Privacy Policy

GDPR Policy
How long do we hold data:
Hoop will hold data on data subjects for up to 6 years, further consent will be sought if there’s no engagement with a data subject within this time frame. Hoop will hold data for 6 years for the purposes of:

• In the event of a contractual claim with any civil suit (Limitation Act 1980)
• HMRC purposes in order to show we have paid at least the national minimum wage rates if a breach of contract claim is brought forward.
• Pension auto enrolment records (Pension regulator – guidance for employers)
• Detailed VAT records
• Company accounts purposes
• Records kept in line with care inspectorate wales regulatory requirements for nursing

Right to erasure (i.e. right to be forgotten):
Individuals will have the right to have their personal data erased from Hoop records as per their request. The right to erasure is not an absolute right and will only apply in the following circumstances:

• the personal data is no longer necessary regarding the reason or purpose for which it was collected or otherwise processed;
• the individual withdraws his/her consent;
• the individual objects to the processing of their personal data and there are no overriding legitimate grounds for the processing;
• the individual objects to the processing of their personal data for direct marketing purposes;

There will be circumstances where Hoop are required to retain data and therefore not comply with a request to erase. These include:

• conduct regulations requirements i.e. keep records relating to work-seekers for at least a year after their creation or from the date they last provided work finding services
• payroll records
• right to work checks
• establishment, exercise or defence of legal claims
• any separate requirements to keep personal data i.e. regulatory body requirements   

Hoop will ensure we respond to all right to erasure request and, if we’re unable to erase the data completely, a full explanation as to why we’re retaining the data will be issued.
On receipt of a right to erasure request Hoop will clarify with the individual making this request if they simply want us not to contact them for a period of time or if they want us to permanently delete their record. We will advise that if we delete their entire record they may at some point in the future receive further communications from us if, for example, we find their details on a jobs board. All right to erasure requests will need to be made in writing.

Collection of Personal Data:
On seeking employment on a permanent basis or on a contract for services Hoop will request various personal data from candidates. The data we request, and the reasons why are:

• Name, address, date of birth, contact number, e-mail address, passport/birth certificate – information required to verify they have the right to work in the UK
• Criminal convictions – information required to assess suitability to work in social care, education or nursing industries
• DBS number – information required to ensure are able to work with vulnerable adults or children
• Next of Kin info – information required in case of an emergency (only requested if on a temporary assignment through Hoop)
• Details for 3 referee’s - information required to comply with national recruitment regulatory body (REC) and the care inspectorate wales
• Qualifications, professional registration – information required to verify required professional qualifications have been obtained

All the data is stored on our secure CRM system Vincere, once the information is stored on Vincere any hard copies are destroyed in line with company policy. The only exception is hard copies of data collected on behalf of any qualified nurses working through Hoop on temporary assignments. Hard copies of their data is stored in a lockable cabinet as well as an electronic copy on Vincere, this is in line with care inspectorate wales requirements.

Subject Access Request (SAR):
Any individual can make a subject access request. A SAR requires Hoop to supply any and all information held on an individual, in the case of Hoop this information could include returned references, CVs, any personal data i.e. name, number, address etc. On receipt of a SAR Hoop will inform the individual that there is no charge for requesting and supplying this information and all data will be supplied within one month from the date of asking. Any subject access request must be received in writing addressed to:
Donna Williams, Data Protection Officer, Hoop Recruitment, 14-18 City Road, Cardiff, CF24 3DL