Privacy Policy

1. Background

This Privacy Policy is made in compliance with the data protection obligations under the General Data Protection Regulation (GDPR) we make this policy on behalf of all companies within the TXM Group of Companies. For clarification for the purpose of this policy, TXM Group incorporates TXM Recruit Ltd, TXM Healthcare Ltd, TXM Technology Ltd, TXM Infrastructure Ltd, TXM Projects Ltd, TXM Manpower Solutions, 2XM Recruit Pty, 2XM Technology Pty, 2XM Projects Pty, 2XM Finance Pty, TXM Inc, Specialist Locum Network Ltd, TXM Teleconsult UK Ltd, Provide Medical Ltd and Provide Consulting Ltd, who may be referred to in this privacy policy as “we” or “us”.

We respect your concerns about privacy and data security. This policy applies to (1) our job candidates, (2) our

consultants, who are people we source or place on assignment with one of our clients, or individuals to whom we provide career transition services, (3) users of our websites, and (4) representatives of our clients.

This policy describes the types of personal information we collect, how we use the information, with whom we share it, and the rights of and choices available to individuals regarding our use of their information. It also describes the measures we take to protect the security of that information and how you can contact us about our privacy practices and to exercise your rights. Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements. This policy should be read in conjunction with our Cookies Policy.

2. Information We Collect

We collect personal information in various ways, directly from you and from some third-party sources such as through our website, through job boards and social media channels, at events, from telephone calls and emails, through job applications and in connection with in-person recruitment; and in connection with our interactions with clients and vendors.

 

We may collect the following types of personal information:

  • Contact information (such as name, postal address, email address and telephone number and any other data contained in your CV); Username and password when you register on our websites; information you provide about friends or other people you would like us to contact; Other information you may provide to us, such as in surveys or through the “Contact Us” feature on our websites.

  • In addition, if you are a job applicant and you apply for a position or create an account to apply for a position, we may collect the following types of personal information:

  • Employment and education history;

  • Language proficiencies and other work-related skills;

  • Eligibility to work documentation such as passport (details or copies) or equivalent and/or visa documentation;

  • Personal data such as date of birth and gender;

  • Bank payment details and tax-related information;

  • Disabilities and health-related information (if applicable to the job position);

  • Results of drug and alcohol tests, DBS and other applicable background checks;

  • Information provided by references; and

  • Any other information contained in your C.V. regarding your career interests

 

We may collect some basic contact information you provide to us about other individuals, such as information related to emergency contacts.

3. Information Collected by Automated Means

When you visit our websites, we may collect certain information by automated means, such as cookies and web server logs. The information we may collect in this manner includes IP address, unique device identifier, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our websites, dates and times of visits to our websites and other usage statistics. A “cookie” is a file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser.

Through these automated collection methods, we may obtain “clickstream data,” which is a log of the links and other content on which a visitor clicks while browsing a website.

As the visitor clicks through the website, a record of the action may be collected and stored. We link certain data elements we have collected through automated means, such as your browser information, with other information we have obtained about you to let us know, for example, whether you have opened an email we sent to you. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all the features of our websites. To the extent required by applicable law, we will obtain your consent before collecting personal information using cookies or similar automated means.

The providers of third-party apps, tools, widgets and plug-ins on our websites, such as social media sharing tools, also may use automated means to collect information regarding your interactions with these features. This information is collected directly by the providers of the features and is subject to the privacy policies or notices of these providers. Subject to applicable law, we are not responsible for these providers’ data protection practices.

