Terms & conditions

Employee Privacy Notice in respect of Priory Group UK No 1 Limited and all its subsidiaries (the “Priory”)

What is a Privacy Notice?

We want to ensure you understand what information we collect about you, how we will use it and for what purpose. We are also required by data protection legislation to explain certain matters to you. This notice sets out and overrides anything previously communicated to you which is different. For the avoidance of doubt, this privacy notice does not form part of your contract of employment or engagement and we may update it at any time.

What information about you will we collect and use?

During your employment/engagement with the Priory, it is routine for us to collect, process and store personal information about you.

The personal information will include:

(a) personal information such as name, gender, date of birth, dependants, next of kin, job title, NHS number etc.;
(b) contact details such as addresses, telephone numbers, email addresses andemergency contact details, social media and other online identifiers;
(c) identification information such as photographs, passport and/or driving licencedetails, etc.;
(d) pay and financial information such as salary, benefits (including pensions),bank account details, card details, timesheets, National Insurance numbers,etc.;
(e) recruitment and professional information such as application forms, CVs, academic and training-related information, records/results of any preemployment checks (including credit and fraud checks), references, etc.;
(f) employment and management records such as disciplinary and grievance records, flexible working requests, performance records, appraisals and training records, holiday and attendance records, terms and conditions of
employment, etc.;
(g) right to work documentation such as proof of eligibility to work in the UK and obtaining and maintenance of any necessary professional consents or licences;
(h) information relating to access to our premises and/or use of our management and IT systems such as system ID, passwords, use of websites, emails sent or received, telephone calls, entry/exit records etc; and
(i) recordings of phone conversations.

We also handle the following special categories of sensitive personal information:

(a) information collected for equal opportunities monitoring such as gender, race, ethnic origin etc.;
(b) any trade union memberships you hold, religious beliefs, sexual orientation and political opinions,
(c) information about physical and mental health, including any medical conditions, biometric records, sickness absence records, occupational health records, medical reports, pre-employment medical screening tests, insurance claims, etc.; and
(d) information about criminal convictions and offences.

How and why will we use your personal information

In most cases, we will use your personal information to perform your contract, to comply with our legal obligations as your employer or where we need to in order to further the Priory’s legitimate business interests. We obtain information either directly from you or sometimes from third parties such as employment agencies, your former employers, immigration consultants, the Disclosure and Barring Service and other background check agencies. In rare cases, we may need to use your personal information to protect your (or someone else’s) best interest or if it is in the public interest for us to do so. The situations in which we will use your personal information include:

(a) recruitment and selection;
(b) salary, pensions, insurance and benefits administration (including pensions);
(c) HR, business management and planning purposes;
(d) carrying out appraisals, handling disciplinary and grievance matters, performance management, career planning, training, promotion, secondments, etc.;
(e) managing disability, sickness or other types of leave, e.g. maternity leave;
(f) to facilitate settling of expenses staff have incurred in the course of the business in accordance with their employment contracts;
(g) to facilitate communications between employees and members within the business;
(h) internal record keeping purposes to enable us to maintain an audit trail in respect of approvals of decisions, voting and any internal surveys;
(i) managing and safeguarding our management, IT and communications systems;
(j) security reasons;
(k) health and safety reasons;
(l) performing workforce analysis, project management and planning;
(m) training and quality purposes;
(n) legal reasons, e.g. complying with employment and health and safety obligations, ensuring you are legally entitled to work in the UK, establishing or defending legal claims, for record keeping purposes (including, without limitation to keep pension records or records for tax purposes), to defend our legal rights etc.
(o) to test our computer systems to improve our services to you i.e. when there are changes to the National Minimum Wage or Living Wage. If you do not wish for your information to be used for these purposes, you can let us know.

Some of the above grounds may overlap and there may be several grounds that justify our use of your information.

We process sensitive personal information for the following purposes:

(a) managing sickness absence, providing reasonable adjustments in the workplace and administering benefits; and
(b) for legal reasons, e.g. to comply with employment and health and safety obligations.
(c) We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
(d) We will use trade union membership information to pay trade union premiums, register the status of a protected employee and to comply with employment law obligations.

Change of purpose

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.

With whom might we share your information?

We may share personal data about you with other entities and their representatives in the Priory group.

We may also from time to time appoint a third party to process personal data on our behalf for the purposes outlined above. Currently we share personal data about with the following third parties:

(a) other group entities and their employees, representatives, strategic investor, their respective advisors;
(b) our group’s service providers such as our advisers, pensions and benefits providers, payroll provider, as well as those who provide and support our management, data storage, intranet, and other IT systems;
(c) occupational health/other benefits provider;
(d) HM Revenue & Customs and any other regulatory bodies which have authority over the Priory Group or its group
(e) our professional advisers, such as lawyers, auditors, immigration advisers etc.;
(f) such third parties as we reasonably consider necessary in order to prevent crime.

When we use third parties to process information on our behalf, we require them to commit to compliance with relevant data protection legislation. 

We may also share your personal data with other third parties where and to the extent that we are under a legal obligation to do so, e.g. HMRC, because of a Court Order, etc.

When might we transfer your information overseas?

Generally, your personal data will be kept within the UK and will never be transferred out of the European Economic Area (EEA). However, at times personal data stored on Priory servers may be temporarily transferred outside the UK into the EEA.


June 2020