Skilled Medical Pty Ltd ABN 73 112 482 526 (Australia) & Skilled Medical Ltd Company number 07260946 (UK) hereafter referred to as “Skilled Medical” takes seriously its commitment to preserve the privacy of the personal information that we collect as an APP Entity, under the Australian Privacy Principles and in accordance with the UK’s General Data Protection Regulation (GDPR). Skilled Medical is an is an international medical recruitment agency, placement and services firm which provides work-finding services to its clients and work-seekers in Australia, New Zealand and the United Kingdom. In providing work-finding services, we will process personal data (including sensitive personal data) in accordance to these privacy principles so we can provide our services.
This policy applies to information held about you and individuals connected to your business by Skilled Medical as an APP entity and as a Data Controller, as described below. It explains what information we collect about you, how we’ll use that information, who we’ll share it with, the circumstances when we’ll share it and what steps we’ll take to make sure it stays private and secure. It continues to apply even if your agreement with us ends.
The contact details for Skilled Medical set out in this notice are:
PO Box 1408
Carlton VIC 3053
91 Wimpole Street
Marylebone London W1G 0EF
Or via email: firstname.lastname@example.org
You may provide your personal details to Skilled Medical directly, such as submitting an online question, query or feedback with us via our Skilled Medical websites and/or mobile sites and providing your registration details via email, post or phone and via our online registration/enquiry forms. When you submit your online registration form via Skilled Medical’s AU/NZ or UK website we are obtaining your acknowledgment/consent to our Privacy Collection Notice when you submit your personal information to us. Skilled Medical must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services and/or information relating to job roles relevant to you we will only use your personal data in accordance with the terms of the following statement:
We will only collect information in line with relevant regulations and law that is reasonably necessary and where Skilled Medical has a legitimate reason to process your information for the proper performance of our activities or functions as an international medical recruitment agency, placement and services firm. We will not collect personal information just because we think it could be useful at some future stage, if we have no present need for it. We also do not collect or use personal information for the purposes of unlawful discrimination.
If we receive unsolicited personal information from you or about you, Skilled Medical will take such measures as we think appropriate to delete it from our internal systems.
Please be aware that you have the following data protection rights:
- The right to be informed about the personal data the company processes on you;
- The right of access to the personal data the company processes on you;
- The right to rectification of your personal data;
- The right to erasure of your personal data in certain circumstances;
- The right to restrict processing of your personal data;
- The right to data portability in certain circumstances;
- The right to object to the processing of your personal data that was based on a public or legitimate interest;
- The right not to be subjected to automated decision making and profiling; and
- The right to withdraw consent at any time.
There may be circumstances where Skilled Medical will still need to process your data for legal or official reasons. If this is the case, we will inform you and restrict the data to only what is necessary for the purpose of meeting those specific reasons.
Skilled Medical manages personal information, as an APP Entity, under the Australian Privacy Principles and as a Data Controller. The Skilled Medical Privacy Collection Notice & Consent to Electronic Transaction Policy complies with the Australian Privacy Act 1988 and the Australian Privacy Principles.
Skilled Medical is a contracted service provider to public and private health care organisations throughout Australia, New Zealand and the United Kingdom. It may become necessary for us to collect and manage personal information as an agency within the privacy legislatives of a different country other than where you reside or have provided that information.
Information we collect from you will commence when you submit an online question, query or feedback with us via our Skilled Medical websites and/or mobile site, provide your registration details via email, post or phone and your online use related to Google Analytics (including information on how you visit and use web pages on our websites and/or mobile site including your IP address and web browser version).