 

4. Why and How We Use the Information We Collect

We use the information described above to perform the following activities in line with our legitimate interests:

  • Providing workforce solutions and connecting people to work;

  • Creating and managing online accounts;

  • Processing payments;

  • Managing our client and vendor relationships;

  • Sending promotional materials, alerts regarding available positions and other communications;

  • Communicating about, and administering participation in, special events, promotions, programs,

    offers, surveys, contests and market research;

  • Responding to individuals’ inquiries;

  • Operating, evaluating and improving our business (including developing, enhancing, analysing and

    improving our services; managing our communications; performing data analytics; and performing

    accounting, auditing and other internal functions);

  • Protecting against, identifying and seeking to prevent fraud and other unlawful activity, claims and

    other liabilities; and

  • Complying with and enforcing applicable legal requirements, relevant industry standards, contractual

    obligations and our policies.

  • In addition to the activities listed above, if you are a job candidate and you apply for a position or

    create an account to apply for a position, we use the information described in this Privacy Policy to:

  • Provide you with job opportunities and work;

  • Provide HR services to you, including administration of benefit programs, payroll, performance

    management and disciplinary actions;

  • Provide additional services to you, such as training and career transition services;

  • Assess your suitability as a job candidate and your associate qualifications for positions; and

  • Perform data analytics, such as (i) analysing our job candidate and associate base; (ii) assessing

    individual performance and capabilities, including scoring on work-related skills; (iii) identifying skill shortages; (iv) using information to match individuals and potential opportunities, and (v) analysing pipeline data (trends regarding hiring practices).

  • We also may use the information in other ways for which we provide specific notice at or prior to the time of collection.

We also may use the information in other ways for which we provide specific notice at or prior to the time of collection.

In addition, we use information collected through cookies, pixels, web server logs and other automated means for purposes such as (i) customising our users’ use of our websites; (ii) delivering content tailored to our users’ interests and the manner in which our users use our websites; and (iii) managing our websites and other aspects of our business. To the extent required by applicable law, we will obtain your consent before collecting information using cookies or similar automated means.

We also use third-party analytics services on our websites. The analytics providers that administer these services use technologies such as cookies, web server logs to help us analyse your use of our websites.


The information collected through these means (including IP address) may be disclosed to these analytics providers and other relevant third parties who use the information, for example, to evaluate use of the websites.

 

5. Information We Share

We do not disclose personal information we collect about you, except as described in this Privacy Policy or in

separate notices provided in connection with specific activities.

We share personal information with relevant third parties for business and contractual reasons, who perform services on our behalf based on our instructions. We do not authorise these third parties to use or disclose the information except as necessary to perform services on our behalf or to comply with legal requirements.

We may share your personal information (i) with our subsidiaries and affiliates; (ii) with our clients who may have job opportunities available or interest in placing our job candidates; and (iii) with others with whom we work, such as job placement consultants and subcontractors.

In addition, we may disclose information about you (i) if we are required to do so by law or legal process; (ii) to law enforcement authorities or other government officials based on a lawful disclosure request; and (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We also reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganisation, dissolution or liquidation).

Information collected through third-party plug-ins and widgets on the websites (such as information relating to your use of a social media sharing tool) is collected directly by the providers of the plug-ins and widgets. This information is subject to the privacy policies of the providers of the plug-ins and widgets; we are not responsible for those providers’ data protection practices.

6. Lawful Basis for Processing Personal Data

Other than where we have a legitimate interest in processing your data, we also have a lawful basis if any of the following conditions apply:

 

1. The data is used to fulfil any contractual obligations that exist between us and yourself; where we request personal data be provided to enter into, or meet the terms of any such contract, you will be required to provide the relevant personal data or we will not be able to deliver the goods or services you want. In such cases the lawful basis of us processing the personal data is that it is necessary for the performance of a contract.

 

2. We are required by law to process personal data for purposes relating to our legal obligations

 

Where we process special categories of personal data, we shall do so under on or more of the following additional lawful basis:

 

1. We have received your explicit consent. You may withdraw your consent for us to process your personal data for these purposes at any time; after a withdrawal of consent request is received, we may have to contact you to verify the request.

  1. It is necessary for carrying out obligations and exercising the specific rights of the organisation or of the data subject in the field of employment, social security or social protection law.

