INTRODUCTION
This Privacy Policy describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
This Privacy Policy applies in respect of the personal data of the following categories of people:
- Candidates;
- Temporary Workers;
- Clients;
- People whose data we receive;
- Website Users.
We are subject to applicable data protection legislation including but not limited to the General Data Protection Regulation and the UK GDPR. Please note that when we refer to the GDPR throughout the policy, we are referring to both the GDPR and UK GDPR.
It is important to point out that we may amend this Privacy Policy from time to time.
If you are dissatisfied with any aspect of our Privacy Policy, you may have legal rights and, where relevant, we have described these in this document.
HOW TO USE THIS PRIVACY POLICY
This Privacy Policy tells you a few things about how we use your personal data, and perhaps more importantly, what your rights are in relation to this (you have, for example, the right to ask us to delete or confirm the nature of information that we hold about you at any time, withdraw any consents that you may previously have given and/or lodge a complaint with our Data Protection Officer or a supervisory authority if you are not happy about something we have done).
CANDIDATES
Includes individual with whom The Pharmacy Agency has not had prior contact, but whom The Pharmacy Agency reasonably considers would be interested in, or might benefit from, The Pharmacy Agency’s services and being considered for any roles advertised or promoted by The Pharmacy Agency including permanent, part-time and temporary positions. Candidates also include applicants for such roles as well as people who have supplied a speculative CV to The Pharmacy Agency not in relation to a specific job and/or who have engaged with The Pharmacy Agency about services and/or roles advertised or promoted by The Pharmacy Agency.
WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT
So, you’re looking for a bit more insight into what data we collect about you? Here’s a more detailed look at the sorts of information that we will collect. The information described below is, of course, in addition to any personal data we are required by law to process in any given situation.
Depending on the relevant circumstances and applicable local laws and requirements, we will collect some or all of the information listed below to enable us to assess how we can assist you if we reasonably believe you might be interested in, or might benefit from our services, and to offer you employment opportunities which are tailored to your circumstances and your interests.
- Key Identification and contact information
- Name;
- Nationality / citizenship / place of birth;
- Contact details;
- A copy of your driving license and/or passport/identity card.
- Education and employment information
- Education details;
- Employment history;
- Current job title/specialism/industry sector;
- Skills and languages spoken;
- Referee details;
- Immigration status (whether you need a work permit);
- Available start date;
- Details about your previous and current remuneration and benefits;
- Details of hours of work available.
- Financial Information
- Financial information (if financial background checks are required for a role you have been shortlisted for);
- Bank details (for Temporary Workers).
- Special category information
- Details of racial or ethnic origin, sexual orientation, religious or other similar beliefs, and physical or mental health, including disability-related information, in ease case for diversity monitoring purposes;
- Physical or mental health, including disability-related information in order to enable us to make reasonable adjustments and health-related information when we need to use or offer occupational health to you in the context of certain types of roles;
- In certain circumstances, video recordings of Candidates attending or participating in meetings where individuals have consented to the recording;
- Religious Beliefs in order to calculate entitlement to annual leave.
- Criminal conviction data
- Details of any criminal convictions if this is required for a role that you are interested in applying for.
- Automatically collected information
- IP address;
- Usage information including the dates, times and frequency with which you access our services;
- User choices (e.g. marketing preferences).
- Information that others provide about you
- Extra information that your referees choose to tell us about you;
- Extra information that our Clients may tell us about you, or that we find from other third party sources such as job sites (which you have uploaded information onto, or is otherwise made available to us);
- Information about your interests and needs regarding future employment, both collected directly and inferred, for example from jobs viewed or articles read on our website or from links clicked on in emails from us; and
- Additional information that you choose to tell us
- Any other information that you may provide to us including, for instance, details of your childcare or carer arrangements (for example, when you authorise a deduction from pay for childcare vouchers or when you volunteer this information) and when corresponding with us via email or otherwise.
How do we collect your personal data?
We collect Candidate personal data in the following ways:
- Personal data that you, the Candidate, give to us;
- Personal data that we receive from other sources; and
- Personal data that we collect automatically.
Personal data you give to us
The Pharmacy Agency needs to know certain information about you in order to provide you with its services. This will enable us, amongst other things, to provide you with the best opportunities, and should save you time in not having to trawl through information about jobs and services that are not relevant to you.
There are numerous ways you can share your information with us. These may include:
- Entering your details on The Pharmacy Agency website or via an application form, as part of the registration process;
- Leaving a hard copy CV at a Pharmacy Agency recruitment event, job fair or office;
- Emailing your CV or other information to a Pharmacy Agency consultant or being interviewed by them;
- Applying for jobs through a job aggregator, which then redirects you to the Pharmacy Agency website;
The types of information that receive from you in this way include:
- Key identification and contact information;
- Education and employment information;
- Financial information;
- Special category information;
- Criminal conviction data, and
- Additional information that you choose to tell us,
as described in the section entitled “What Kind of Personal Information Do We Collect?” above.
Personal data we receive from other sources
We also receive personal data about Candidates from other sources. Depending on the relevant circumstances and applicable local laws and requirements, this will involve personal data received in the following situations:
- When we search for Candidates via third party sources, such as LinkedIn and other job sites, from which we obtain your personal information and/or when we carry out other pre-recruitment activities (please refer to the section entitled “Pre-recruitment activities” below);
- Your referees may disclose personal information about you;
- Our Clients, Suppliers, other Candidates and our colleagues within The Pharmacy Agency (e.g. in the context of them making a referral) may share personal information about you with us;
- If we receive your personal information from Facebook or Twitter, if you ‘like’ our Facebook page or ‘follow’ us on Twitter (or perform a similar interaction with us on any social media platform on which we have a presence);
- The types of information that we receive about you in this way include the information that others provide about you described in the section entitled “What Kind of Personal Information Do We Collect?” above.
Personal data we collect automatically
To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we will also collect your data automatically (e.g. via website tracking scripts such as cookies or pixels) or through you providing it to us. For more information, please refer to the context-specific section of this Privacy Policy that applies to Website Users.
The types of information that we collect about you in this way includes the “Automatically collected information” described in the section entitled “What Kind of Personal Information Do We Collect?” above.
How do we use your personal data?
We generally use Candidate data in five ways:
- Pre-recruitment Activities;
- Recruitment Activities;
- Marketing Activities;
- Equal Opportunities Monitoring; and
- To help us to establish, exercise or defend legal claims.
- In appropriate circumstances, we also use Candidate data for Profiling.
Pre-recruitment Activities
When conducting pre-recruitment activities, we use your data to work out whether you might be interested in, or might benefit from, our services, and to assess whether and how we might be able to assist you. If we think we can help, we will use your contact details to get in touch with you and find out if you are interested in our services (usually via email), subject to any applicable laws and requirements.
- For us to do this, we may:
- Collect your personal data;
- Store your details (and update them when necessary) on our database so that we can contact you about our services;
- Send you an email to inform you about our processing of your personal data and to direct you towards this Privacy Policy;
- Review your information to work out whether and how our services might help you; and
- Contact you about our services.
We’ve set out in more detail below various ways in which we will use and process your personal data for the purposes of determining whether our services would be beneficial to you, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive.
In most cases, we will use your personal data for the purposes below if we deem it necessary to do so for our legitimate interests. Article 6(1)(f) of the GDPR says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of you which require protection of personal data.”