- We check that it is reasonably necessary for our functions or activities as an international medical recruitment, placement and services firm;
- We record and hold your information in our Information Record System - PLACEM®;
- We retrieve your information when we need to use or disclose it for our functions and activities as an international medical recruitment, placement and services firm. At that time, we check that it is current, complete, accurate and relevant. This will sometimes mean that we have to cross-check the information that we collect from you with third-parties once again - especially if some time has passed since we last checked;
- Skilled Medical acknowledges that an individual has the right to not identify themselves, or to use a pseudonym when dealing with us. However, this only applies if it is practicable for Skilled Medical to do so and it doesn’t impact our service delivery to our customers and clients;
- Subject to some exceptions, we permit you to access your personal information in accordance with the legislative requirements of Australia, New Zealand, and the United Kingdom;
- We destroy or de-identify your personal information when it is no longer needed for any purpose which it may be used or disclosed provided that it is lawful for us to do so; and
- We do not destroy or de-identify information that is contained in a Commonwealth Record.
This policy may change over time due to changes to privacy laws, technology and our business practices. If you use our website regularly or conduct transactions with us that involve collection of your personal information, it is important that you check this policy regularly to ensure that you are aware of the extent of any consent, authorisation or permission you might give.
Kinds of Information that We Collect and Hold
The type of personal information that we collect and hold is information that is reasonably necessary for the proper performance of our functions and activities as an international medical recruitment, placement and services firm and is likely to differ depending on whether you are:
- A Workseeker - i.e. someone who is looking for a placement or work through us; or whom we have identified as a person, who might be receptive to an offer of a placement or work through us;
- A Client - i.e. someone other than a Workseeker who is looking to acquire our services as an international medical recruitment, placement and services firm or whom we have identified as someone, who might be interested in acquiring our services; and
- A Referee - i.e. a person from whom we have sought facts or opinions regarding the suitability of one of our Workseekers for work or positions through us and who may be a Referee nominated by the Workseeker, a Client or us.
Sometimes we may collect sensitive information, this information is only collected with your consent and where it is necessary for the performance of our functions and activities as an international medical recruitment agency, placement and services firm. Sensitive information will need to be collected where it relates to a genuine occupational requirement or an inherent requirement of the job or work being considered. Our collection of some types of sensitive information is also governed by equal opportunity and anti-discrimination laws.
The type of information that we typically collect and hold about Workseekers is information that is necessary to assess amenability to work offers and work availability, suitability for placements or to manage the performance in work obtained through us. It includes:
- Information submitted and obtained from Workseekers and other sources (e.g. Referees or Clients) in connection with enquiries/applications/registrations for work;
- Personal details such as name, address, contact details, date of birth and gender;
- Information about personality, character, skills, qualifications and experience;
- Information about career path and preferences;
- Access to your qualifications and experience to determine you will meet an employer's requirements;
- Information about work entitlement and ability to undertake specific types of work;
- Work performance information;
- Information about incidents in the workplace;
- Information submitted and obtained in relation to absences from work due to leave, illness or other causes;
- Bank details, Tax File or VAT Number, Business or Company registration details or any other relevant invoice information;
- Information for criminal history check applications, criminal history records; and
- Worker health checks including immunisation status
- Information relating to your visa details if applicable
Information that we collect, hold, use and disclose about Workseekers is typically used for:
- Work placement operations and placement opportunities;
- Recruitment functions;
- To help match the needs and availability of health professionals and health employers;
- To supply required supporting documentation required in the employment process;
- To process travel and related arrangements and other transactions;
- To facilitate participation in the loyalty and referral rewards programs of Skilled Medical and other organisations;
- To use information from market research activities to improve the range and level of services we provide where this is permitted and whilst you are registered with us;
- Staff management;
- Payment purposes;
- Risk management; and
- Statistical purposes and statutory compliance requirements.
The type of information that we typically collect and hold about clients is information that is necessary to help us manage the presentation and delivery of our services and includes:
- Client relationship information;
- Information about the position, contracting and hiring authority;
- Information about team structures and roles;
- Information about incidents in the workplace; and
- Financial information such as banking and entity details.
Personal information that we collect, hold, use and disclose about clients is typically used for:
- Client and business relationship management;
- Work placement operations;
- Recruitment functions;
- Training needs assessments;
- Risk management;
- Work health and safety operations;
- Marketing services to you; and
- Statistical purposes and statutory compliance requirements.
