Privacy Policy

Who we are

Opal Dental Locums is a specialist dental staffing agency supplying locum dental nurses, hygienists, receptionists and other dental professionals to practices across the UK. Opal Dental Locums is a trading name of Opal Recruitment Services Ltd, a company registered in England and Wales.

For the purposes of UK data protection law we are the data controller for the personal information described in this policy. That means we decide why and how it is used, and we are responsible for looking after it.

• Registered company name: Opal Recruitment Services Ltd
• Company number: 13977008
• Registered office: Sherwood House, 7 Gregory Boulevard, Nottingham, England, NG7 6LB
• ICO registration number: ZB331368
• Email: Bookings@odlocums.com
• Telephone: 0330 174 4770

We are regulated as an employment business under the Employment Agencies Act 1973 and the Conduct of Employment Agencies and Employment Businesses Regulations 2003, which affects some of the records we are required to keep.

Who this policy covers

This policy applies to four groups of people:

• Candidates and locums — dental nurses, hygienists, receptionists, dentists, practice managers and other professionals who register with us, apply for work, or are placed by us.
• Clients — the staff and representatives of dental practices and dental groups who book cover through us.
• Website visitors — anyone browsing opaldentallocums.com or submitting a form on it.
• Suppliers and contacts — people at the businesses we work with, and anyone who gets in touch with us.

Our staff and job applicants for internal roles are covered by a separate internal privacy notice, available on request.

Information we collect

If you are a candidate or locum

• Identity and contact details — name, date of birth, home address, email, phone number, emergency contact, and a photograph where you provide one.
• Right to work and identity evidence — passport, visa or share code, National Insurance number, and copies of the documents we are legally required to check.
• Professional credentials — GDC registration number and status, qualifications and certificates, CPD records, training records, indemnity or professional insurance details, and specialist skills such as implant, orthodontic or oral surgery nursing.
• Work history and suitability — CV, employment history, references and reference feedback, interview and registration notes, and any restrictions on where you are willing to work.
• Vetting information — DBS certificate details and disclosure outcomes, and confirmation of your immunisation and occupational health status where a practice or regulation requires it.
• Placement and payment information — availability, shifts worked, timesheets, hours, rates, bank account details, tax and payroll information, umbrella company details, and holiday and absence records.
• Feedback and conduct — client feedback about a placement, any complaints, incidents or performance concerns raised, and our notes about how these were handled.
• Communications — emails, messages, WhatsApp and SMS exchanges, and notes of calls with our consultants.

If you are a client

• Your name, job role, practice name, work email, phone number and practice address.
• Booking requests, including the type and quantity of cover needed, dates, times, break lengths and any special requirements.
• Purchase order, invoicing, billing and payment information.
• Contract terms, correspondence, feedback and complaint records.

If you visit our website

• Anything you type into a form on the site, including the booking form and contact form.
• Technical information such as IP address, browser type and version, device type, operating system, and approximate location derived from IP address.
• Usage information such as the pages you view, how long you spend on them, the links you click, and the site or advert that brought you to us.
• Cookie and similar tracking data — see our Cookie Policy.

Where we get it from

Most of the information we hold comes directly from you — when you register, apply, submit a form, email or call us. We also collect personal information from:

• Referees you nominate, and previous or current employers.
• The General Dental Council register, to verify registration status.
• The Disclosure and Barring Service and our approved DBS umbrella provider.
• Job boards, our recruitment platform and professional networks such as Indeed, Reed, CV-Library, Facebook and LinkedIn, where you have made your details available for recruitment purposes.
• Referrals from colleagues, existing locums or practices — if someone refers you, we will tell you who did when we first contact you.
• Clients, who give us feedback about placements.
• Public sources such as company websites and Companies House, mainly for client and supplier contacts.

Why we use it, and our legal basis

We must have a valid legal basis under the UK GDPR every time we use your personal information. Ours are set out below.

Where we rely on legitimate interests, we have considered whether our interests are overridden by your rights and freedoms, and concluded that they are not. You can ask us for details of that assessment, and you have the right to object — see Your rights.

Health and criminal records data

Some of the information we handle needs extra protection under data protection law.

Health and other special category information

We may hold information about your immunisation status (including hepatitis B), occupational health clearance, disabilities and any adjustments you need, sickness absence during a placement, and — where you choose to provide it for equal opportunities monitoring — information about your ethnicity, religion or sexual orientation.

We use this information because it is necessary for carrying out our obligations in the field of employment law and social security law (Article 9(2)(b) UK GDPR, together with Schedule 1 Part 1 of the Data Protection Act 2018), or because it is necessary for reasons of substantial public interest, including equality of opportunity monitoring and safeguarding. Where none of these apply, we ask for your explicit consent, which you can withdraw at any time.

