Instant Connect Privacy Policy

(Updated 21st August 2024)

At Instant Connect we take data privacy very seriously and we are committed to protecting and respecting the rights of all individuals. We are dedicated to ensuring the confidentiality and privacy of information entrusted to us and aspire to be transparent when we collect and use personal data.

This policy relates to Instant Connect, and is intended to tell you how we collect and use your Personal Information to give you the information you need at a glance, with the option of following a link if you want to find out more.

This Privacy Notice should be read in conjunction with the terms of business applicable to the service that you receive from Instant Connect found at www.instant-connect.co.uk/legal. 

This privacy notice covers the following:

Table of Contents

1. Our Contact Details

If you have questions or comments about this Privacy Notice or how we handle personal data, please direct your correspondence either to the below postal address (marking the envelope FAO - Data Protection Office), or to [email protected]

10 Matlock Road

Brighton and Hove

Brighton

BN1 5BF

2. Who are we

We are INSTANT CONNECT LTD, trading as Instant Connect ("Instant Connect", "we", "us") and we act as a processor for the purposes of all applicable UK legislation including (i) the General Data Protection Regulation, Regulation (EU) 2016/679 as it forms part of domestic law in the United Kingdom by virtue of section 3 of the European Union (Withdrawal) Act 2018; and (ii) the UK Data Protection Act 2018 (the "Data Protection Law"). We operate the Instant Connect platform and website at https://instant-connect.co.uk/ (the "Platform").

Our Platform connects Locums with Dental Practices through https://instant-connect.co.uk/ and any other website or application through which we may make the Platform and services available from time to time (our "services"). This policy applies to you if you are a Member, Locum, Dental Practice, visitor to our Platform. For the purposes of this policy:

  • Members – a user of the Platform who completes a registration as a Member.

  • Locums – a Member of the Platform who is a provider of healthcare services and operator of healthcare facilities that is regulated by the Care Quality Commission, such as but not limited to, dental practices.

  • Dental Practices – a Member of the Platform who is a provider of healthcare services and operator of healthcare facilities that is regulated by the Care Quality Commission, such as but not limited to, dental practices.

  • Platform Visitors – anyone who visits our Platform.

3. How Instant Connect collects personal information

For the purposes of this Privacy Notice, "Personal Information" consists of any information that relates to you and/or information from which you can be identified, directly or indirectly as defined under Data Protection Law. For example, information which identifies you may consist of your name, address, telephone number, photographs, location data, an online identifier (e.g. cookies identifiers and your IP address) or to one or more factors specific to your physical, economic, cultural or social identity. When we combine other information (i.e. information that does not, on its own, identify you) with Personal Information, we treat the combined information as Personal Information.Given the nature of our website, we do not expect to collect the personal data of anyone under 18 years old. If you are aware that any personal data of anyone under 18 years old has been shared with our website please let us know so that we can delete that data. This privacy policy is primarily written for adults.We may collect use, store and transfer different kinds of Personal Information about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name (if applicable), last name, community username, title, date of birth and gender, job title, a copy of a photographic identity document (such as a passport or ID card), a photograph for incorporation into your profile on the Platform.

  • Contact Data includes address, former addresses (where applicable), email address and telephone number(s).

  • Career History and Education Data includes professional skills and experience, employment history, academic and professional qualifications, certificates, training, competencies (clinical and medication).

  • Employment Status Data includes status/right to work and work permit information.

  • Worker Profile Data includes job role, details of professional indemnity insurance cover, your ratings submitted via our in-built ratings system, feedback relating to you, preferences.

  • Financial Data includes bank account details, direct debit mandates.

  • Technical Data includes internet protocol (IP) addresses, location data, username and password, usage session dates and duration, page views, time zone setting and location, browser plug-in types and versions, operating system and platform, the type of browser used while visiting our Platform, how you use our Platform and the numbers of users who visit our website.