The type of information that we typically collect and hold about Referees is information that is necessary to help to make determinations about the suitability of one of our Workseekers for particular jobs or particular types of work and may include:
- Information about work position, authority to give a reference and preferred contact details;
- Opinions of the Referee regarding the Workseeker's character, work performance and work environment;
- Facts or evidence in support of those opinions, sometimes involving the Referee's own knowledge and experience of having worked with the Workseeker; and
- Information about incidents in the workplace.
Personal information that we collect, hold, use and disclose about Referees is typically used for:
- To confirm identity and authority to provide references;
- Workseeker suitability assessment;
- Recruitment functions; and
- Risk management.
Automated Decision Making
Skilled Medical uses automated decision making in pre-selecting Workseekers by their level and disciplines to match the requirements of the role our clients have requested.
We market to candidates and clients using a variety of methods including email, phone, SMS, online advertisements and printed marketing materials. We will only use personal information related to our business, except where you have specifically requested we don’t. We may use personal information for the purposes of contacting you about our goods and services.
If you do not wish to have your personal information used for direct marketing purposes, you may contact your Recruitment Consultant or our Privacy Coordinator on: email@example.com and request not to receive direct marketing communications from us. Upon receipt of this request, your marketing preferences will be updated in our internal systems.
Any opinions you provide to us such as testimonials, may be passed onto a third-party for the purposes of creating marketing materials. In these cases, we will ask your consent before passing this information onto the third-party.
How your Personal Information is Collected
How we will generally collect your personal information are likely to differ depending on whether you are:
- A Workseeker
- A Client
- A Referee
Sometimes the technology that is used to support communications between us will provide personal information to us - see our section on Electronic Transactions.
Personal information will be collected from you directly when you fill out and submit one of our application/registration forms or any other information relating to your application to us for work.
Information will also be collected electronically via our telecommunications or email systems. See our section on Electronic Transactions.
Personal information is also collected when:
- We receive or give any reference about you;
- We receive results of enquiries that we might make of your former employers, work colleagues, professional associations or registration body;
- We receive the results of any competency, psychometric or medical test;
- We receive performance feedback;
- We receive any complaint from or about you in the workplace;
- We receive any information about a workplace accident in which you are involved;
- We receive any information about any insurance investigation, litigation, registration or professional disciplinary matter, criminal matter, inquest or enquiry in which you are involved; and
- You provide us with any additional information about you.
Personal information about you may be collected:
- When you provide it to us for business or business related social purposes; and
- Electronically through our telecommunications and technology systems – for more information see our section on Electronic Transactions.
Personal information about you may be collected when you provide it to us:
- In the course of our checking Workseeker references with you and when we are checking information that we obtain from you about Workseekers;
- For business or business-related social purposes;
- Electronically through our telecommunications and technology systems – for more information see our section on Electronic Transactions.
Photos & Images
We may request proof of identification from you including copies of your passport, visa and or driver’s licence and will only do so for the proper performance of our functions and activities as an international medical recruitment, placement and services firm.
We may request scanned copies of proof of your ID in cases where sighting photographs or proof of identify documents is not possible.
At times, video surveillance which operates in or near our premises may capture images of you.
You should also read our section about Electronic Transactions because sometimes your communications with us may attach profile images of yourself that you have uploaded to the Internet.
This section explains how we handle personal information collected from our websites, www.skilledmedical.com and www.skilledmedical.co.uk and by other technology in the course of electronic transactions.
It is important that you understand that there are risks associated with use of the Internet and you should take all appropriate steps to protect your personal information.
It is important that you:
- Be careful what information you share on the Internet;
- Use privacy tools on the site - control access to your search listing and profile; and
- Make sure your anti-virus and data protection software is up-to-date.
Please contact us on firstname.lastname@example.org if you have concerns about making contact via the Internet.
Sometimes, we collect personal information that individuals choose to give us via online forms or by email, for example when individuals:
- Ask to be on an email list such as a job broadcast notification list;
- Register as a site user to access facilities on our site such as a job notification board;
- Make a written online enquiry or email us through our websites;
- Submit a CV/resume by email or through our websites; and
- Follow, interact and converse via social networking platforms such as Facebook, Twitter and LinkedIn.
Social Networks and Web Searches
In order to assess your suitability for positions and to assist you in finding work, we will need to collect, use and disclose personal information about you. We will conduct background checking via social network media sites, Google searches, regulatory and immigration sites and medical registration boards, for the purposes of assessing suitability for representation by Skilled Medical.
When you look at our websites, our Internet service provider makes a record of the visit and logs (in server logs) the following information for statistical purposes:
- Your server address;
- Your top-level domain name (for example .com, .gov, .org, .au, .nz, .uk, etc);
- The pages you accessed and documents downloaded;
- The previous site you visited; and
- The type of Internet browser being used.
We do not identify users or their browsing activities except, in the event of an investigation, where a law enforcement agency may exercise a warrant to inspect the Internet service provider's server logs.
Cookies are uniquely numbered identification numbers like tags which are placed on your browser. By themselves cookies do not identify you personally, but they may link back to a database record about you. If you register on our websites, we will then link your cookie back to your personal information details.
The website statistics for www.skilledmedical.com and www.skilledmedical.co.uk are generated from this usage data, as outlined above, and analytics programs such as Google Analytics to view and access this data.
If we use web beacons, we will display a clearly visible icon on the page. The icon will include the name of the company collecting information and will be labelled as a tracking device. The web beacon will be linked to a page disclosing what data is collected, how it is used, and which companies receive the data. Web visitors will be able to opt out of data collection by web beacons. Web bugs will not be used to collect sensitive information.
Cloud Computing Services
In cases where we use cloud computing services, we will take reasonable steps to ensure that:
- Disclosure of your personal information to the cloud service provider is consistent with our disclosure obligations of Australia, New Zealand and the United Kingdom. This may include ensuring that we have obtained your consent, or that the disclosure is for purposes within your reasonable expectations;
- Disclosure is consistent with any other legal obligations, such as the restrictions on the disclosure of tax file number information or the disclosure by private employment agencies of Workseeker details; and
- Our Cloud computing services provider’s terms of service recognise that we are bound by obligations to protect the privacy of your personal information and that they will not do anything that would cause us to breach those obligations.
Please make sure that you do not upload photographs of any individuals who have not given consent to the display of their photograph. Displaying photographs without that person’s consent may breach privacy laws and you may be responsible for any legal consequences.
Our technology systems log emails received and sent and may include voting, read and receipt notifications to enable tracking.
When your email address is received by us, it may be added to an email mailing list for the purposes of communicating with you information we feel you would be interested in (unless you have specifically requested not to be added to any mailing lists) or you opt-out of receiving Skilled Medical communications.
Call & Message Logs
Our telephone technology (systems and mobile phones) logs telephone calls and messages received and sent and enables call number display, which may include your profile picture if you have provided it.
When your call number is received by us because you phone us or send us a message, the number (and profile picture) will only be used or disclosed for the purpose for which you have provided it and it will not be added to a phone list or used or disclosed for any other purpose without your consent other than as may be permitted or required by law.
Teleconference & Video Conferences
Teleconferences and video conferences may be recorded with your consent. In cases where it is proposed that they be recorded, we will tell you first the purpose for which they are to be used and retained.
We use an internal, secure recruiting software, database and placement system to log and record recruitment operations. The software allows us to perform complex search and job matching based on the details you have provided us, and operates from servers that permit disclosure to cross-border recipients. Your information will only be used or disclosed for recruitment purposes.
Our employees use laptops, tablets, phones/mobile phones and other portable electronic devices that allow them to access, retrieve and store your personal information.
Recognising the environmental advantages and efficiencies it provides, we operate a partially paperless office. As a result, your paper-based communications sent to us may be digitised and retained in digital format. The paper-based communications may be culled.
It is therefore important that, except where specifically requested, you do not send us originals of any paper-based document and you retain copies for your own records.
Where we require original paper-based documents, we will return them to you once they are no longer required by us for the purpose for which they may be used or disclosed.
How Your Personal Information is Held
We take a range of measures to protect your personal information.
When your personal information is collected, it will be held in our Information Record System - PLACEM®. It will be held until it is no longer needed for any purpose for which it may be used or disclosed at which time it will be de-identified or destroyed provided that it is lawful for us to do so.
Your personal information is held in our internal, secure recruitment software, database and placement system which has restricted access to employees with approved login credentials and only accessed by persons authorised to do so as is reasonably necessary for the proper performance of our functions and activities as an international medical recruitment, placement and services firm.
There are some inherent risks in the use of the Internet Communications and other Technologies.
It is important that you read the section on Electronic Transactions and Cross Border Disclosures if you are using Internet Communications or other technologies to communicate with us.
Our Information Records System
Your information is stored in our internal recruiting software, database and placement system and network drives.
Your information is also securely retained as part of our backup and Disaster Recovery processes. Backups are secured with access by our authorised IT employees only.
Where we utilise Cloud computing services, please also refer to our Electronic Communications – Cloud Computing Services to understand our obligations.
We take all reasonable steps to ensure your personal information remains secure and confidential and is only used as is reasonably necessary for the proper performance of our functions and activities as an international medical recruitment, placement and services firm.
We take a range of measures to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure and these measures include:
- Staff training;
- Document naming protocols;
- "Clean desk" procedures;
- Password protection;
- Office alarm systems and restricted access policy;
- Need-to-know and authorisation policies;
- Policies on laptop, mobile phone and portable storage device security;
- Procedures including shredding and secure disposal etc.;
- Sensitive and confidential information management policy.
This section deals with our disclosure policies. Personal Information that we hold about you is only disclosed for the primary and related purposes for which it was collected. In this section, you will find out about our policies dealing with:
- General Disclosures;
- Related Purpose Disclosures; and
- Cross Border Disclosures.
We may disclose your personal information for any of the purposes for which it is primarily held or for a related purpose where lawfully permitted.
We may disclose your personal information where we are under a legal duty to do so.
Disclosure will usually be:
- Internally and to our related entities;
- To our Clients; and
- To Referees for suitability and screening purposes.
In addition to disclosures for general purposes, we may also disclose your personal information for a range of related purposes.
Related Purpose Disclosures
We outsource a number of services to contracted service providers from time to time. Our contracted service providers may see some of your personal information. Typically, our contracted service providers will include:
Software solutions providers;
- Software solutions providers;
- IT contractors and database designers and Internet service suppliers;
- Legal and other professional advisors;
- Insurance brokers, loss assessors and underwriters;
- Background checking and screening agents; and
- Travel/booking agents
We take reasonable steps to ensure that terms of service with our contracted service providers recognise that we are bound by obligations to protect the privacy of your personal information and that they will not do anything that would cause us to breach those obligations.
Some of your personal information may be disclosed to overseas recipients in our capacity as an international medical recruitment agency, placement and services firm which provides work-finding services to its clients and work-seekers. Skilled Medical operates within multiple countries detailed in the below table, we have also outlined the type of information disclosed and likely recipients, so far as is practicable.
Type of Information
Personal and sensitive information including but not limited to: CVs/ resumes, qualifications, results of background checks, photo identification and/or any other documentation required for the purpose of your job search or applications with regulatory or immigration bodies.
Our Australian-based Clients as is reasonably necessary for the proper performance of our functions and activities as a medical recruitment agency, placement and services firm.
Contacts at the Australian Health Practitioner Regulation Agency to confirm medical registration applications.
Personal and sensitive information including but not limited to: CVs/resumes, qualifications, results of background checks, photo identification and/or any other documentation required for your job search or applications with regulatory or immigration bodies.
Our New Zealand-based Clients as is reasonably necessary for the proper performance of our functions and activities as a medical recruitment agency, placement and services firm.
Contacts at the Medical Council of New Zealand to confirm medical registration applications.
Personal and sensitive information including but not limited to: CVs/ resumes, qualifications, results of background checks, photo identification and/or any other documentation required for your job search or applications with regulatory or immigration bodies.
Our United Kingdom-based Clients as is reasonably necessary for the proper performance of our functions and activities as a medical recruitment agency, placement and services firm.
Contacts at the General Medical Council to confirm medical registration applications.
We will take such steps as are reasonable in the circumstances to ensure that the overseas recipient does not breach the privacy legislations within their country.
However, we cannot guarantee that any recipient of your personal information will protect it to the standard to which it ought to be protected. The costs and difficulties of enforcement of privacy rights in foreign jurisdictions and the impracticability of attempting to enforce such rights in some jurisdictions will mean that in some instances, we will need to seek your consent to disclosure.
Access & Correction
You have a right to access and correct your personal information/data. This section sets out our policy dealing with:
• Access; and
Subject to some exceptions that are set out in international privacy laws, you can gain access to the personal information that we hold about you.
An important exception is any evaluative material contained in references that we obtain will be collected under obligations of confidentiality that we make and which the communicator of that information is entitled to expect will be observed.
If you wish to obtain access to your personal information you should contact our Privacy Coordinator on email@example.com.
You should also anticipate that it may take a little time to process your application for access as there may be a need to retrieve information from storage and review information in order to determine what information may be provided. We will generally respond to your request for access within fourteen (14) working days.
If we refuse to give access to the personal information or to give access in the manner requested by you, we will provide you with a written notice that sets out:
• The reasons for our refusal except to the extent that, having regard to the grounds for the refusal, it would be unreasonable to do so; and
• The mechanisms available to complain about our refusal.
We will take reasonable steps to ensure information we hold about you is accurate and up- to-date where it is practicable to do so. We also rely on you to tell us when there are changes to your personal information that we hold about you. This could be for example, a change of address or change to your employment status, level and discipline.
We will take such steps as reasonable in the circumstances to correct that information to ensure that, having regard to the purpose for which it is held, the information is accurate, up- to-date, complete, relevant and not misleading.
If we have disclosed personal information about you that is inaccurate, out of date, incomplete, irrelevant or misleading, you can ask us to notify the third-parties to whom we made the disclosure and we will take such steps (if any) as are reasonable in the circumstances to give that notification unless it is impracticable or unlawful to do so.
If you find that personal information that we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, you can ask us to correct it by contacting us on firstname.lastname@example.org.
In some cases, we may not agree that the information should be changed.
If we refuse to correct your personal information as requested by you, we will provide you with a written notice that sets out:
• The reasons for the refusal except to the extent that it would be unreasonable to do so; and
• The mechanisms available to complain about the refusal.
You may also ask us to provide a statement that the information is contested as being inaccurate, out of date, incomplete, irrelevant or misleading and we will take such steps as are reasonable to do so.
You have a right to complain about our handling of your personal information if you believe that we have interfered with your privacy. In this section, you can learn:
• How to complain; and
• How your complaint will be handled.
How to Complain
If you are making a complaint about our handling of your personal information, it should first be made to us in writing.
You can make complaints about our handling of your personal information to our Privacy Coordinator on email@example.com
How Your Complaint Will Be Handled:
When we receive your complaint:
- We will take steps to confirm the authenticity of the complaint and the contact details provided to us to ensure that we are responding to you or to a person whom you have authorised to receive information about your complaint;
- We may ask for clarification of certain aspects of the complaint and for further details;
- We will consider the complaint and may make enquiries of people who can assist us to establish what has happened and why;
- We will require a reasonable time (usually 30 days) to respond to you;
- If the complaint can be resolved by procedures for access and correction, we will suggest these to you as possible solutions; and
- If we believe that your complaint may be capable of some other solution, we will suggest that solution to you, on a confidential and without prejudice basis in our response.
V11 | Jun 2023