  2. it is necessary for preventive or occupational medicine, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems or pursuant to contract with a health professional

7. Data Retention

We will keep your personal data only for as long as required in order to achieve the purposes for which it was collected, in line with this policy.

The following criteria apply that determine the period for which we will store your personal data:

  • Until we are no longer required to do so in order to comply with any regulatory requirements or financial obligations that we are subject to.

  • Until we are no longer required to do so by any law it is subject to.

  • Until all purposes for which the data was originally gathered have become irrelevant or obsolete.

  • Until the goods and/or services we have provided are no longer in active use.

  • Until it has been requested that we no longer process the data and that it is erased.

 

8. Your Rights and Choices
There are several rights granted to you immediately upon providing us with your personal information; some of these are mentioned above. We’d like you to know that our companies take your rights as a Natural Person seriously and will always conduct ourselves in a way that is considerate of our responsibility to serve your legal rights to the extent provided by the law of your jurisdiction.

The Right of Access grants you the right to confirm whether your personal data is being processed, and to be provided with relevant details of what those processing operations are and what personal data of yours is being processed.

If you would like access to the personal data we have about you, we ask that you contact us by using our details below (section 13.)

The Right to Rectification grants you the right that if you notice that the data we have about you is inaccurate or incomplete, you may request we rectify the mistake. We will make every effort to respond to requests of this type immediately.

The Right to Erasure grants you the right to instruct us to erase personal data concerning yourself that we are processing. In some cases, where there is a remaining relevant or legal reason, we may opt to restrict the amount of processing being conducted to what is absolute necessary rather than erase it.

The Right to Objection is a basic freedom all democracies enjoy. If you wish to object to the way we use, or have used, your personal data you may do so freely.

We will always try to maintain the highest standards and encourage the confidence our clients have in us as an organisation. In order that we can achieve this we do request that any complaints be first brought to our attention so we can properly investigate matters; if however you would like to complain about us to a supervisory authority you may do so by contacting the Information Commissioners Office.

8. International Transfers of Your Data
As a part of its standard business practices we may be required to transfer your personal data to countries outside the European Union (EU), or to organisations who intend to transfer the data outside the EU. Where such transfers of data take place, we shall ensure that at least one of the following control measures are in place:

  1. The data transfer is necessary in order to fulfil a contract between us and you, or to satisfy pre- contractual requirements that have been requested by you.

  2. We have gathered your specific consent before the transfer takes place, after making you aware of any risks involved.

  3. Contracts are in place between the parties involved that ensure the recipient organisation has a suitable standard of data protection in place

 

9. How We Protect Personal Information

We maintain administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use.

10. Links to Third-Party Websites, Apps and Services

For your convenience and information, our websites may provide links to third- party sites, apps and services that may be operated by companies not affiliated with us. These companies may have their own privacy notices or policies, which we strongly suggest you review. We are not responsible for the data protection practices of any third-party site or service.

 

11. Amendments

This Privacy Policy may be updated periodically to reflect changes in our data protection practices. For significant changes, we will notify you by posting a prominent notice on our websites indicating at the top of the policy when it was most recently updated.

12. Data Protection Officer

We have appointed Ametros Group as our official Data Protection Officer (DPO), an outsourced consultancy firm that provides practitioner led GDPR advisory services. Contact details for our DPO are as follows:
Ametros Group Ltd
Lakeside Offices

Thorn Business Park
Hereford
HR2 6JT
Email: dpo@ametrosgroup.com Tel: 0330 223 2246

 

13. ContactUs

If you have any questions about this Privacy Policy, if you would like to exercise your rights, or update the information we have about you or your preferences, please contact us directly at gdpr@txmgroup.com. We shall endeavour to respond to emails sent to this address within two working days.

Should you wish to discuss a complaint, please feel free to contact us using the details provided above. All complaints will be treated in a confidential manner.