Criminal offence information

Because our locums work in healthcare settings and may have contact with children and vulnerable adults, we process DBS disclosure information. We do this under Schedule 1 of the Data Protection Act 2018 for the purposes of employment and safeguarding.

We keep DBS certificate information to the minimum needed — usually the certificate number, date of issue, level of check and whether it is clear. We do not retain copies of certificates for longer than is necessary, and access is restricted to the compliance staff who need it. Our full policy on the handling of DBS information is available on request.

Who we share it with

We do not sell your personal information, and we do not share it for third-party marketing. We share it only where we need to, with:

• Dental practices and dental groups — candidate details are shared for the purpose of a specific placement or booking. We share what the practice needs to satisfy itself of your suitability and to comply with its own regulatory duties, and no more.
• Our recruitment and CRM platform provider, which hosts our candidate and vacancy records, including the jobs hub at hub.rocket-recruitment.co.uk.
• Payroll, accountancy and umbrella companies that process payments to locums and invoicing to clients.
• Vetting and screening providers, including our DBS umbrella body and any occupational health provider.
• Referees you have nominated.
• IT, hosting, email, telephony, e-signature and file storage providers that support our systems.
• Professional advisers — lawyers, auditors, insurers and insurance brokers.
• Regulators and public bodies — including HMRC, the General Dental Council, the Care Quality Commission, the Employment Agency Standards Inspectorate, the ICO, and the police or courts where we are legally required or permitted to disclose.
• A buyer or successor, if our business is sold, transferred or reorganised.

Where a third party acts as our processor, we have a written contract requiring them to keep your data secure, use it only on our instructions, and delete or return it when the contract ends. When we send your details to a practice, that practice becomes an independent controller for what it then does with them, and its own privacy notice will apply.

Sending data outside the UK

We are a UK business and our services are provided in the UK. Some of our suppliers — for example cloud hosting, email or analytics providers — may store or access data outside the UK.

Where that happens, we make sure appropriate safeguards are in place, which will be one of the following: the country is covered by UK adequacy regulations; the transfer is made under the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses; or another lawful transfer mechanism applies. You can ask us for a copy of the safeguards we rely on by emailing Bookings@odlocums.com.

How long we keep it

We keep personal information only for as long as we need it, then delete it securely or anonymise it. Our standard periods are:

Where a complaint, claim, incident or investigation is live, we keep the relevant records until it is resolved and any limitation period has expired.

How we protect it

We take appropriate technical and organisational measures to protect personal information against loss, misuse, unauthorised access and disclosure. These include access controls and role-based permissions, encryption in transit, password policies and multi-factor authentication on our key systems, staff training on data protection and confidentiality, written contracts with our suppliers, secure disposal of paper and electronic records, and procedures for detecting and responding to data breaches.

No system is completely secure. If a breach occurs that is likely to result in a risk to your rights and freedoms, we will report it to the Information Commissioner’s Office within 72 hours, and tell you directly where the risk is high.

Your rights

Under UK data protection law you have the right to:

• Be informed about how we use your data — this policy is part of that.
• Access a copy of the personal data we hold about you.
• Rectification — have inaccurate or incomplete data corrected.
• Erasure — ask us to delete your data, where we have no continuing lawful reason to keep it.
• Restrict processing — ask us to pause the use of your data while a concern is resolved.
• Data portability — receive data you gave us in a machine-readable format, where processing is based on consent or contract.
• Object to processing based on legitimate interests. You can object to direct marketing at any time and we will always stop.
• Withdraw consent at any time, where we relied on consent. This doesn’t affect anything we did before you withdrew it.

To exercise any of these rights, email Bookings@odlocums.com or call 0330 174 4770. We will respond within one month. If your request is complex we may extend that by up to two further months and will tell you if so. There is normally no charge. We may ask you to verify your identity before we release information.

If you ask us to delete your data while you are on an active assignment, or where we are legally required to keep records, we may not be able to delete everything — we will explain what we have kept and why.

Automated decisions

We do not make decisions that produce legal or similarly significant effects about you based solely on automated processing. Our systems may sort or shortlist candidates by criteria such as location, availability, role and qualifications, but a consultant always reviews and decides who is put forward for a booking.

Cookies

Our website uses cookies and similar technologies. Full details of what we use, why, and how to change your settings are in our Cookie Policy.

Changes to this policy

We review this policy regularly and may update it to reflect changes in our services, technology or the law. The version and date at the top of the page tell you when it last changed. If we make a significant change, we will tell candidates and clients directly. Please check back from time to time.

Contact us and complaints

If you have a question about this policy or how we handle your information, please get in touch. We would always prefer to resolve a concern with you directly.

Complaining to the regulator

You also have the right to complain to the Information Commissioner’s Office, the UK supervisory authority for data protection.

Website: ico.org.uk/make-a-complaint
Helpline: 0303 123 1113
Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF