried out to ensure HCML can meet its corporate social obligations by monitoring diversity in our recruitment processes and workforce, and exercise rights under law related to employment or (only where applicable) to establish, exercise or defend legal claims.

HCML will not use your data for any purpose other than recruitment, and will never use your data for direct marketing.

Who will HCML share data with?

HCML may share your data with our group companies and, if you are applying for a senior management position with us, may be required to share your data with its investors or key clients in order to proceed with your application.

In addition, HCML may need to share your personal information with a regulator or otherwise to comply with the law.

HCML will not usually share your data with any other third parties, unless your application for employment is successful and an offer of employment is made. HCML will then share your data with former employers in order to obtain references, and with Civil & Corporate Security Ltd (or other background check provider) in order to perform background checks permitted by law.

How does HCML protect data?

HCML takes the security of your data seriously and has taken appropriate technical and organisational measures to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed by anyone except for authorised persons in the proper performance of their duties.

For how long does HCML keep data?

If your application for employment is unsuccessful (including when you have speculatively applied for a role which is not available, or when an advertised position is no longer available), HCML will hold your data on file for 6 months. At the end of that period, your data is either anonymised or deleted / destroyed (unless HCML need to retain it for longer to exercise or defend any legal claims or meet any other statutory requirements).

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which employee data is held will be provided to you in a separate staff privacy notice.

Your rights

As a data subject, you have a number of rights under data protection law. You can:

  • withdraw your consent where this was explicitly provided to HCML;
  • access and obtain a copy of your data on request;
  • require HCML to change incorrect or incomplete data;
  • require HCML 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 HCML is relying on its legitimate interests as the legal ground for processing; or
  • ask us to transfer your data to another organisation.
If you would like to exercise any of these rights or if you have any questions about this notice or our processing of your data more generally, please contact .

If you believe that HCML has not complied with your data protection rights, you can complain to the Information Commissioner’s Office (

What if you do not provide personal data?

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