Anti-slavery Policy

Privacy Policy


General Data Protection Regulations (GDPR)

This notice (together with our terms of and any other documents referred to on it) sets out the basis on which any personal data the Company collects from you, or that you provide to us, will be processed.

GDPR Principles

The Company complies with the principles of GDPR. The six overall guiding principles are:

  • Lawfulness, transparency and fairness
  • Purpose Limitation
  • Data Minimisation
  • Accuracy
  • Storage limitation
  • Confidentiality and integrity

Your privacy and security is of the utmost importance to us. We will always follow these principles and ask you how you would like us (or our partners) to communicate with you. The Information Commissioner regulates compliance with GDPR.

Who is the Data Controller?

When you provide personal information to CRG or any CRG Subsidiaries, the data controller is the Company.

If another company is the data controller, this will be made clear when you provide your personal information.

Lawful Processing

The Company has a lawful basis for processing your personal data under the provisions of GDPR 6 (1) a, b, and c.  These provisions allow for processing your personal data based on your consent and/or that your data is necessary for the performance of a contract (i.e. employment or temporary/locum work) or to take steps to entering into a contract and/or for the legal obligation we have in relation to providing you with suitable employment or providing our clients with a suitable employee.

Information we may collect from you

We may collect and process the following data about you:

  • Information that you provide by filling in forms on this site. This includes information provided at the time of registering to use our site, subscribing to our service, posting material or requesting further services. We may also ask you for information when you enter a competition or promotion and when you report a problem with our site.
  • If you contact us, we may keep a record of that correspondence.
  • We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
  • Details relating to our recruitment services and the supply of your services to our clients.
  • Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.

How We Use Personal Data

The data controller will use your information together with other information for administration (including providing any goods, services or information you have requested), marketing, customer services.


By returning or submitting a form with your personal information to us, you consent to the Company:

  • Processing your sensitive personal data for the above purposes;
  • Transferring your information to countries which do not provide the same level of data protection as the UK if necessary for the above purposes and where you have indicated a preference for overseas work. If we do make such a transfer, we will put a contract in place to ensure your information is protected.

When you give us your personal information, we will give you the opportunity to opt out of receiving communications by post or telephone from the Company but remember that this will preclude you from receiving any of our special offers or promotions in future. We will also give you the opportunity to opt in to receive such information by e-mail or SMS and will only send it to you if you do opt in or if you are an existing client and the information relates to similar goods or services to those which you have previously requested from us.

You may also exercise your right to opt out of the use of your information for marketing purposes at any time by contacting us using the methods explained at the end of this notice.

Your personal information will be disclosed where we are obliged or permitted by law to do so. If you post or send offensive or objectionable content anywhere on or to any of our websites or otherwise engage in any disruptive behaviour on any of our websites, we can use whatever information that is available to us about you to stop such behaviour. This may involve informing relevant third parties such as your employer and law enforcement agencies about the content and your behaviour.

IP Addresses and Cookies

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

When you visit one of our websites, we may send you a cookie. A cookie is a small file that can be placed on your computer’s hard disk for record keeping purposes and we may use them to do a number of things.

Cookies help us to recognise you when you next visit one of our websites and note the content displayed to you. This allows us to tailor the content we provide to your preferences. We may use the services of third party ad servers for this purpose.

Cookies may be used to compile anonymous statistics related to the take up or use of services, or to patterns of browsing. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our site and to deliver a better and more personalised service. They enable us:

  • To estimate our audience size and usage pattern.
  • To store information about your preferences, and so allow us to customise our site according to your individual interests.
  • To speed up your searches.
  • To recognise you when you return to our site.

A third party collects such data on our behalf to measure web site performance. Information collected is aggregated for reporting purposes. No personally identifiable information is collected by this service. The use of this service assists us in measuring and improving the structure and ease of use of our web sites.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site.

Your Rights

Under GDPR, there are new rights for individuals and existing rights have been strengthen, are very clear and can be found here:

You have the right to ask us not to process your personal data for marketing purposes. We will ask you to opt in (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You have the right to opt out of receiving marketing communication at any time.

Please note the Company’s site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  You are advised to check these policies before you submit any personal data to these websites

Information Requests

Under GDPR, individuals have the right to confirm if their data is being processed and the right to access their personal data and other supplementary information. Individuals must be able to verify their identity through reasonable means. There is no charge for this information under the regulation but a fee can be charged if the request is manifestly unfounded, excessive or repetitive or if at the extreme of these reasons, this request can be refused. This fee is based on the administrative cost of providing the information.  Under such a subject request we have to provide this information within 30 days but where information is complex or numerous this period can be extended by a further 60 days by informing you of this within the initial month. If a request is refused for the reasons above and explanation must be given and you have the right to complain to the supervisory authority

Rectification and Erasure

You have a right to have any inaccurate or incomplete data rectified. Similar to the access requests the Company will respond within 30 days and this can be extended by an extra 60 days in complex cases. This can also be refused but a reason must be given and you have the right to complaint to a supervisory authority. You also have the right to be forgotten, however this request can be refused where data is required to comply with legal obligations, for public health purposes or for the defence or exercise of legal claims. More information can be found here.