  • Services Data includes information about how you use our services, details of which services you have received from us, choices you have made on the Platform (including, for example, settings and favourite workers), information as to shifts accepted or declined, cancellations, ratings, reviews, responses to surveys and requests for feedback, information about your use of our services, correspondence and communications with you and information about any complaints or enquiries you make to us.

  • Community Data includes any information you send to other Members via the Platform's community function.

  • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

  • Special Categories of Data: we may collect the following special categories of Personal


    Information about you:

    • occupational health information including vaccination/immunisation status and history ("Occupational Health Data");

    • the identity of your professional indemnity insurer which may indicate trade union membership ("Trade Union Data"); and

    • proof of CDC registration (“CDC”)

    • where a photographic ID is provided (for example by way of a copy of your passport, driving licence or other photographic ID document) an inference may be made as to your race, ethnicity and/or religious beliefs ("ID Data").

    • - Criminal Offences Data: we will process information about a Locums criminal convictions including enquiries made of the Disclosure and Barring Service ("DBS") in respect of criminal convictions as part of a Locums membership application process, creation of a profile and use of the Platform.

You must provide this personal data to use our website and deal with our business. Our Dental Practices require us to carry out a criminal records check in order to satisfy themselves that there is nothing in a Locum’s criminal convictions history which makes a Locum unsuitable for becoming a Member of the Platform, using the Platform and/or applying for and carrying out an Assignment. Therefore, we may collect a copy of your DBS Certificate, your DBS Certificate number and DBS Update Service Number. We may also ask you to provide a statement about the information contained in your DBS Certificate.


We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.

3. a) If you fail to provide personal information

Where we need to collect Personal Information by law, or under the terms of a contract we have with you, and you fail to provide that Personal Information when requested, we may not be able to perform the contract we have, or which we are attempting to enter into, with you (for example, to provide you with services and support). In such circumstances, we may be required to cease providing services and support to you and will notify you accordingly.

4. How Instant Connect collects personal information

At Instant Connect we may obtain personal data directly from individuals in a number of ways we may also obtain personal information indirectly (such as your browsing activity while on our website) from a variety of sources including:

A. Members

  • Personal Information that you provide directly to us. You may give us your Identity Data, Contact Data, Marketing and Communications Data, by filling in our Platform registration form, creating an account and profile or by corresponding with us by email, phone or otherwise. We collect Services Data when we correspond with you about our services and when you use the Platform.

  • Automated technologies or interactions. When you interact with our Platform, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Information by using cookies and other similar technologies, and our analytics providers. Please see section 10 below.

B. Dental Practices

  • Personal Information that you provide directly to us. You may give us your Identity Data, Contact Data, Financial Data, Marketing and Communications Data, by filling in our Platform registration form, creating an account and profile, updating and adding to your profile, using the Platform or by corresponding with us by email, phone or otherwise. We collect Services Data when we correspond with you about our services and when you use the Platform.

  • Automated technologies or interactions. When you interact with our Platform, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Information by using cookies and other similar technologies, and our analytics providers. Please see section 10 below.

  • Third parties or publicly available sources. We may collect your Identity Data and Contact Data from publicly available sources such as Companies House and the CQC.

C. Locums

  • Personal Information that you provide directly to us. You may give us your Identity Data, Contact Data, Career History and Education Data, Employment Status Data, Worker Profile Data, Financial Data, Special Categories of Data, Criminal Offences Data, Marketing and Communications Data, by filling in our Platform registration form, creating an account and profile, updating and adding to your profile, using the Platform or by corresponding with us by email, phone or otherwise. We collect Services Data when we correspond with you about our services and when you use the Platform.

  • Automated technologies or interactions. When you interact with our Platform, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Information by using cookies and other similar technologies, and our analytics providers. Please see section 10 below.

  • Third parties or publicly available sources. We may receive Identity Data, Career History and Education Data from third parties such as your Referee and from publicly available sources such as LinkedIn, the NMC. We may also receive Criminal Offences Data from a third party DBS check provider if you have chosen to use our recommended provider to obtain a DBS Certificate and from the DBS Update Service provided by the government if you have chosen to give us access to that service.

