Privacy Policy

Your Right to be Informed

mydentist is committed to protecting the privacy and security of your personal information.

This privacy notice sets out how mydentist collect and use personal information about you as part of our recruitment processes.

It applies to all candidates for current and potential opportunities across all areas of the business including those who have chosen to join our talent pool.

It is important that you read this notice carefully, and any other privacy notice we may provide on specific occasions, so that you understand how and why we are using your personal information.

The kind of personal information we hold about you

The legal entity Whitecross Dental Care Limited is responsible for deciding how we hold and use your personal information.

Personal data, or personal information, means any information about you from which you can be identified. It does not include personal information where your identity has been removed (such as any anonymous personal information).

We collect, store, and use the following categories of personal information about you:

  • the information you have provided to us in your curriculum vitae and covering letter
  • the information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history and qualifications
  • any information you provide to us during an interview.
  • Information we obtain from search tools and other information you make publicly available via social media

We also collect, store and use ‘special categories’ of more sensitive personal information:

  • Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions
  • Trade union memberships
  • Genetic information and biometric data
  • information about your health, including any medical condition, health and sickness records, and
  • information about criminal convictions and offences.

We are committed to complying with data protection laws. These laws say that the personal information we hold about you must be:

  • used lawfully, fairly and in a transparent way
  • collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
  • relevant to the purposes we have told you about and limited only to those purposes
  • accurate and kept up to date
  • kept only as long as necessary for the purposes we have told you about, and
  • kept securely.

How is your personal information collected?

We collect your personal information from the following sources:

  • You, the candidate;
  • Any relevant recruitment agency
  • Any relevant background check provider
  • Professional or Educational bodies
  • Disclosure and Barring Service in respect of criminal convictions, and
  • your named referees, from whom we typically collect the following categories of personal information:
    • confirmation of your previous employments
    • length of service

Where appropriate, we also collect your personal information from the following publicly accessible sources:

  • GDC Register and any similar publicly accessible register
  • Internet search tools designed to collate information from social media
  • National Performer List (in England)
  • Medical Performers List (in Wales)
  • NHS Board Dental List (in Scotland)
  • Dental List of the Health and Social Care Board and any similar publicly accessible lists
  • Social media websites such as LinkedIn, Twitter and Facebook but only where we have a legitimate interest to do so

Using your personal information

We need the categories of information in the list above primarily to allow us to perform our contract with you or take specific steps before entering into a contract and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below but we will only use the personal information we collect about you where the law allows us to, most commonly it will be for the following purposes:

  • To assess your skills, qualifications, and suitability for the work or role
  • carry out background and reference checks, where applicable
  • communicate with you about the recruitment process
  • keep records related to our hiring processes, and
  • to add you to our ongoing talent pool for future contact
  • comply with legal or regulatory requirements.

It is in our legitimate interests to decide whether to appoint you to the work or role since it would be beneficial to our business to do so.

We also need to process your personal information to decide whether to enter a contract with you such as a contract of employment or contract of engagement.

Having received your, as applicable:

  • CV
  • covering letter
  • enquiry or application form
  • social media profile that is publicly available

we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. The information will then be used to progress you through our process. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role or work.

If we decide to offer you the role or work, we will then:

  • take up references; and
  • carry out a Disclosure and Barring Service check
  • Any other pre-employment checks as and when required for the role you are applying

before confirming your appointment.

Using your sensitive personal information

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

We may also use more sensitive information:

  • In relation to levels of absence or sickness absence
  • About your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits.
  • About your race or national or ethnic origin, your gender, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
  • About criminal convictions, for example, as part of the recruitment process or when we complete DBS checks.
  • Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.
  • To ensure appropriate safeguards are taken to assure patient safety.
  • To pay trade union premiums, register the status of a protected employee and to comply with employment law obligations.

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We do not make decisions that have a significant impact on you based on automated decision making

Processing information about criminal convictions

We envisage that we will process information about criminal convictions.

We will collect information about your criminal convictions history if we would like to offer you the work or role (conditional on checks and any other conditions, such as references, being satisfactory).

In many cases, we are required to carry out criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role or work.

In particular:

  • we are legally required by the General Dental Council and other regulatory bodies to carry out criminal record checks for those carrying out certain roles or work
  • many of the roles or work are listed on the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975 (SI 1975/1023) and specified in the Police Act 1997 (Criminal Records) Regulations (SI 2002/233) so are eligible for a standard or enhanced checks from the Disclosure and Barring Service, and
  • many of the roles or work require a high degree of trust and integrity and so we would like to ask you to seek a basic disclosure of your criminal records history.

We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such personal information.