We don’t think that any of the activities in relation to which we rely on the legitimate interests condition prejudice Candidates in any way. However, you do have the right to object to us processing your personal data on this basis. If you would like to know more about how to do so, please refer to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
---|---|---|
Collecting and processing data in the course of and to the extent necessary to work out whether you might be interested in or benefit from recruitment services, including by:
|
|
Legitimate interests, namely it is in our interests and your interests for us to assess whether you may be interested in or benefit from our recruitment services. |
Collecting and processing your data in the course of reviewing your information to ascertain how The Pharmacy Agency’s recruitment services may assist. |
|
Legitimate interests, namely it is in our interests and your interests for us to identify how we can help you with your job search. |
Collecting and processing your data in the course of communicating with you in relation to The Pharmacy Agency’s recruitment service. |
|
Legitimate interests, namely it is in our interests and your interests to contact and correspond with you as part of providing you with our recruitment services. |
Recruitment Activities
Obviously, our main area of work is recruitment – connecting the right Candidates with the right jobs. We’ve listed below various ways in which we will use and process your personal data for this purpose, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive.
In most cases, we will use your personal data for the purposes below if we deem it necessary to do so for our legitimate interests. Article 6(1)(f) of the GDPR says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of you which require protection of personal data.”
We don’t think that any of the activities in relation to which we rely on the legitimate interests condition prejudice Candidates in any way – in fact, they help us to offer you a more tailored, efficient service. However, you do have the right to object to us processing your personal data on this basis. If you would like to know more about how to do so, please refer to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.
We may in certain circumstances process your personal data for the purposes below if it is necessary for us to deliver a contractual service to you (or to fulfil a pre-contract request from you). Article 6(1)(b) of the GDPR says that we can process your data where it “is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.”
When we process your information for recruitment activities based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on such consent before the consent is withdrawn by referring to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
---|---|---|
Collecting and processing data in the course of and to the extent necessary to provide recruitment services to Candidates and facilitating the recruitment process including by:
|
|
We will rely on legitimate interests, namely it is in our interests and your interests for us to provide you with our recruitment services and for you to receive them in order for us to function as a profit-making business, and to help you and other Candidates to find employment To the extent that we record a video of you, we will ask for your consent before we start recording but will rely on legitimate interests in relation to our use of the data for training/monitoring and for monitoring compliance standards. |
Collecting and processing Candidates’ data in the course of carrying out:
To the extent that any data is published, this will be in aggregated/anonymised form only. |
|
Legitimate interests, namely it is in our interests to:
|
Collecting and processing Candidates’ data in the course of communicating with Candidates in relation to services-related issues and providing customer support by processing requests for support. |
|
We will rely on legitimate interests, namely it is in our interests and your interests to:
|
Collecting and processing Candidates’ data in the course of communicating with Candidates in relation to services-related issues and providing customer support by processing requests for support. |
|
We will rely on legitimate interests, namely it is in our interests and your interests to:
|
Verifying details that a Candidate has provided or to request information (such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate and in accordance with local laws). |
|
For criminal conviction data, we will obtain your explicit consent. For all other types of data:
|
In certain jurisdictions, using a web-based video identity verification process to verify a Candidate’s identity if we do not meet them in person and document this process. |
|
To the extent that this is carried out in your jurisdiction, we will ask for your consent before we start recording but rely on the legitimate interests condition (it is in our legitimate interests to maintain internal compliance standards) in relation to our use of the data that we capture to verify your identity. |
Collecting and processing Candidate data in the course of carrying out assessment and development activities such as psychometric evaluations or skills tests. |
|
Legitimate interests, namely it is in our interests and your interests for us to provide you with the services of assessment centres, competency management, reorganisation issues, management development, career development, and career transition. |
Marketing Activities
We will periodically send you information that we think you may find interesting, or to ask for your help with connecting other Candidates with jobs. In particular, we will use your data for the purposes listed below, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive.
We need your explicit opt-in consent for some aspects of these activities or soft-opt-in (which we explain further below).
Soft opt-in consent is a specific type of consent which applies where we have obtained your contact details from an occasion when you previously engaged with us (for example by informing one of our consultants that you are interested in our services, submitting a job application or CV, or registering a vacancy to be filled), and we are e-marketing or sending by text message other recruitment-related services of our own. Under ‘soft opt-in’ consent, we will take your consent as given unless or until you object or opt out (and we will remind you of your right to do this and provide you with the opportunity to opt-out, in each e-marketing message that we send to you). For most people, this is beneficial as it allows us to provide you with information that we think will be of interest to you and suggest other jobs to you alongside the specific one you applied for, significantly increasing the likelihood of us finding you a new position. We will use your personal data to send you e-marketing materials with your ‘soft opt-in’ consent if we deem that it is in our legitimate interests to do so.
