Privacy Policy

ProClinical Limited (company number 574 2788) is committed to protecting the privacy of our candidates, client and visitors of our website. We will ensure that the information you submit to us via our website or through any of our offices is only used for the purposes set out within this policy.

Company Name: ProClinical Limited

Contact Details:
Alana Duncan
ProClinical Limited
Eldon House
2-3 Eldon Street
London EC2M 7LS

Topic: Data protection
Date: 23.04.2018
Version: Version 1.2

At a glance:

This Policy explains when and why we collect personal information about people who enquire about roles we advertise. This policy also explains how we use that information, the conditions under which we may disclose information to others and how we keep personal information secure. At ProClinical Limited we are committed to protecting and respecting your privacy and are transparent in everything we do. We may change this Policy from time to time so please check this page to ensure that you are happy with any changes. By using our website, you are agreeing to be bound by this Policy. 

Who is the controller of the data that you provide to us? 
ProClinical Limited is registered as a data controller in the United Kingdom for the purposes of the Data Protection Act 1998. We ensure that the data you supply to us is processed fairly and lawfully. 

What information will we collect? 
We will collect data about you, both personal data (such as your name and contact details) and sensitive personal data (such as information in your CV or cover letter). Depending on the relevant circumstances and applicable local laws and requirements, we may collect some or all of the information listed below to enable us to offer you employment opportunities which are tailored to your circumstances and your interests. In some jurisdictions, we are restricted from processing some of the data outlined below. In such cases, we will not process the data in those jurisdictions.

  • Name
  • Age/date of birth
  • Sex/gender
  • Marital status; details
  • Education Details
  • Employment history
  • Emergency contacts and details of any dependents
  • Referee details
  • Immigration status / whether you need a work permit
  • Nationality/citizenship/place of birth
  • A copy of driving licence and/or passport/identity card
  • Financial information for credit checks
  • Social security number (or equivalent) and any other tax-related information
  • Diversity information including racial or ethnic origin, religious or other similar beliefs, and physical or mental health, including disability-related information
  • Details of any criminal convictions if required for role applying for
  • Details about current remuneration, pensions and benefits arrangements, information on your interests and needs regarding future employment, both collected directly and inferred, for example from jobs viewed or articles read on our website
  • Extra information you choose to tell us
  • Extra information that your referees tell us
  • Extra information that our clients may tell us, or that we find from other third part sources such as job sites
  • IP address
  • The dates, times and frequency with which you access our services, and CCTV footage if you attend our premises

How will we use your personal data? 
The personal data and sensitive personal data will be stored, processed, used and disclosed by us in the following ways:

  • To provide our recruitment services to you and to facilitate the recruitment process
  • To compare your data against vacancies which we deem suitable for you
  • To send your information to client(s) to apply for jobs or to assess your eligibility for jobs
  • To answer your questions and enquiries
  • We use third party providers to provide a recruiting CRM. We share your personal data with other third-party service providers that may assist our processes, administering and evaluating pre-employment screening and testing, and improving our recruiting practices. Our third-party suppliers include, but are not limited to, Bullhorn, Cube 19, Daxtra, Hubspot, RSM In Time, Keybridge Solutions and CloudCall
  • To carry out our obligations arising from any contract entered between you and us.
  • From time to time we may seek your consent to process, use or disclose your information for any other purpose not listed above.
  • We may also pass your information to, or allow access to such information to the ProClinical global group of companies, in order that they may access your personal information in the same way as we process, use and disclose your information as described above.
  • We may collect information about the use of our website including details of your visits such as pages viewed and the resources that you access. Such information includes traffic data, location data and other communication data.

The legal basis we rely upon to offer you these services are:

  • Legitimate interest
  • Consent
  • Legal obligation
  • Contractual obligation

Lawful Basis for Collecting Data

Annex A
a) The lawfulness of processing conditions for personal data are:

  1. Consent of the individual for one or more specific purposes.
  2. Processing is necessary for the performance of a contract with the individual or in order to take steps at the request of the individual to enter into a contract.
  3. Processing is necessary for compliance with a legal obligation that the controller is subject to.
  4. Processing is necessary to protect the vital interests of the individual or another person.
  5. Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller.
  6. Processing is necessary for the purposes of legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the individual which require protection of personal data, in particular where the individual is a child.

b) The lawfulness of processing conditions for sensitive personal data are:

  1. Explicit consent of the individual for one or more specified purposes, unless reliance on consent is prohibited by EU or Member State law.
  2. Processing is necessary for carrying out data controller’s obligations under employment, social security or social protection law, or a collective agreement, providing for appropriate safeguards for the fundamental rights and interests of the individual.
  3. Processing is necessary to protect the vital interests of the individual or another individual where the individual is physically or legally incapable of giving consent.
  4. In the course of its legitimate activities, processing is carried out with appropriate safeguards by a foundation, association or any other not-for-profit body, with a political, philosophical, religious or trade union aim and on condition that the processing relates only to members or former members (or those who have regular contact with it in connection with those purposes) and provided there is no disclosure to a third party without the consent of the individual.
  5. Processing relates to personal data which are manifestly made public by the individual.
  6. Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.
  7. Processing is necessary for reasons of substantial public interest on the basis of EU or Member State law which shall be proportionate to the aim pursued, respects the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and interests of the individual.
  8. Processing is necessary for the purposes of preventative or occupational medicine, for assessing the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of EU or Member State law or a contract with a health professional and subject to the necessary conditions and safeguards.
  9. Processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of healthcare and of medicinal products or medical devices, on the basis of EU or Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the individual, in particular professional secrecy.
  10. Processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard fundamental rights and interests of the individual.

Account and CV information
When you create a ProClinical account, or apply for a vacancy online, we store some information about you in your account area but it is protected by your password and can only be accessed by you. If you choose to upload a CV to our database, we rely on you to ensure that your details are kept up to date. You should update your CV at least every 6 months, particularly if your contact details have changed. 

Can information be amended, modified or be deleted? 
You may request that we confirm what information we hold about you at any time and may request us to modify, update or delete such information. We will require you to verify your identity and may ask for more information about your request. Where we are legally or contractually permitted to do so, we may refuse your request and will give you reasons for doing so. We will seek to act on your request in the timescale required by applicable data protection laws. 
If you wish to contact us with respect to the above matters please email us at dataprotection@proclinical.com 

How long will information be held for? 
We are required by law to hold your information for as long as it is necessary to comply with our statutory and contractual obligations and in accordance with our legitimate interests as a data controller. 

We will use reasonable endeavours to ensure that your Personal Data is maintained and up to date. However, you are under a duty to inform us of all changes to your Personal Data to assist with this and we will delete and update your Personal Data accordingly. 

How do we safeguard your personal data? 
Data security is of great importance to ProClinical Limited and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected via this website. 
This website takes every precaution to protect our users' information. When users submit sensitive information via the website, your information is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol. 
If password access is required for certain parts of our website, you are responsible for keeping this password secure and confidential. 
We endeavour to do our best to protect your personal Data. However, transmission of information over the internet is not entirely secure and is done at your own risk. We cannot ensure the security of your Data transmitted to the website. 

Keeping Children Safe 
We are concerned to protect the privacy of children aged 18 or under. If you are aged 18 or under, please get your parent/guardians permission beforehand whenever you provide us with personal information. If we learn that we have collected the personal information of a child under the relevant minimum age without parental consent, we will take steps to delete the information as soon as possible. Parents who believe that their child has submitted personal information to us and would like to have it deleted may contact us at dataprotection@proclinical.com 

How do we keep your personal data? 
We will hold your data for no longer than it is required and in accordance with our data retention and disposal policy which can be requested at dataprotection@proclinical.com. We will use reasonable endeavours to ensure that your Personal Data is maintained and up to date. We rely on you to inform us of all changes to your Personal Data to ensure that it is up to date and we will update or delete your Personal Data accordingly. 

How do we access/amend your personal data? 
The accuracy of your information is important to us. If you change email address, or if any of the other information we hold is inaccurate or out of date, please email us at: dataprotection@proclinical.com You have the right to ask for a copy of the information we hold about you. If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer who will investigate the matter. Our Data Protection Office is Alana Duncan and you can contact them at a.duncan@proclinical.com If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the Information Commissioner’s Office (ICO), Wycliffe House, Water House, Wilmslow SK9 5AF 

How do we store and transfer your personal data? 
Data, which we collect from you, may be stored and processed in and transferred to countries outside of the European Economic Area (EEA). We also share information with our group companies, some of which are located outside the EEA. These countries may not have data protection laws equivalent to those in force in the EEA. If we transfer data in this way, we will take steps with the aim of ensuring that your privacy rights continue to be protected as outlined in this privacy policy. You expressly agree to such transfers of Data. 