D. Platform Visitors

When you interact with our Platform, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Information by using cookies and other similar technologies, and our analytics providers. Please see section 10 below.

We will always ensure you know we are processing your personal information except where it is disproportionately difficult to do so.

5. How do we use your information

We will only use your Personal Information when Data Protection Law allows us to do so. You can see a full list of the types of data we process, the purpose for which we process it and the lawful basis on which it is processed in the table below.

Where we refer to a legitimate interest herein, we mean that we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us using the contact details provided herein.

5. a) Instant Connect’s purposes and lawful bases of personal data processing

We may use the Personal Information that we collect for the following purposes. For each purpose, we describe the legal bases we rely on to justify such use of your Personal Information:

Category Purpose/Activity Type of Data Legal Basis
Dental Practices To register you or your employer as a Dental Practice Identity Data
Contact Data		 Necessary for performance of a contract with you
Locums To provide you with our services including:
- operating the Platform;
- allowing you to communicate with other Members;
- allowing you to request work from locums;
- managing payments, fees and charges including via Payment Processor(s) 		Identity Data
Contact Data
Financial Data
Community Data 		Necessary for:
- performance of a contract with you;
- our legitimate interests to operate the Platform and those of other Members
Locums To register you as a Locum including making enquiries of third parties, for example, via a Verification Services Provider. Identity Data
Contact Data
Career History and Education Data
Employment Status Data
Profile Data 		Necessary for performance of a contract with you
Locums To provide you with our services including:
- operating the Platform;
- allowing you to amend your profile;
- allowing you to communicate and interact with other Members;
- allowing you to accept invitations from Dental Practices;
- managing payments, fees and charges including via the Payment Processor;
- collecting and seeking to recover money owed to us 		Identity Data
Contact Data
Financial Data
Services Data
Career History and Education Data
Employment Status Data
Profile Data
Community Data 		Necessary for:
- performance of a contract with you;
- our legitimate interests to operate the Platform and those of other Members;
- our legitimate interests (to recover debts due to us)
Locums For compliance purposes – Locums (as healthcare institutions) will need to access the personal data of a Locum via the Platform in order:
- to assess the WORKER against the compliance standards set by the Client organisation ahead of arrangement of an Assignment;
- to maintain records of WORKERs with whom the Client has entered into Assignments 		Identity Data
Contact Data
Profile Data
Referee Data 		Necessary for:
- performance of a contract with you;
- our legitimate interests to operate the Platform and those of other Members
Locums To communicate with relevant regulatory bodies including the Care Quality Commission. Identity Data
Contact Data
Profile Data
Services Data 		Necessary for:
- performance of a contract with you;
- to comply with a legal obligation;
- for our legitimate interests and those of any applicable regulators
Members, Locums and Dental Practices To manage our relationship with you which will include:
- notifying you about changes to our Terms and Conditions or Privacy Notice;
- asking you to leave a review or provide feedback 		Identity Data
Contact Data
Marketing and Communications Data
Services Data 		Necessary for:
- performance of a contract with you;
- to comply with a legal obligation;
- our legitimate interests in keeping our records updated and studying how Members use our Platform and services
Members and Platform Visitors For security purposes and to administer our Platform – to maintain and enhance the Platform, to ensure that content from it is presented in the most effective manner for you and your computer, and to enhance the user experience (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) Technical Data Necessary:
- for our legitimate interests in running our business;
- to ensure the security of our systems, to assist us in the provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation

Please be aware that we are not responsible for the data processing activities of others, such as Dental Practices.

5. b) Marketing communications

Where permitted in our legitimate interest or with your prior consent where required by Data Protection Law, we will use your Personal Information for marketing analysis and to provide you with promotional update communications by email, telephone or post about our products and services. For further information on this, see the 'Your Choices' section of this Privacy Notice.

5. c) Combining personal information

We may combine the Personal Information that we collect from you to the extent permitted by applicable law. For example, we may combine various different databases that contain your Personal Information to carry out internal analysis of our Member base and how the services are used, and to provide better services and more personalised content (such as marketing).

