Recruitment and Employer Branding Privacy Policy
Health & Care Management Ltd (HCML) and companies that are part of HCML
Date of publication: 21/10/2026
We at Health & Care Management Ltd (HCML) manage employer branding and recruitment through our Career Site and recruitment platform. HCML also provides the recruitment platform infrastructure, administration and recruitment support to other companies that are part of HCML.
Those companies recruit for their own vacancies and remain responsible for assessing candidates and making recruitment decisions for their roles. Where you apply for a vacancy with another company that is part of HCML, that company will assess candidates and ultimately decide who to recruit, while HCML provides the recruitment platform and recruitment support.
For the purposes of this policy, references to “we”, “us” or “our” mean HCML and, where relevant to your application, the company to which you are applying.
This policy applies to all job applicants, whether they apply directly, through the Career Site, through a recruitment agency or by another recruitment route. It does not form part of any contract of employment or engagement.
2. Our commitment to your privacy
We are committed to handling personal information fairly, lawfully and transparently, protecting its privacy and security, and meeting our obligations under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
When we process personal information, we will:
· use it fairly, lawfully and transparently;
· collect it for specified, explicit and legitimate purposes;
· limit it to what is adequate, relevant and necessary;
· keep it accurate and, where necessary, up to date;
· keep it only for as long as necessary;
· protect it using appropriate technical and organisational measures;
· process it in accordance with your rights; and
· not sell your personal information.
Where personal information is transferred outside the UK, we will ensure that appropriate safeguards are in place in accordance with applicable data protection law.
3. How we collect your personal information
We normally collect information directly from you through our recruitment platform, application forms, interviews, assessments and communications with us. We may also receive information from:
· recruitment agencies;
· referees and former employers;
· professional or regulatory bodies;
· background-check providers; and
· the Disclosure and Barring Service (DBS), where appropriate.
Where HCML supports recruitment for another company that is part of HCML, your application will be collected through HCML’s recruitment platform and made accessible to authorised HCML colleagues and authorised individuals within the company to which you are applying.
4. Personal information we collect
Depending on the role and stage of recruitment, we may collect and process:
· your name, contact details and address;
· your CV, application form, employment history, qualifications and professional memberships;
· interview notes, assessment results and information about your skills and experience;
· information about your current or previous remuneration where lawful and relevant;
· references and information from former employers;
· proof of identity, immigration status and right-to-work information;
· information required for appropriate background, regulatory or DBS checks;
· information about reasonable adjustments required during recruitment;
· equal opportunities monitoring information, where you choose to provide it; and
· any other information you choose to provide in connection with your application.
5. Why we process your personal information
We process applicant information to:
· manage and progress your application;
· assess your skills, qualifications, experience and suitability for a role;
· communicate with you and arrange interviews or assessments;
· obtain references and undertake appropriate pre-employment checks;
· determine the terms on which employment may be offered;
· maintain appropriate recruitment records and respond to or defend legal claims;
· comply with legal, regulatory and safeguarding obligations; and
· improve the effectiveness and security of our recruitment processes.
Where you apply for a position with another company that is part of HCML, HCML processes your information to provide the recruitment infrastructure, administration and support. The company recruiting for the vacancy processes your information to assess your application and make the recruitment decision.
Our lawful bases may include taking steps at your request before entering into an employment contract, compliance with legal obligations and our legitimate interests in operating an effective, fair and secure recruitment process. Where the law requires it, we will seek your consent for a particular use of your information.
6. Special category and criminal offence information
We will only process special category information, such as health, disability, racial or ethnic origin, religious or philosophical beliefs, sexual orientation or trade union membership, where the law permits us to do so. This may include:
· making reasonable adjustments during recruitment;
· assessing working capacity where relevant and lawful;
· equal opportunities monitoring, normally using anonymised or aggregated information;
· meeting employment, social security, safeguarding or regulatory obligations; and
· establishing, exercising or defending legal claims.
Information about criminal convictions or offences will only be processed where authorised by law and where relevant to the role. Appropriate safeguards and policies will apply.
7. Who has access to your information
Access is limited to people who reasonably require the information for the relevant recruitment purpose. This may include authorised members of the HCML People team who provide recruitment platform administration and recruitment support, together with relevant hiring managers and authorised colleagues within the company to which you are applying.
For example, if you apply for a role with another company that is part of HCML, HCML may administer and support the process through the recruitment platform, while the recruiting company assesses candidates and makes the recruitment decision. Relevant authorised colleagues within HCML and the recruiting company may therefore access your application information for those respective purposes.
Your application will not automatically be made available to every company that is part of HCML. Access will be limited to the company recruiting for the role and those who need the information to administer, support or oversee the recruitment process.
We may also share relevant information with service providers and third parties, including:
· the provider of our applicant tracking and recruitment platform;
· recruitment agencies;
· providers carrying out references, background or DBS checks;
· IT, hosting and security service providers;
· occupational health or assessment providers where relevant;
· professional advisers, including lawyers and auditors; and
· the Home Office, HM Revenue & Customs, regulators, law-enforcement bodies or other public authorities where required or permitted by law.
We may also share information in connection with a proposed sale, acquisition, transfer or restructuring, subject to appropriate confidentiality and data-protection safeguards.
8. Data protection roles
The company advertising and recruiting for the vacancy is responsible for the recruitment decision relating to that role. HCML provides the recruitment platform infrastructure and recruitment support. The precise data-protection responsibilities of HCML and the recruiting company depend on how each party determines the purposes and means of the relevant processing.
HCML and each relevant company will maintain appropriate written arrangements covering access, security, retention, individual rights and responsibilities.
9. How long we keep applicant information
For unsuccessful applicants, we will normally retain application information for six months after the recruitment process has concluded, unless there is a legitimate and lawful reason to retain it for longer.
If we would like to retain your information to contact you about other suitable opportunities, we will explain this and, where required, ask whether you would like us to do so.
Where your application is successful, relevant recruitment information will become part of your employment record and will be retained in accordance with the retention requirements and privacy arrangements of your employing company.
10. Your rights
Subject to the conditions and exemptions in data protection law, you may have the right to:
· request access to your personal information;
· ask us to correct inaccurate or incomplete information;
· request deletion of your information;
· request restriction of processing;
· object to processing based on legitimate interests;
· request transfer of information in a portable format where applicable; and
· withdraw consent where processing is based on consent.
If you wish to exercise a right, or have questions or concerns about the use of your personal information, contact: DataProtection@hcml.co.uk
You also have the right to complain to the Information Commissioner’s Office (ICO). Further information is available at https://ico.org.uk/.
11. If you do not provide information
You are not required to provide all information requested. However, if information is necessary to assess your application, verify your identity or right to work, undertake required checks or prepare an employment offer, we may be unable to progress your application without it.
12. Automated decision-making
We do not currently make recruitment decisions based solely on automated processing or profiling. If this changes, we will provide appropriate information about the logic involved, the significance and likely consequences, and your applicable rights.
13. Changes to this policy
We may update this policy where our recruitment arrangements, legal obligations, technology or processing activities change. Material changes will be communicated through the Career Site or by another appropriate method.
