1. Introduction

Sterling Practice Limited is committed to protecting the privacy and security of personal information relating to job applicants, employees, workers, contractors, consultants and former staff.

This Privacy Notice explains how we collect, use, store and protect personal data during recruitment and employment processes in accordance with the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018 and associated legislation.

2. Who We Are

Sterling Practice Limited
1 Colour House
7 Bell Yard Mews
London
SE1 3TJ

Email: info@sterlingpractice.co.uk
Telephone: 020 3473 3433

Sterling Practice Limited is the data controller for the personal data described in this notice.

3. Scope of this Notice

This notice applies to:
• Job applicants
• Employees
• Workers and contractors
• Agency staff
• Consultants
• Volunteers and placement students
• Former employees
• Sponsored migrant workers

This notice applies to recruitment activity undertaken directly by Sterling Practice and through third-party recruitment platforms and agents.

4. Information We Collect

During recruitment and employment, we may collect and process the following categories of personal data:

Recruitment Information

• Name, address and contact details
• CVs and application forms
• Employment history and qualifications
• Professional registrations (e.g. HCPC)
• Interview notes and assessment outcomes
• References
• Right to work documentation
• Immigration and visa information
• DBS and safeguarding checks
• Equality and diversity monitoring information

Employment Information

• Payroll and bank details
• National Insurance number
• Pension information
• Attendance and leave records
• Supervision and appraisal records
• Training and CPD records
• Occupational health information where applicable
• Disciplinary or grievance information

5. How We Collect Your Data

We may collect personal data from:

• Direct applications
• Recruitment agencies
• Jobs Boards
• Professional networking sites
• Referees
• Identity and right-to-work documents
• DBS providers
• Professional regulators
• Internal HR systems

6. Why We Use Your Information

We process personal data for the following purposes:

Recruitment

• Assessing suitability for employment
• Verifying qualifications and registrations
• Arranging interviews and recruitment assessments
• Carrying out safeguarding and right-to-work checks
• Managing recruitment records

Employment Administration

• Paying salaries and administering benefits
• Workforce management and planning
• Managing supervision, appraisal and training
• Meeting safeguarding and regulatory obligations
• Maintaining immigration sponsor compliance obligations

Legal and Regulatory Obligations

• Compliance with employment law
• Compliance with UK immigration requirements
• Compliance with safeguarding obligations
• Compliance with tax and pension obligations

7. Lawful Bases for Processing

We process personal data under one or more of the following lawful bases:

• Performance of a contract
• Compliance with legal obligations
• Legitimate business interests
• Employment and social protection law obligations
• Explicit consent where required

Special category data is processed only where permitted under Article 9 UK GDPR.

8. Sharing Your Information

We may share personal data with:

• Payroll providers
• Pension providers
• DBS services
• Professional regulators
• Occupational health providers
• Recruitment platforms including NHS Jobs
• Government authorities including UK Visas and Immigration where required by law
• NHS organisations, schools and local authorities where necessary for service delivery and safeguarding compliance

We do not sell personal data to third parties.

9. Data Retention

Recruitment records for unsuccessful applicants are generally retained for up to 12 months unless a longer retention period is required by law.
Employment records are retained in accordance with legal, regulatory and operational requirements.
Immigration and right-to-work documentation may be retained for the duration required under sponsor licence obligations.

10. International Recruitment and Immigration Compliance

As a licensed sponsor under the Skilled Worker route, Sterling Practice processes immigration-related information for sponsored workers in order to:

• Verify right to work status
• Meet sponsor licence compliance obligations
• Maintain required employment records
• Report relevant changes to UK Visas and Immigration

This processing is undertaken in accordance with UK immigration legislation and sponsor guidance.

11. Your Rights

Individuals may have the right to:

• Access personal data
• Request correction of inaccurate data
• Request erasure in certain circumstances
• Restrict or object to processing
• Request transfer of data where applicable
• Withdraw consent where processing is based on consent

Requests should be made in writing to:
info@sterlingpractice.co.uk

Individuals also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO).

12. Data Security

Sterling Practice takes appropriate technical and organisational measures to protect personal information from unauthorised access, loss, misuse or disclosure.
Access to recruitment and employment records is restricted to authorised personnel only.

13. Changes to this Notice

We may update this Privacy Notice from time to time to reflect legal, operational or regulatory changes.
The most current version will be available on our website.

14. Contact

If you have any questions regarding this Privacy Notice or how your information is handled, please contact:

Sterling Practice Limited

Email: hr@sterlingpractice.co.uk