For other types of e-marketing, we are required to obtain your explicit consent. If you are not happy about our approach to marketing, you have the right to opt out or withdraw your consent at any time and can find out more about how to do so by referring to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.
Nobody’s perfect, even though we try to be. We want to let you know that even if you have opted out from our marketing communications through our preference centre, it is possible that your details may be recaptured through public sources in an unconnected marketing campaign. We will try to make sure this doesn’t happen, but if it does, we’re sorry. We’d just ask that in those circumstances you opt out again.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
---|---|---|
Using Candidates’ data to carry out marketing activities to promote our services through digital channels including in relation to:
|
|
If we have obtained your contact details from an occasion when you previously engaged with us and we are e-marketing other recruitment-related services of our own, we will rely on soft opt-in consent if we consider that the legitimate interests legal basis applies, namely if we wish to reach out to you to tell you about our services and we consider that it would be in your interests to hear about similar services to those that you have already expressed an interest in. In all other circumstances, we will obtain your opt-in consent. |
Collection of data via cookies or tracking pixels and use of data to show users The Pharmacy Agency adverts and other content on other websites, for example, Facebook. |
|
We will obtain your consent via the Cookie Preferences link on our website. If you do not want us to use your data in this way, please turn off the “Advertising Cookies” option . Even where you have turned off advertising cookies, it is still possible that you may see a The Pharmacy Agency advert, but in this case, it won’t have been targeted at you personally, but rather at an anonymous audience. Please note that if you access The Pharmacy Agency’s’ services across multiple devices, you may need to adjust your settings (e.g. if you want to turn off advertising cookies) via the Cookie Preferences link on each of your devices. |
Lookalike targeting and other data driven marketing: providing lists of certain Candidates’ data to Facebook and Google to enable them to find an audience of people with similar characteristics or demographics to these Candidates (which will not include these Candidates) for The Pharmacy Agency’s’ marketing purposes. Facebook’s policy is to irreversibly hash such lists prior to use, match the hashed data against their own customers, generate the lookalike audience, then delete the original list and use it for no other purpose. We will not have access to the identity of anyone in the lookalike audience, unless they choose to click on the advertisements. |
|
We will obtain your opt-in consent for the collection of advertising identifiers via the Cookie Preferences link on our website. We will share these advertising identifiers with Facebook and Google in reliance on the legitimate interests legal basis, namely it is in our interests to identify and target advertisements to potential customers who share characteristics or demographics with our existing customers, unless we are required by local law to obtain your consent in which case we will obtain such consent via our consent management tool. |
Displaying excerpts from Candidates’ profiles for promotional purposes on The Pharmacy Agency’s’ website(s) to provide examples of success stories. |
|
We will always ask for your explicit consent before featuring you in this way on the website. |
Use of Candidates’ data in the course of making service and marketing communications via WhatsApp. |
|
We will ensure that you have opted-in (and therefore provided your consent) through one of a number of channels:
|
Compliance with a legal obligation
In some circumstances, we will use your personal data to comply with our legal obligations. Article 6(1)(c) of the GDPR says that we can process your data where it “is necessary for compliance with a legal obligation to which (we) are subject”.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
---|---|---|
Disclosing Candidates’ data to the recipients listed in the section entitled “Who do we share your personal data with”, including the transfer, storage and processing of such data outside of the UK/European Economic Area. |
The actual information used depends on the factual circumstances, but could include any of the following:
|
The disclosure is necessary (e.g. to potential employers) to conclude and perform any contracts that we have entered into with you (see section entitled Recruitment Activities above). The disclosure (e.g. to tax, audit, or other authorities) is necessary for the compliance with a legal obligation to which we are subject (see section entitled Compliance with a legal obligation above). The disclosure (e.g. to our professional advisers) is necessary to help us to establish, exercise or defend legal claims. We have obtained your consent (e.g. when we share your special category data with Clients (including to their internal or external auditors) where this is contractually required or the Client specifically requests such information to enable them to comply with their own employment processes. The disclosure is necessary for health and social care purposes (e.g. to an occupational health specialist to enable the provision of support during the recruitment process if a Candidate suffers from a health condition or disability). The disclosure is necessary for carrying out the obligations and exercising The Pharmacy Agency’s’ specific rights in the field of employment. The disclosure is necessary for the purposes of ‘legitimate interests’ pursued by us (as detailed in the tables above). |
Temporary Workers
Temporary Workers include someone who becomes employed or engaged by The Pharmacy Agency for the purposes of undertaking temporary work for a Client. If you are a Temporary Worker, we will also continue to process your personal data as a Candidate throughout the duration of your temporary work assignment and thereafter, in accordance with the terms of this Privacy Policy. Temp Relationship means our contractual relationship with Temporary Workers while they are employed or engaged directly by us.