What are cookies and how are they used? 
Cookies are files that are recorded in temporary Internet Folders on your PC, they provide information regarding the computer used by a visitor. We may use cookies where appropriate to gather information about your computer to assist us in improving our website. 

We may gather information about your general internet use by using the cookie. Where used, these cookies are downloaded to your computer and stored on the computer's hard drive. Such information will not identify you personally. It is statistical data which does not identify any personal details whatsoever. 

You don’t have to accept cookies. Most browsers allow you to refuse cookies by activating the relevant setting, (please check the help menu of your browser for more details) however, selecting this setting may mean you are unable to access certain parts of our site. You can adjust the settings on your computer to decline any cookies if you wish. This can easily be done by activating the reject cookies setting on your computer. 

Further Detail on Cookies 
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies do lots of different jobs, like letting you navigate between pages efficiently remembering your preferences, and generally improve your web site experience. They can also help to ensure that adverts you see online are more relevant to you and your interests. 

We can split cookies into 4 main categories: 
Category 1: strictly necessary cookies
Category 2: performance cookies
Category 3: functionality cookies
Category 4: targeting cookies or advertising cookies


Category 1 – Strictly necessary cookies
These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies, services you have asked for, like registering for job alerts, can not be provided. 
Please be aware our site uses this type of cookie. 

Category 2 – Performance Cookies
These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get an error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works. 
By using our website and online services, you agree that we can place these types of cookies on your device. 

Category 3 – Functionality Cookies 
These cookies allow the website to remember choices you make (such as your user name and password) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymous and they can not track your browsing activity on other websites. 
By using our website and online services, you agree that we can place these types of cookies on your device. 

Category 4 – targeting cookies or advertising cookies 
These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisations. 
We do have links to other web sites and once you access another site through a link that we have provided it is the responsibility of that site to provide information as to how they use cookies on the respective site. 
You can find more information about cookies by visiting www.allaboutcookies.org or www.youronlinechoices.eu . Google also have a brief video which explains the use of cookies. 

Profiling 
We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively. We may also use your personal information to detect and reduce fraud and credit risk. 

Social media features
This website includes social media features, such as the Facebook Like button, and widgets, such as the Apply with LinkedIn button or interactive mini-programs that run on our sites. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them. 

Links to other websites 
Our website may contain links to other websites run by other organisations, these are out of our control and are not covered by this policy. This privacy policy applies only to our website, so we encourage you to read the privacy statements on the other websites you visit. We cannot be held responsible for the privacy policies and practices of other sites even if you access them using links from our website. 
In addition, if you linked to our website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third part site and recommend that you check the policy of that third party site. 

Log files 
We may collect demographic information, such as your postcode, age, gender, preferences, interests and favourites using log files. There is also information about your computer hardware and software that is automatically collected by us, including your IP address, browser type, domain names, access times and referring website addresses. This information is used by ProClinical to maintain quality of service to individuals and provide general statistics regarding use of the website. For these purposes, we do link this automatically-collected data to personal information such as name, email address, address, and phone number. 

Telephone recording and monitoring 
Telephone calls may be recorded by ProClinical for quality monitoring, training, compliance and security purposes. External calls made by employees may also be recorded by ProClinical. These recordings will only be used for the purposes specified in this policy.

We shall ensure that the use of these recordings is fair and that we comply with the requirements of the relevant legislation. This includes:

  • The Privacy and Electronic Communications Regulations 2003
  • The Regulation of Investigatory Powers Act 2000
  • The Telecommunications (Lawful Business Practice) (Interception of Communications Regulations) 2000
  • The Telecommunications (Data Protection and Privacy) Regulations 1999
  • The Data Protection Act 1998
  • The Human Rights Act 1998

Under normal circumstances a call will not be retrieved or monitored unless:

  • It is necessary to investigate a complaint
  • It is part of a management 'spot check' that customer service standards are being met
  • There is a threat to the health and safety of staff or visitors or for the prevention or detection of crime
  • It is necessary to check compliance with regulatory procedures

Consent – your individual rights 
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
  • he 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
  • The right to withdraw consent at any time.


Changes to this Privacy Policy 
ProClinical Limited reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the website. 

Complaints or Queries 
If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law you can complain to the Information Commissioner’s Office. Details can be found here: https://ico.org.uk/concerns 

Reviewed April 2018