Staywell Occupational Health Ltd
Data Protection Privacy Notice (Pre-placement screening)
This notice explains what personal data (information) we will hold about you, how we collect it, and how we will use and may share information about you during the online booking process. We are required to notify you of this information, under data protection legislation. Please ensure that you read this notice (sometimes referred to as a ‘privacy notice’) and any other similar notice we may provide to you from time to time when we collect or process personal information about you.
Who collects the information
Staywell Occupational Health Ltd (‘Company’) is a ‘data controller’ and gathers and uses certain information about you.
Data protection principles
We will comply with the data protection principles when gathering and using personal information, as set out by the Faculty of Occupational Medicine.
About the information we collect and hold
The table set out below summarises the information we collect during the booking process of our pre-placement screening service, how and why we do so, how we use it and with whom it may be shared.
We seek to ensure that our information collection and processing is always proportionate. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.
Where information may be held
Information may be held at our offices, representatives and agents.
How long we keep your information
We keep the personal information that we obtain about you from management referrals for at least 6 years following the end of your employment from a specific company. Any management referrals relating to the Control of Substances Hazardous to Health (COSHH) may be kept for at least 40 years, in line with the HSE requirement that COSHH records are retained for at least this period of time.
Your rights to correct and access your information and to ask for it to be erased
Please contact our head office who can be contacted by email: admin@staywelloh.co.uk and by phone at 0800 4714941 if (in accordance with applicable law) you would like to request access to information that we hold relating to you or if you have any questions about this notice. You also have the right to ask for some but not all of the information we hold and process to be erased (the ‘right to be forgotten’) in certain circumstances.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
We hope that our Head Office can resolve any query or concern you raise about our use of your information. If not, contact the Information Commissioner at https://ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.
As a private occupational health provider, we process data under the following lawful bases outlined by GDPR:
Article 6 (1) (f): processing is necessary for the purposes of the legitimate interests pursued by the controller or a third party.
Article 9 (2) (h): processing is necessary for the purposes of preventative or occupational medicine, for the assessment of 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 or services.
| The information we collect | How we collect the information | Why we collect the information | How we use and may share the information |
| ‘Your name’ | From your employer and you | Article 6 (1) (f): processing is necessary for the purposes of the legitimate interests pursued by the controller or a third party. | This data is collected to identify you. |
| ‘Date of Birth’ | From your employer and you | Article 6 (1) (f): processing is necessary for the purposes of the legitimate interests pursued by the controller or a third party. | This acts as a further identifier and allows us to verify who you are if you submit a subject access request. |
| ‘Email Address’ | From your employer | Article 6 (1) (f): processing is necessary for the purposes of the legitimate interests pursued by the controller or a third party.
Article 9 (2) (h): processing is necessary for the purposes of preventative or occupational medicine, for the assessment of 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 or services. |
We will use this information to automatically send the health questionnaire to you. This email address may also be used if further follow up is required. |
| ‘Phone number’ | From you | Article 6 (1) (f): processing is necessary for the purposes of the legitimate interests pursued by the controller or a third party.
Article 9 (2) (h): processing is necessary for the purposes of preventative or occupational medicine, for the assessment of 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 or services. |
We will use this information to communicate with you if further follow up is required. |
| ‘Home Address’ | From your employer and you | Article 6 (1) (f): processing is necessary for the purposes of the legitimate interests pursued by the controller or a third party.
Article 9 (2) (h): processing is necessary for the purposes of preventative or occupational medicine, for the assessment of 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 or services. |
This is used to help identify the distance you will travel to work and if you are likely to experience any difficulty with this and also as a further identifier to allow us to verify your identity. |
| ‘Health information’ | From you | Article 6 (1) (f): processing is necessary for the purposes of the legitimate interests pursued by the controller or a third party.
Article 9 (2) (h): processing is necessary for the purposes of preventative or occupational medicine, for the assessment of 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 or services. |
This information is collected in order for us to identify if any changes would be recommended for you in the workplace. In the instance where we believe a health condition may benefit from workplace adjustments, a follow up telephone assessment will always be recommended, where you will have the chance to discuss these conditions with an OH nurse. From this, the OH nurse will decide if any adjustments are recommended. We will always seek your consent during this follow up assessment, before disclosing any health conditions to your employer. |
| ‘Previous employment’ | From you | Article 6 (1) (f): processing is necessary for the purposes of the legitimate interests pursued by the controller or a third party.
Article 9 (2) (h): processing is necessary for the purposes of preventative or occupational medicine, for the assessment of 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 or services. |
This information is used to establish any previous workplace environments and the similarity they pose against your proposed role. An example of when this may be used is as follows: ‘You declare a back issue and your new job requires a reasonable amount of heavy lifting. In your follow up assessment the OH nurse will discuss this with you and also see that your previous role involved a reasonable amount of lifting.’ This will help the OH nurse decide if any adjustments are recommended in your new workplace. |
Last updated 30/09/2019