Health Primary LTD, hereinafter referred to as “Us, We, Ours, Company, Employer, HPL” is a Occupational Health and Safety consultancy, and staff business registered in the United Kingdom, and operating website Health Primary LTD - Promoting Workplace Safety and Health

This document explains how we use the personal data we collect about you when you seek employment through or with us.

Information collected from you

That personal data includes (but is not limited to) your name, contact details, work history, employment preferences, references and the usual information contained on a CV. We will also ask for and keep copies of your CV and, where appropriate, proof of your eligibility to work in accordance with our legal obligations. For nationals of certain countries, we are able to perform digital identity checks via an online application hosted by a third-party service provider (who acts as our data processor), OCR Labs. Where we are able to perform these digital checks, we will ask your consent and provide you with more information in the consent request form. If you are directly engaged by us, we will also ask you to provide us with the information needed to ensure that you are paid appropriately (e.g. your bank details and National Insurance Number).

We may also ask if you need any reasonable adjustments to be made in connection with the recruitment process or application for a particular role.

Where we are legally required to do so, we may also ask for details of any criminal offences and seek an up-to-date criminal records check.

We will keep details of roles that you obtain through us and copies of correspondence sent to you and to any hirer in connection with such roles.

Device information

If you use our website or interact with emails that we send you, we also collect personal data from those interactions. We collect personal data such as your IP address and other data about your device, which we need to provide our online content to you.

Third parties

We also obtain personal data about you from third parties, including (but not limited to):

• Clients to whom we provided your CV and who provided feedback to us;
• Former employers and referees who provide references;
• The Disclosing and Barring Service, Disclosure Scotland, Access Northern Ireland, or overseas police forces, if we need to obtain details of criminal convictions;
• Credit reference agencies, where we need to check your financial standing;
• Publicly available sources such as social media sites and LinkedIn, to enhance the information we hold in order to assist you better with finding suitable roles.

Legal grounds for processing your personal data

Under the Data Protection Act 2018, we rely on the following legal grounds to process your personal data:

(a) Our legitimate interests – (including but not limited to):
• Provision of our operations in an efficient manner;
• Provision of our services to you;
• Optimizing the performance of our website and user experience;
• Provision of information about our services;
• Responding to requests and enquiries.

(b) Performing a contract – where in order to perform our obligations under a contract with you (or taking of steps to enter into the contract)

(c) Compliance with legal obligation – where we need to process your personal data in order to comply with a legal or regulatory obligation

(d) Consent – we will ask you for your consent to process your personal data. When we process your personal data based on your consent, you have the right to withdraw such consent at any time.

As a Job Seeker, we will use your personal data to:-

• provide you with our recruitment services,
• enable us to monitor equality and diversity,
• Provide you information with the aim of helping you find a suitable role (e.g. interviewing and salary advice)

Your personal data (including references), and where appropriate sensitive personal data may be provided to prospective employers, hirers and their appointed agents or processors, who will use it for processing your application, for personnel administration, additional screening checks and for inspecting our files (for audit purposes) where they are entitled to do so.

Sharing your personal data

We do not share your personal data with third parties, except where it is necessary to do so to provide you with our recruitment services and as set out in this Privacy Notice.

We may however share your personal data with third party service providers who assist us in carrying out our business activities. These third parties act as our data processors and are bound by strict contractual provisions to only process your personal data under our instructions and for the limited purposes we permit them. These third parties include (but are not limited to) our accountants; auditors; external legal advisors; external IT providers; support and hosting service providers; printing, advertising, marketing and market research and analysis service providers, technical engineers, data storage and cloud providers and all other outsourced service providers (such as communication providers) that assist us in the provision of our services.

We may also share your personal data with courts, tribunals, regulators and other governmental and public authorities (such as the police or tax authorities) to: (i) allow us to pursue legal remedies, (ii) to enforce our terms and conditions and protect our operations, (iii) to comply with legal process, (iv) to comply with applicable law, and (v) to respond to requests from public and governmental bodies.

Length of time that we retain your personal data 

We will keep your personal data (in accordance with our data retention and destruction policy) for as long as we need to in order to fulfil the purpose we collected it for. This may be for an ongoing purpose, e.g., we will retain your personal data for the duration of our business relationship with you and beyond, as we often support candidates with job placements over many years and potentially throughout their careers.

We keep some personal data for longer than others. To determine the appropriate retention period for personal data, we consider factors such as the purposes for which we process your personal data, including any legal, regulatory, accounting and reporting obligations, the nature and amount of personal data that we hold about you, and the potential risk of harm to you from unauthorised use or disclosure of your personal data.

However, you retain control over your personal data and may instruct us to stop looking for work for you at any time. When instructed by you, we will remove your records from our database unless we are required to keep it for legal reasons.

Data transfers

Your personal data is stored on servers in the European Economic Area(EEA) and it is transferred outside that area if you ask us to assist you in obtaining work outside the EEA, in which case it will be made available to the appropriate office of ours overseas and to prospective employers in the relevant territories.

We engage a third party, IMS to assist us with certain administrative functions in relation to the recruitment services we provide. IMS is based in India and act as our data processor. As such, your data may be transferred to India for processing by IMS. To ensure your personal data receives an adequate level of protection in India, we comply fully with The Digital Personal Data Protection Act, 2023 of India.

If your personal data is transferred to any other third party service providers outside the EEA, we will ensure that suitable safeguards are in place for example, by using approved agreements. We will provide you with details of such safeguards upon request.

Cookies

Cookies are text files placed on your computer to collect standard internet log and visitor behaviour information. This information is used to track visitor use of the Website, to compile statistical reports on Website activity and to help us make recommendations that are relevant to you.

We also use third party advertising companies to serve ads when you visit the Website. Those companies may use information about your visits to this and other websites in order to provide you with advertisements about other goods and services that may be of interest to you.

If you would like more information about this practice, including how to prevent it, please visit What Is an Opt-out Cookie? | All About Cookies

Access to your personal data, data portability, erasure and correction

You have the right to request a copy of the personal data that we hold about you. If you would like a copy of some or all of your personal information please email using the email address on our website.

We want to make sure that your personal data is accurate and up to date and are happy to remove or amend any information you think is inaccurate.

Changes to our Privacy Notice

We keep this document under regular review and we place any updates on this webpage. This statement was last updated on 2026.

How to contact us

Please contact us if you have any questions about this statement or information we hold about you by emailing us using the email address listed on our website.

You also have the right to raise any concerns about our processing of your personal data with the Office of the Information Commissioner (ICO), details of which are available at  Information Commissioner's Office