INTRODUCTION
Welcome to Expert Cura! At Expert Cura, we are committed to protecting the privacy and security of your personal data. This Privacy Policy describes how we collect and use personal data about our staff, employees, and self-employed carers (collectively referred to as “you” or “your”).
This we do in accordance with the UK’s Data Protection Act (“DPA”) and the EU’s General Data Protection Regulation (“GDPR”).
SCOPE
This policy covers both personal and special category personal data held in relation to you. It applies equally to personal data held in print and digital form.
All staff, employees, self-employed carers, and others processing personal data on our behalf must read it. A failure to comply may result in disciplinary action. All managerial and executive staff are responsible for ensuring that their subordinate staff and associated self-employed carers are complying with this policy and should implement appropriate practices, processes, controls, and training accordingly.
We may update this policy at any time, but if we do, we will provide you with an updated copy as soon as reasonably practical.
It is important that you read and retain this privacy policy, together with any other privacy policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are aware of how and why we are using such information and what your rights are under the DPA and GDPR.
THE DATA CONTROLLER
Expert Cura is a “data controller,” which means that we are responsible for deciding how we hold and use personal data about you.
DATA PROTECTION PRINCIPLES
Expert Cura is responsible for and must be able to demonstrate compliance with the data protection principles set out. All personal data must be:
1. Used lawfully, fairly, and in a transparent way;
2. Collected only for valid purposes that we have clearly explained to you;
3. Not used in any way that is incompatible with the purposes it was collected for;
4. Relevant to the purposes we have told you about and limited only to those purposes;
5. Accurate and kept up to date;
6. Kept only as long as necessary for the purposes we have told you about; and
7. Kept securely.
THE INFORMATION WE HOLD ABOUT YOU
Personal data means any information about an individual from which that person can be identified. It does not include anonymous data.
There are also “special categories” of more sensitive personal data that require a higher level of protection.
We will collect, store, and use the following categories of personal data:
● Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses;
● Date of birth;
● Gender;
● Marital status and dependents;
● Next of kin and emergency contact information;
● Bank account details, payroll records, and tax status information;
● Salary, fees, annual leave, pension, and benefits information (where applicable);
● Start date and, if different, the date of continuous engagement or employment;
● Location of work or engagement;
● Copy of driving licence (where applicable);
● Recruitment information, including right to work documentation, references, and CV or cover letter details;
● Work history, working hours, holidays, training records, and professional memberships;
● Personnel files and performance data, disciplinary/grievance matters, and time records;
● Information about use of our IT and communication systems;
● Records of any reportable death, injury, disease, or dangerous occurrence.
We may also collect, store, and use the following “special categories” of more sensitive personal data:
● Race or ethnicity;
● Health information, including medical conditions, accident, sickness records:
• Where a person leaves due to ill-health, injury, or disability;
• Details of any statutory parental leave, sick leave, or health-related absences;
• Where information is required for pension or insurance purposes.
HOW DO WE COLLECT PERSONAL DATA?
We collect personal data about you through the application or onboarding process, either directly from you or from employment agencies, background check providers, or other third parties such as former employers and credit reference agencies.
Additional data may be collected throughout your working relationship with us, whether you are employed or engaged as a self-employed carer.
HOW DO WE PROCESS THE INFORMATION COLLECTED ABOUT YOU?
We only use your personal data when the law allows us to. Most commonly, we use it:
1. To perform a contract with you;
2. To comply with legal obligations;
3. For our legitimate interests (or those of a third party) unless your rights override those interests.
Rarely, we may use your data:
1. To protect your or someone else’s vital interests;
2. When required for the public interest or official purposes.
SITUATIONS IN WHICH WE WILL PROCESS YOUR PERSONAL DATA
We process your personal data (as employee or self-employed carer) to:
● Make decisions about recruitment, engagement, or appointment;
● Pay fees or salaries and deduct tax, if applicable;
● Administer the contract or engagement terms;
● Manage performance and professional development;
● Conduct disciplinary or grievance procedures;
● Manage the end of the working relationship;
● Ensure legal and health & safety compliance;
● Prevent fraud or monitor IT systems;
● Maintain equal opportunities monitoring.
Multiple legal grounds for processing may apply.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Failure to provide necessary information may prevent us from fulfilling our obligations to you or complying with the law.
CHANGE OF PURPOSE OF PROCESSING
We will only use your personal data for the purposes we collected it for. If we need to use it for a different reason, we’ll notify you and explain the legal basis.
We may process your data without your knowledge or consent where required or permitted by law.
HOW DO WE PROCESS SENSITIVE PERSONAL DATA?
“Special categories” of sensitive data require further justification. We may process such data:
● With your explicit written consent;
● To comply with legal obligations or exercise rights in relation to your role;
● In the public interest (e.g., equal opportunity monitoring).
Less commonly, we may process this data for legal claims or where it has been made public.
OUR OBLIGATIONS
We use sensitive data from employees and self-employed carers to:
● Monitor sick or family-related leave for compliance with law;
● Ensure health and safety in the workplace;
● Provide adjustments and benefits;
● Monitor equal opportunity compliance.
INFORMATION ABOUT CRIMINAL CONVICTIONS
We may process information about criminal convictions:
● In legal claims;
● To protect vital interests;
● Where already public.
WHEN DO WE SHARE PERSONAL DATA?
We share your data with third parties where required by law, to manage the working relationship, or where there is a legitimate interest.
HOW SECURE IS MY INFORMATION WITH THIRD PARTIES?
All third-party providers must follow our security protocols. They are only allowed to process your data on our instructions and for specified purposes.
HOW LONG WILL YOU KEEP MY INFORMATION?
We retain your data only as long as necessary, in line with legal and regulatory obligations.
After your employment or engagement ends, we securely destroy your data unless anonymised for legitimate use.
See our Data Retention Policy for full details.
ACCURACY
Please keep us updated if your personal data changes during your working relationship with us.
DATA SUBJECT RIGHTS
You have the following rights:
● Right to information
● Right to rectification
● Right to object
● Right to erasure
● Right to data portability
● Right to withdraw consent
● Right to lodge a complaint
● Right not to be subject to automated decisions
Updating your data or withdrawing consent: You may update your data or withdraw consent by contacting us or updating your account.
Access Requests: You may request access to your data. We’ll respond within 30 days. If we can’t meet that, we’ll inform you. If access or corrections are denied, we’ll explain why (unless the law prevents us).
WHAT WE DO NOT DO
● We do not knowingly collect personal data from minors;
● We do not process special category data without consent unless lawfully justified;
● We do not engage in automated decision-making or profiling;
● We do not sell your personal data.
HELP AND COMPLAINTS
Questions, Contact us at: [email protected]
CHANGES
This is version 1.0 of the Privacy Policy, issued in January 2025 .