What kind of personal information do we collect?
If we employ or engage you as a Temporary Worker directly, we will, depending on the relevant circumstances and applicable local laws and requirements, collect some or all of the information listed below (in addition to the data collected about Candidates) in order to ensure that our Temp Relationship runs smoothly and that we are able to comply with our contractual and other duties to each other, and to our Clients, as part of our Temp Relationship and our duties to third parties such as tax authorities and government agencies.
- Temporary worker information
- Staff number/other identifier;
- Location of your workplace at the Client;
- Details of any complaints, whether brought by or against you or in which you are or have been otherwise involved;
- Details of any leave you take or request during our Temp Relationship;
- Details of travel undertaken;
- Details of resident/work permit;
- Where applicable:
- Details of any grievance or disciplinary matters, whether brought by or against you or in which you are or have been otherwise involved; and
- Information about your performance in your role during our Temp Relationship, including details of any bonuses or promotions you receive performance assessments and other information that relates to your employment, your interaction with colleagues and employment-related issues that arise; and
- Special category information
- Details of any sickness absence including health-related information.
Please note that the above list of categories of personal data we collect is not exhaustive.
A number of elements of the items listed above are required to enable us to fulfil our contractual duties to you or to others. Other items may simply be needed to ensure that our Temp Relationship can run smoothly, or to run our business.
Depending on the type of personal data in question and the grounds on which we may be processing it, should you decline to provide us with such data, we may not be able to fulfil our contractual requirements or, in extreme cases, may not be able to continue with our Temp Relationship.
How do we collect your personal data?
If we employ or engage you as a Temporary Worker directly, we collect your data (in addition to the data already collected about Candidates) in the following ways:
- Personal data that you give to us; and
- Personal data that we receive from other sources.
Below are some more details about each of these methods.
Personal data you give to us
The Pharmacy Agency needs to know certain information about you in order to fulfil our obligations to you, to ensure that you are properly fulfilling your obligations to us, and to ensure that we are both fulfilling our obligations to others. This information will enable us to operate a usual Temp Relationship, along with all that entails.
There are numerous ways that you can share your information with us in addition to the information you share as a Candidate. Where appropriate and in accordance with any local laws and requirements, these may include:
- when you complete registration forms at the beginning of our Temp Relationship; or
- in meetings or communications with your consultant, our HR team or other colleagues.
The types of information that we receive from you in this way include:
- Temporary worker information; and
- Special category information,
as described in the section entitled “What Kind of Personal Information Do We Collect?” above.
Personal data we receive from other sources
We also receive personal data about you from other sources. Depending on the relevant circumstances and applicable local laws and requirements, these may include personal data received in the following situations:
- if you were referred to us through a recruitment agency or other work agencies, they may have shared personal information about you with us;
- information obtained about you from third party service providers who undertook background checks about you on our behalf at the start of our Temp Relationship;
- your colleagues may share personal information about you with us;
- medical professionals may (in appropriate and limited circumstances) share personal information about you with us;
- your pension and benefits providers may share relevant personal information about you with us; and
- other third parties like your local tax authority may share your personal data with us.
The types of information that we receive about you in this way include:
- Temporary worker information; and
- Special category information,
as described in the section entitled “What Kind of Personal Information Do We Collect?” above.
How do we use your personal data?
If we employ or engage you as a Temporary Worker directly, we use your data for the following purposes:
- To ensure the smooth running of our Temp Relationship, including all of the activities that need to be undertaken in a usual relationship of that type, such as:
- facilitating payroll and invoicing processes;
- determining the terms on which you work during your Temp Relationship;
- keeping a record of any promotions, salary rises or bonuses you are awarded; and
- Assessing your performance.
Temp Relationship Activities
We’ve listed below various ways in which we will use and process your personal data in connection with our Temp Relationship, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive.
In most cases, we will use your personal data for the purposes below if it is necessary for us to carry out our obligations under a contract that we have entered into with you or if we deem it necessary to do so for our legitimate interests.
Article 6(1)(b) of the GDPR says that we can process your data where it “is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.”
Article 6(1)(f) of the GDPR says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of you which require protection of personal data.”
We don’t think that any of the activities in relation to which we rely on the legitimate interests’ condition prejudice Temporary Workers in any way – in fact, they help us to offer you a more tailored, efficient service. However, you do have the right to object to us processing your personal data on this basis. If you would like to know more about how to do so, please refer to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.
When we process your information for recruitment activities based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on such consent before the consent is withdrawn. You can find out more about how to do so by referring to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.
Why and how we process your information | Types of personal data used | Legal basis relied upon |
---|---|---|
Disclosing Candidates’ data to the recipients listed in the section entitled “Who do we share your personal data with”, including the transfer, storage and processing of such data outside of the UK/European Economic Area. |
The actual information used depends on the factual circumstances, but could include any of the following:
|
The disclosure is necessary (e.g. to potential employers) to conclude and perform any contracts that we have entered into with you (see section entitled Recruitment Activities above). The disclosure (e.g. to tax, audit, or other authorities) is necessary for the compliance with a legal obligation to which we are subject (see section entitled Compliance with a legal obligation above). The disclosure (e.g. to our professional advisers) is necessary to help us to establish, exercise or defend legal claims. We have obtained your consent (e.g. when we share your special category data with Clients (including to their internal or external auditors) where this is contractually required or the Client specifically requests such information to enable them to comply with their own employment processes. The disclosure is necessary for health and social care purposes (e.g. to an occupational health specialist to enable the provision of support during the recruitment process if a Candidate suffers from a health condition or disability). The disclosure is necessary for carrying out the obligations and exercising The Pharmacy Agency’s’ specific rights in the field of employment. The disclosure is necessary for the purposes of ‘legitimate interests’ pursued by us (as detailed in the tables above). |
Sharing of data
If we employ or engage you directly as a Temporary Worker, we may share your personal data with a number of additional parties in order to ensure the smooth running of our Temp Relationship. For example, we may share your personal data with appropriate colleagues within The Pharmacy Agency, with a Client and, if appropriate, medical professionals such as your GP or an occupational health specialist (for instance, for the purpose of any work adjustment assessments if applicable).
We will generally rely on the same legal bases referred to in the section addressing Temp Relationship Activities above depending on the context.
If you would like to see a full list of who we will share your personal data with, please refer to the section entitled “Who do we share your personal data with” in the General Privacy Information section of this Privacy Policy.
Clients
Clients include our customers, clients, and others to whom The Pharmacy Agency provides services in the course of its business or whom The Pharmacy Agency reasonably considers would be interested in our services. In certain circumstances, The Pharmacy Agency provides services to individual employees who work for Client organisations.
Please note that in this context, The Pharmacy Agency requires Clients to communicate the relevant parts of this Privacy Policy (namely the section directed at Clients, Website Users) to their employees.