Third parties where your personal data has been disclosed also have to be informed of this erasure.

When you give us information about another person, you confirm that they have appointed you to act for them, to consent to the processing of their personal data, including sensitive personal data and to the transfer of their information abroad and to receive on their behalf any data protection notices.

Disclosure of your Information

  • We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
    We may disclose your personal information to third parties:
  • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
  • If the Company or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Notification of changes

From time to time, we may make changes to this Privacy Policy. This may be in relation to changes in the law, best practice or changes in our services.

How to contact us

Telephone: +44 (0) 20 7451 1451

HCL Workforce,
33 Soho Square

General information about data protection may be found on the Information Commissioner’s website.

Anti-Slavery Policy


This statement sets out Healthcare Locums (HCL) Ltd’s commitment to continually improving its practices to combat slavery and human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1st January 2016 to 31st December 2016.

As a provider of health and social care workforce solutions, we and our supply chain recognise that we have a responsibility to take a robust approach to slavery and human trafficking.

HCL Group structure and supply chains

We are a provider of recruitment services in the health and social care sector. We are the parent company of the Healthcare Locums Ltd Group (Group). The Group has over 500 employees worldwide and operates in the UK and Australia. Under The Modern Slavery Act 2015 the Group is required to provide this statement. The Group operates with the following business units:

  • Healthcare Locums Ltd (Parent company)
  • HCL Healthcare Ltd
  • HCL Doctors Ltd
  • HCL Nursing Ltd
  • HCL Social Care Ltd
  • HCL Permanent Ltd
  • HCL Managed Services Ltd
  • JCJ Locums Ltd
  • HCA International

Our supply chains include:

  • Temporary workers for the health and social care sector
  • Subcontracting suppliers of temporary workers for the health and social care sector
  • Learning and development/training
  • Laboratory Services
  • Occupational Health Services
  • Employment Background Checking Services
  • Stationers
  • Print Solution
  • Cleaning & Janitorial
  • Office furniture
  • Confidential waste supplier
  • Couriers & Postal Services
  • Utilities
  • Hotel/Accommodation
  • Travel

All of which are based in the UK.

Our supply chain outside of the UK includes:

  • Supply of (temporary) workers
  • Outsource providers

Some of which are based in North America, India and Europe.

The following is the process by which the company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:

  • The Group confirms that prior to any supplier being included on our supply chain they have policies and procedures that are congruent with our intention to combat slavery and human trafficking.
  • If suppliers do not have their own Modern Slavery policy, we will make our policy available and obtain assurances of the supplier’s commitment to follow prior to supply commencing.
  • If, after supply commences, we believe there is an actual breach or risk of breach , we will investigate this following our Complaints & Serious Untoward Incident Policy.


Responsibility for the HCL Group’s anti-slavery initiatives is as follows:

Policies – In addition to the Modern Slavery policy, there are several other Group policies that are used to support the intention of combating slavery and human trafficking and identifying risk. These policies are:

Recruitment & Selection policy

All internal and temporary workers are screened and vetted in line with best practice and relevant legislation to ensure: Authentic and legal documentation, right to work in the UK and identity, as well as assessing for any concerning behaviours/fears/pay or banking irregularities or health issues that may require further review in line with combating Modern Slavery.

Whistleblowing policy

We encourage all of our workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the HCL Group. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The HCL Group’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns may raise them with the individuals identified within the policy or they can contact Public Concern at Work’s confidential helpline.

Employee Handbook – Code of Conduct

The HCL Group’s code makes clear to employees the actions and behaviour expected of them when representing the HCL Group. The HCL Group strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.

Procurement & Authorisation Levels policy and procedure

The HCL Group is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. This includes the supplier confirming their business process conform to the Modern Slavery Act (2015). The HCL Group works with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. If there are breaches found in the supplier’s adherence to the Modern Slavery Act, or Code of Conduct expected, this will require improvement reviews and may result in the termination of the business relationship if the breaches cannot be resolved. We seek to confirm adherence to combating slavery and human trafficking in our supply chain by requesting this assurance on our supplier questionnaire prior to commencing supply.

Safeguarding of Children policy

Sets out the expectation of temporary workers in identifying, recording and reporting actual or potential safeguarding risk to children. This includes the identification of actual or potential risk of slavery and human trafficking. Internal staff use this policy when there is an allegation raised about safeguarding a child about a temporary worker, or a temporary worker makes contact to raise a concern occurring within their work placement.