Sharing your personal information

From time to time will share your personal information with third parties including:

  • other entities in the mydentist group for the purposes of internal administration
  • Primary Care Support England (who are responsible for the delivery of primary care support services for NHS England) for the purposes of expediting any applications to the National Performer List.

We may also share your personal information with third parties where:

  • required by law
  • where it is necessary to administer the working relationship with you, and
  • we have another legitimate interest in doing so.

We require third parties to respect the security of your personal information and to treat it in accordance with the law.

All our third-party service providers and other entities in mydentist are required to take appropriate security measures to protect your personal information in line with our policies.

We do not allow our third-party service providers to use your personal information for their own purposes. We only permit them to process your personal information:

  • for specified purposes, and
  • in accordance with our instructions.

We will, where necessary, share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business.

We will also, where necessary, need to share your personal information with a regulator (such as the GDC) or to otherwise comply with the law.

Change of purpose

We will only use your personal information for the purposes for which we collect it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal information for an unrelated purpose, we will:

  • let you know, and
  • explain the legal basis which allows us to do so.

We may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Securing your personal information

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know.

They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from our Data Protection Officer (see below).

We have put in place extensive procedures to deal with any suspected security breach which involves personal information and we will let you and any applicable regulator know of a suspected breach where we are legally required to do so.

Keeping your personal information for as long as necessary

We will retain your personal information for a minimum period of two years after we have communicated to you our decision about whether to appoint you to the role or work. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way.

After this period, we will securely destroy your personal information in accordance with our Data Retention Policy unless we have decided to employ or engage you in which case we retain your information for a minimum period of six years.

To determine the appropriate retention period for personal information, we consider:

  • the amount, nature, and sensitivity of the personal information
  • the potential risk of harm from unauthorised use or disclosure of your personal information, and
  • the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Keeping your personal information up to date

It is important that the personal information we hold about you is accurate and current.

Please keep us informed if your personal information changes.

Exercising your rights of access, correction, erasure, and restriction

Under certain circumstances, by law you have the right to ask for:

  • access to your personal information (commonly known as a ‘subject access request’). This means you can receive a copy of the personal information we hold about you and check that we are lawfully processing it;
  • the correction of the personal information that we hold about you. This means you can correct any incomplete or inaccurate information we hold about you;
  • the erasure of your personal information. This means you can ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to stop processing personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground;
  • object to processing of your personal information. Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground you can object to the processing. You also have the right to object where we are processing your personal information for direct marketing purposes;
  • the restriction of processing of your personal information. This means you can ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it; and
  • the transfer of your personal information to another party.

If you want to do any of these things, please send us an e-mail: [email protected]

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection and use of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.

To withdraw your consent, please send us an e-mail [email protected] or use the unsubscribe function in any e-mail we send.

Social media

We love social media and chatting with you there, whether it be on Facebook, Twitter, Instagram or LinkedIn.

Don’t forget, however, that everybody can see everything you do there (those sites are public) so if you want us to keep your information private, please don’t put anything on these sites which you would like to keep private, whether now or in the future.

We will always try to respond to you using another medium such as e-mail or phone, where appropriate.

If you use certain social media features from within our website or connect with us on our social media webpages, the privacy policies of those companies will apply. Please read them carefully before you share your information with us and others as these companies may protect your information in different ways to us.

Failing to give us your personal information

If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

Data Protection Officer

Our Data Protection Officer oversees compliance with this privacy notice.

If you have any questions about this privacy notice or how we handle your personal information, please contact the Data Protection Officer. Details are as follows:

Intergrated Dental Holdings Limited
Europa House
Europa Trading Estate
Stoneclough Road
Kearsley, Manchester
M26 1GG

Telephone: 01204 799799

E-mail:  [email protected]

Complaints to the Information Commissioners Office

You can complain to the Information Commissioner’s Office (ICO) if you are unhappy with the way we have dealt with a request from you to exercise any of your rights or if you think we have not complied with our legal obligations. Whilst you do not have to do so, we would appreciate you making us aware of the issue and giving us an opportunity to respond and to address it before contacting the ICO.

Making a complaint will not affect any other legal rights or remedies that you have. More information can be found on the ICO website:

https://ico.org.uk/

and the Information Commissioner's Office can be contacted by post, phone, fax or email as follows:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Tel: 0303 123 1113 (local rate) or 01625 545 745 9 (national rate number); Fax: 01625 524 510

Email: [email protected]

Changes to this privacy notice

From time to time will need to update this privacy notice. If we do so, we will let you know.

Details of any changes will also be recorded in our change log below.

Date: July 2024

Nature of change: General updates to the privacy policy.

From time to time, we will also let you know in other ways about the processing of your personal information.

We are required under data protection laws to let you have the information contained in this privacy notice.

If you have any questions about this privacy notice, please email our Data Protection Officer (see above).