What kind of personal information do we collect?
The data we collect about Clients is actually very limited. We generally only need to have your contact details or the details of individual contacts at your organisation to enable us to ensure that we can reach out to you about our services, ensure our relationship runs smoothly and in certain circumstances, provide services to your employees.
We also hold information relating to your online engagement with Candidate profiles and other material published by The Pharmacy Agency, which we use to ensure that our marketing communications to you are relevant and timely. We may also hold extra information that someone in your organisation has chosen to tell us. In certain circumstances, such as when you engage with our Finance and Debt Recovery teams, our calls with you may be recorded, depending on the applicable local laws and requirements. If we need any additional personal data for any reason, we will let you know:
Key identification and contact information
About yourself or individual contacts at your organisation, including:
Names;
Job titles;
Telephone numbers;
Email addresses.
Automatically collected information
Information relating to your online engagement with Candidate profiles;
Information relating to your online engagement with other material published by The Pharmacy Agency;
IP address;
Extra Usage information that you choose to tell us; including the dates, times and frequency with which you access our services;
User choices (e.g. marketing preferences);
Email engagement with The Pharmacy Agency;
Location information (inferred from jobs, IP address, application history or system stored data).
Information that others provide about you
Extra information that our Candidates may tell us about you, or that we find from other third party sources; and
Additional information that you choose to tell us
Extra information that you or someone in your organisation has chosen to tell us, including when corresponding with us via email or otherwise.
Please note that the above list of categories of personal data we collect is not exhaustive.
To the extent that you access our website or click through any links in an email or text message from us, we will also collect certain data from you.
How do we collect your personal data?
We collect Client personal data in the following ways:
Personal data that we receive from you;
Personal data that we collect or receive from other sources; and
Personal data that we collect automatically.
Personal data that we receive directly from you
We both share the same goal – to make sure that you have the best staff for and at your organisation. We will receive data directly from you in two ways:
Where you contact us proactively, usually by phone or email; and/or
Where we contact you, either by phone or email, or through our consultants’ business development activities more generally.
The types of information that we receive from you in this way include:
Key identification and contact information; and
Additional information that you choose to tell us,
as described in the section entitled “What Kind of Personal Information Do We Collect?” above.
Personal data we receive from other sources
Where appropriate and in accordance with any local laws and requirements, we will seek more information about you or your colleagues from other sources generally by way of due diligence or other market intelligence:
From third party market research and by analysing online and offline media (which we will do ourselves or employ other organisations to do for us);
From reputable vendors of business-to-business data lists to the extent we are able to use such data from such sources in compliance with the GDPR;
From delegate lists at relevant events; and
From other limited sources and third parties, for example, from our Candidates to the extent that they provide us with your details to act as a referee for them or where they give feedback on a particular assignment.
The types of information that we receive about you in this way may include information that others provide about you as described in the section entitled “What Kind of Personal Information Do We Collect?” above.
Personal data we collect via our website or through links and emails
To the extent that you access our website or read or click on an email or text message from us, where appropriate and in accordance with any local laws and requirements, we will also collect your data automatically or through you providing it to us. For more information, please refer to the Context-Specific section of this Privacy Policy that applies to Website Users.
The types of information that we collect about you in this way include the automatically collected information as described in the section entitled “What Kind of Personal Information Do We Collect?” above.
How do we use your personal data?
We use Client information for:
Providing our services;
Marketing Activities; and
To help us to establish, exercise or defend legal claims.
Providing our services
Our services broadly consist of: (i) providing you with Candidates; (ii) consultancy and advisory services. We’ve listed below the various ways in which we use your data in order to facilitate this.
In most cases, we will use your personal data for the purposes below if we deem it necessary to do so for our legitimate interests.
Article 6(1)(f) of the GDPR says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of you which require protection of personal data.”
We don’t think that any of the activities in relation to which we rely on the legitimate interests’ condition prejudice Clients in any way. However, you do have the right to object to us processing your personal data on this basis. If you would like to know more about how to do so, please refer to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.