Safeguarding of Vulnerable Adults policy

Sets out the expectation of temporary workers in identifying, recording and reporting actual or potential safeguarding risk to vulnerable adults. This includes the identification of actual or potential risk of slavery and human trafficking. Internal staff use this policy when there is an allegation raised about safeguarding an adult, raised about a temporary worker, or a temporary worker makes contact to raise a concern occurring within their work placement.

Diversity & Inclusion policy

Sets out the expectations we have of all our employees, temporary workers and suppliers to embrace diversity and inclusion. In cases where we believe this is not the case we will be mindful of considering whether actual or potential slavery and human trafficking may be a contributing factor. Should there be any cause for concern the policy identifies possible courses of action.

Health & Safety (including Lone Worker) policy

In accordance with its duty under Section 2(3) of the Health and Safety at Work Act 1974 and in fulfilling its obligations to both staff and other persons who may be affected by its activities, HCL group aims to achieve a working environment which is free of work related accidents and ill-health and to this end we will pursue continuing improvements from year to year. This includes any actual or potential risk to health & safety identified with slavery and human trafficking assessments and investigations.

Data Protection policy

The Group is registered with the Information Commissioner’s Office (ICO). This policy ensures the Group adheres to its data protection obligations under the DPA and appropriate action to take where a breach or suspected breach has taken place. The aim of the policy, in line with its DPA obligations, is to ensure all information including sensitive information is processed lawfully, subject’s data is held with their knowledge, consent and for a particular purpose. Subjects are also entitled to request their information by making a subject access request.

Corporate Social Responsibility Policy

Sets out to ensure we behave in a thoughtful and meaningful way in all of our work related transactions. Being mindful of the actual or potential risk of slavery and human trafficking is factored in to all of our transactions.

Quality Assurance Policy

Provides the overview of the Group’s commitment to continued improvement, as well as monitoring and measuring adherence to policy and procedures through scheduled audit, policy updates and reviews. Where risk or actual breaches are found, the policy outlines the various actions that can be used to correct, reduce or mitigate future risk.

Risk assessments

An initial risk assessment is completed with a new supplier via a supplier questionnaire; confirming adherence to policy intent and new employees/temporary worker recruitment and vetting process. Scheduled audits are completed to identify risks. At any time where a breach or potential breach is identified, either internally or in the supply chain, it is reviewed using the Complaints & Serious Untoward Incident policy.

Investigations/due diligence

At any time where a breach or potential breach is identified, either internally or in the supply chain, it is reviewed using the HCL Complaints & Serious Untoward Incident policy, in conjunction with the National Referral Mechanism framework:

A referral to the Home Office is made using the National Referral Mechanism when referral thresholds are met. This allows for national action to combat modern slavery and provides potential victims with the appropriate support.

Due diligence

HCL Group undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. HCL Group’s due diligence and reviews include assessing the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking in areas which may include but not limited to;

  • evaluating the modern slavery and human trafficking risks of each new supplier [this may be part of a more general human rights or labour rights assessment];
  • reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
  • conducting supplier audits or assessments with a focus on slavery and human trafficking where general risks are identified;
  • taking steps to improve substandard suppliers’ practices, including providing advice to suppliers and requiring them to implement action plans to include specific amendments to be made and adhered to. This will be confirmed through a re-auditing process;
  • participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking
    using, where available, ethical supplier databases, where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular; and
  • invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the suspension or termination of the business relationship and reporting to the authorities as appropriate.


Internal training:

  • The HCL Group requires new internal personnel to complete an online modern slavery training course within three months of their commencement date. For existing personnel training, an annual refresher must be completed.
  • Modern Slavery Assessment Questionnaire for supply chain and subcontractor verification expected to be in place by 1 April 2017, whereby the HCL Group evaluates potential suppliers before they enter the supply chain; and
  • reviewing its existing supply chains and subcontractors against the Modern Slavery Assessment Questionnaire expected to be completed by 30 June 2017, whereby the HCL Group evaluates all existing suppliers.

The HCL Group’s modern slavery training will be the main mechanism for raising awareness about the Modern Slavery Act, which will include:

  • our business’s purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country’s national minimum wage, or the provision of products by an unrealistic deadline;
  • how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
  • how to identify the signs of slavery and human trafficking;
  • what initial steps should be taken if slavery or human trafficking is suspected;
  • how to escalate potential slavery or human trafficking issues to the relevant parties within the HCL Group;
  • what external help is available, for example through the Modern Slavery Helpline, Gangmasters Licensing Authority and “Stronger together” initiative;
  • what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
  • what steps HCL Group should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the HCL Group’s supply chains.

Performance indicators

HCL Group has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, the HCL Group’s temporary worker supply is provided with Safeguarding Children and Vulnerable Adult training to equip them to identify all types of abuse. Guidance on Safeguarding Children and Vulnerable Adults, including slavery and human trafficking, and professional responsibility to report accordingly is also provided in the temporary worker’ handbooks. This training is updated annually.

Board approval

This statement has been approved by the HCL Group’s board of directors, who will review and update it annually.