5. d) Change of purpose

Where we need to use your Personal Information for another reason other than for the purpose for which we collected it, we will only use your Personal Information where 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.

6. Sharing Information

We will only use your Personal Information for our internal business purposes, some of which are mentioned above. We may disclose your information to the following entities:

Dental Practices

We may need to disclose Locum's Personal Information to Dental Practices as part of the services and use of the Platform. For example, we will share Locum’s Identity Data, Contact Data, Profile Data, Employment Status Data and Career History with Clients when you create an account (as defined in our Terms and Conditions).

Service Providers

We use third party service providers to help us to administer certain activities and services on our behalf, such as IT, hosting and cloud services, payment processing services, verification services, marketing services and customer support services. We may share Personal Information about you with such third party service providers solely for the purpose of enabling them to perform services on our behalf and they will operate only in accordance with our instructions. Here are examples of third-party service providers we use:

IT Service Provider and Administration Services – we use gohighlevel, and Cape Marketing Agency Ltd,  to provide us with IT, hosting and cloud services.Marketing and Analytics Services – we use Google Analytics, and Facebook to provide us with marketing and analytics services including Facebook Pixel and Custom Audiences.

  • Facebook Pixel is a cookie (explained below at section 10) which we use to gather information about use of our Platform. Facebook's cookies policy can be found here.

  • We use Custom Audiences to tailor our advertising to people who are likely to be interested in us. The data processing terms which apply to Facebook when we use Custom Audiences are found here.

Payment Processing Services – we use third party online payment processors to collect, process, hold and/or remit payments. Currently we use GoCardless.

Anonymous statistics

We prepare and develop anonymous, aggregate or generic data and statistics for various reasons (such as aggregate usage statistics including "page views" on the Platform analysing how users use our content and for marketing). As this data is anonymous (i.e. you cannot be identified from it) we do not consider this information to be Personal Information. As such, we may share it with any third party.

Third parties when required by law

We will disclose your Personal Information to comply with applicable law or respond to valid legal process, including from our regulators, law enforcement or other government agencies (in which case such agencies or regulators will be acting as processors as well); to protect the users of the Platform (e.g. to prevent spam or attempts to defraud them); to operate and maintain the security of the Platform (e.g. to prevent or stop an attack on our systems or networks); or to protect our rights or property.

Other Parties in Connection with Corporate Transactions

We may disclose your Personal Information to a third party in the event that (a) we buy any business or assets, in which case we will disclose your Personal Information to the prospective buyer of such business or assets subject to the terms of this Privacy Notice; (b)

all or substantially all of our business or assets are or are intended to be sold or otherwise assigned to another entity.

Other Parties at Your Direction

We may share Personal Information about you with third parties when you request such sharing, such as to prospective employers, or to your legal or other professional advisers.

7. What do we do to keep your information secure

We have put in place appropriate physical and technical measures to safeguard your Personal Information. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality. When we use service providers to assist us in processing your Personal Information, we have written contracts in place with such service providers which means that they cannot do anything with your Personal Information unless we have instructed them to do it. However, please note that although we take appropriate steps to protect your Personal Information, no website or transmission of data, computer system or wireless connection is completely secure and therefore we cannot guarantee the security of your Personal Information. We have established and implemented procedures to deal with any suspected Personal Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. How we store your information

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We retain Locums and Dental Practice’s Personal Information for seven years after deletion of their account. When your Personal Information is no longer required for the purpose it was collected or as required by applicable law, it will be deleted and/or returned to you in accordance with applicable law. In some circumstances you can ask us to delete your Personal Information (see section 9 below).

9. Your Rights

We will collect, store and process your Personal Information in accordance with your rights under any applicable Data Protection Laws. Under certain circumstances, you have the following rights which you can exercise at any time in relation to your Personal Information:

  • Subject Access - you have the right to request details of the Personal Information which we hold about you and copies of such Personal Information.

  • Right to Withdraw Consent – where you have consented to our processing of your Personal Information, you have the right to withdraw such consent at any time. In the event you wish to withdraw your consent to processing, please contact us using the details provided in section 1.

  • Data Portability – you may, in certain circumstances, request us to port (i.e. transmit) your Personal Information directly to another organisation or to you.

Rectification – we want to ensure that the Personal Information about you that we hold is accurate and up to date. If you think that any information we have about you is incorrect or incomplete, please let us know. To the extent required by applicable laws, we will rectify or update any incorrect or inaccurate Personal Information about you.

Erasure ('right to be forgotten') - you have the right to have your Personal Information 'erased' in certain specified situations.

Restriction of processing – you have the right in certain specified situations to require us to stop processing your Personal Information.

Object to processing – You have the right to object to specific types of processing of your Personal Information, such as, where we are processing your Personal Information for the purposes of direct marketing.

Prevent automated decision-taking – in certain circumstances, you have the right not to be subject to decisions being taken solely on the basis of automated processing.

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us using the details set forth herein. You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

9. a) What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to expedite our response.

9. b) Rights related request

If you wish to enforce any of your rights under applicable Data Protection Laws, then please see section 1 above. We will respond to your request without undue delay and by no later than one month from receipt of any such request, unless a longer period is permitted by applicable data protection laws, and we may charge a reasonable fee for dealing with your request which we will notify you. Please note that we will only charge a fee where we are permitted to do so by applicable Data Protection Laws.

10. How to complain

If you disagree with how we are processing your data, please contact our DPO at [email protected] or address your letter to the DPO at the registered Instant Connect address listed in the ‘Contact Details' section.You can also complain to the ICO if you are unhappy with how we have used your dataIf you are concerned that we have not complied with your legal rights under applicable data protection laws, you may contact the Information Commissioner's Office (www.ico.org.uk) which is the data protection regulator in the UK which is where we are located.

The ICO’s address is:

Information Commissioner’s Office Wycliffe House

Water Lane Wilmslow Cheshire SK9 5AF

Helpline number: 0303 123 1113

Alternatively, if you are based outside the UK, you may contact your local data protection supervisory authority.

11. Third-party links

Our Platform may contain links to other third party websites that are not operated by us. These linked sites and applications are not under our control and as such, we are not responsible for the privacy practices or the content of any linked websites and online applications. If you choose to use any third party websites, any Personal Information collected by the third party’s website will be controlled by the Privacy Notice of that third party. We strongly recommend that you take the time to review the privacy policies of any third parties to which you provide Personal Information.

12. What are cookies

Our Platform may contain links to other third party websites that are not operated by us. These linked sites and applications are not under our control and as such, we are not responsible for the privacy practices or the content of any linked websites and online applications. If you choose to use any third party websites, any Personal Information collected by the third party’s website will be controlled by the Privacy Notice of that third party. We strongly recommend that you take the time to review the privacy policies of any third parties to which you provide Personal Information.

13. Changes to this Privacy Notice and your duty to inform us of changes

We may use cookies on our website. Cookies are small text files that can be read by a web server in the domain that puts the cookie on your hard drive. Cookies are assigned to and stored in a user's internet browser on a temporary (for the duration of the online session only) or persistent basis (cookie stays on the computer after the internet browser or device has been closed). Cookies collect and store information about a user’s preferences, product usage and content viewed which allows for us to provide users with an enhanced and customised experience when engaging with the website.See our Cookies Policy - www.instant-connect.co.uk/legal  - for further information on cookies and how we use them.

14. Changes to this Privacy Notice and your duty to inform us of changes

It is important that you check back often for updates to the Privacy Notice, as we may change this Privacy Notice from time to time. The “Date last updated” legend at the bottom of this page states when the notice was last updated, and any changes will become effective upon our posting of the revised Privacy Notice.We will provide notice to you if these changes are material and, where required by applicable law, we will seek your consent. We will provide this notice by email or by posting notice of the changes on our websiteIt is also important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us.

(Updated 21st August 2024)

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