Careers at Priory

Priory (“we”, “us”) are committed to protecting and respecting your privacy. This Privacy Notice sets out the basis on which the personal data collected from you, or that you provide to us, will be processed by us in connection with our recruitment processes.

For the purpose of the General Data Protection Regulation (“GDPR”) the Data Controller is Priory.

We use Pinpoint, an online software product provided by The Infuse Group Ltd (t/a Pinpoint Software), to assist with our recruitment process. We use Pinpoint to process personal information as a data processor on our behalf. Pinpoint is only entitled to process your personal data in accordance with our instructions

Where you apply for an opportunity posted by us, these Privacy Notice provisions will apply to our processing of your personal information, in addition to our other Privacy Notice which is available on our website.

Privacy Notice for Priory UK 1 Limited

This Privacy Notice is effective from 8 July 2025 and is applicable to all companies under Priory Group UK No1 Limited trading as ‘Priory’.

We will update this Privacy Notice from time-to-time. When we do change the notice (in a significant way), we will post an update on our website.

Priory takes data protection and confidentiality very seriously. This privacy notice covers:

What a Privacy Notice is
What information we will collect and store about you
How we collect your personal information
For what purpose we will use your personal information
What happens if you fail to provide personal information
How changes of purpose will be managed
Why we might share your personal information with third parties
What type of third party service providers process your personal information
How we may share your personal information with third parties
How long we will use your information
How we store your personal information
Protection of your personal information
Accuracy of personal information
When might we transfer your information overseas
Access to personal information
Automated decisions
Data portability
Additional rights

Privacy questions

If you have any questions or concerns about this Privacy Notice or how we process your information, or if you would like to make a complaint about a possible data breach, please contact us:

Email: personaldata@priorygroup.com

Postal address:
Group Data Protection Officer
Priory
7th Floor, 3 Shortlands
London
W6 8DA

We take data security extremely seriously and all such communications are examined and replies issued where appropriate as soon as possible. If you are unsatisfied with the reply you receive, you may refer your complaint to the Information Commissioner’s Office (
ico.org.uk)

What is a Privacy Notice?

Priory is a 'data controller'. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you regarding how we hold and use your personal information.

This notice applies to current and former employees, workers and contractors and candidates applying for employment. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practical. It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under data protection legislation.

1. What information we will collect, store and use about you

We will collect, store and use the following categories of personal information about you:

Personal contact details such as name, title, address, telephone numbers and personal email addresses
Date of birth
Marital status and dependants
Emergency contact information
National insurance number
Bank account details, payroll records and tax status information
Student and/or postgraduate loan information
Salary, annual leave, pension and benefits information
Records/results of any pre-employment checks (including credit and fraud checks)
Start date and, if different, the date of your continuous employment
Leaving data and your reason for leaving
Location of employment or workplace
Attendance records or timesheets
Copy of passport, driving licence and proof of address
Employee personal relationships with anyone else working for the company
Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process)
Employment records (including job titles, work history, working hours, holidays, training records and professional memberships)
Employment and management records will include disciplinary and grievance records, flexible working requests, performance records, appraisals and training records, holiday and attendance records, terms and conditions of employment
Compensation history
Performance information
Disciplinary and grievance information
CCTV footage, audio CCTV recordings (in limited circumstances) and other information obtained through electronic means such as swipe card records
Information about your use of our information and communications systems
Results of HMRC employment status check, details of your interest in and connection with intermediary through which your services are supplied

We may also collect, store and use the following sensitive special categories of personal information:

Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions
Trade union membership
Information about your physical and mental health, including any medical condition, health and sickness records including:
Pre-employment medical screening tests
Where you leave employment and under any share plan operated by a group company the reason for leaving is determined to be ill-health, injury or disability, the records relating to that decision
Details of any absences (other than holidays) from work including time on statutory paternal leave and sick leave
Any health information in relation to a claim made under the a health insurance scheme
Where you leave employment and the reason for leaving is related to your health, information about that condition needed for pension and health insurance purposes
Genetic information (where applicable)
Biometric records for the purposes of time recording attendance at sites
Information about criminal convictions and offences

2. How we collect your personal information

We collect personal information about candidates, employees, workers and contractors through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies such as immigration consultants, or the Disclosure and Barring Service.

We may also collect personal information from the trustees or managers of pension arrangements operated by a group company.

We will collect additional personal information in the course of job-related activities throughout the period of you working for us.

3. For what purpose we will use your personal information

We will only use your personal information when the law allows us to. Mostly to comply, we will use your personal information in the following circumstances:

Where we need to determine how appropriate your application is for employment
Where we need to perform the contract we have entered into with you
Where we need to comply with a legal obligation
Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests

We may also use your personal information in the following situations, which are likely to be rare:

Where we need to protect your interests (or someone else’s interests)
Where it is needed in the public interest or for official purposes

The situations in which we will use your personal information include:

Making a decision about your recruitment or appointment (for example CV, application form)
Checking you are legally entitled to work in the UK
Paying you and, if you are an employee or deemed an employee for tax purposes, deducting tax and national insurance contributions
Providing the following benefits to you: salary, pensions, insurance and benefits administration (including pensions)
Enrolling you in a pension arrangement in accordance with our statutory automatic enrolment duties
Liaising with the trustees or managers of a pension arrangement operated by a group company, your pension provider and any other provider of employee benefits
Administering the contract we have entered into with you
HR, business management, planning purposes
Making decisions about salary reviews or compensation
Conducting inductions, appraisals or performance reviews, handling disciplinary and grievance matters, performance management, career planning, training, promotion, secondments, etc.
Dealing with legal disputes involving you, or other employees, workers and contractors, including accident at work
Managing disability, sickness or other types of leave, e.g. maternity leave, paternity leave
Ascertaining your fitness to work
To facilitate settling of expenses staff have incurred in the course of the business in accordance with their employment contracts
To facilitate communications between employees and members within the business
Internal record keeping purposes to enable us to maintain an audit trail in respect of approvals of decisions, voting and any internal surveys
Managing and safeguarding our management, IT and communications systems
Security reasons
Complying with health and safety obligations
To prevent fraud
Performing workforce analysis, project management and planning
Education, training and quality purposes
Equal opportunities monitoring
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.
To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution
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:

For security purposes and to assist with time recording at various premises by using biometric measurement data
Managing sickness absence, providing reasonable adjustments in the workplace and administering benefits
For legal reasons e.g. to comply with employment and health and safety obligations

We will use information about your gender, 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.

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.

4. What happens if you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to offer you employment or we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with any legal obligations (such as to ensure the health and safety of our workers).

5. How changes of purpose will be managed

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 publish an updated Privacy Notice on our website.

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. Why we might share your personal information with third parties

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you, which may include during our pre-employment checks, including right to work and the disclosure and barring service; or where we have another legitimate interest in doing so.

7. What type of third party service providers process your personal information

'Third parties' includes third party service providers (including contractors and designated agents) and other entities within our group and their employees, representatives, strategic investors and their respective advisers.

Priory engages these third parties to provide certain services to the business. In order for them to provide their services, we need to allow them to process personal data necessary for their tasks. When we use third parties to process personal data on our behalf, we require them to commit to compliance with relevant data protection legislation.

The following activities are carried out by third party service providers: payroll, pension administration, benefits provision and administration, IT services, management and data storage and intranet services, occupational health/other benefits, digital right to work checks and the disclosure and barring service.

8. How we may share your personal information with third parties

We may share your personal information with other third parties

Sale or restructuring. We may need to share your personal information if a sale or restructuring of all or part of the Priory occurs. In this situation we will, so far as possible, share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the terms of the transaction.

Request from a regulator or otherwise to comply with the law. We may also share your personal information: (i) with a regulator; (ii) to comply with the law; or (iii) in other circumstances when we are legally permitted to do so. This may include making returns to HMRC and disclosures to any other regulatory bodies which have authority over the Priory or its group, our professional advisers (such as lawyers, auditors, immigration advisers etc.), disclosures to stock exchange regulators, disclosures to shareholders such as directors' remuneration reporting requirements and to such third parties as we reasonably consider necessary in order to prevent crime.

9. How long we will use your information

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available in our retention policy which is available on the Priory intranet or from our People Team or Recruitment Manager.

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 requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with our retention policy, applicable laws and regulations.

10. How we store your personal information

The personal information we collect is stored in a variety of paper and electronic forms. Regardless, we have appropriate and adequate technical and administrative processes in place to make sure that all your information is kept secure.

11. Protection of your personal information

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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. Details of these measures may be obtained from the data protection team at personaldata@priorygroup.com.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

12. Accuracy of personal information

Priory makes it easy for you to keep your personal information accurate, complete, and up to date. If any of your information changes please let us know so that we can update our records.

13. When might we transfer your information overseas

We will transfer the personal information we collect about you to countries within the European Economic Area (EEA). There are adequacy regulations in respect of these countries. This means that the countries to which we transfer your data are deemed to provide an adequate level of protection for your personal information.

We may transfer personal information we collect about you to the United States of America or other parts of the world outside the UK where there has not been an adequacy decision. This means that these countries are not deemed to provide an adequate level of protection for your personal information. We will transfer your personal data to those countries in limited circumstances that include when a third party supplier (such as IT software supplier) has operations (or provides IT software support for example) in such a country and can only deliver their service to Priory by transferring your personal data to that country or because their IT infrastructure is structured in such a way that data is stored in those countries.

To ensure that your personal information does receive an adequate level of protection we put in place the following appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects UK law on data protection: data protection agreements, technical and organisational measures, standard contractual clauses and binding corporate rules (where applicable). If you require further information about this or these protective measures, you can request more information from the data protection team at personaldata@priorygroup.com.

14. Access to personal information

You are entitled to see what personal information we hold about you at any time. This Privacy Notice outlines the information we hold about you and why. If you wish to access your personal information, please contact us at personaldata@priorygroup.com.

We are not required to process any request for access which is frivolous or vexatious, jeopardizes or otherwise affects the privacy of others, are impractical, or for which access is not otherwise required by law. We will let you know in writing if any of these circumstances apply to your request.

15. Automated decisions

Automated decision making takes place when an electronic system uses personal information to make a decision without human intervention. You will not be subject to decisions that will have a significant impact on you based solely on automated decision making, unless we have a lawful basis for doing so and we have notified you.

There are however limited circumstances where an automated decision may be made about you, if you are a candidate who confirms that you do not have the Right to Work in the United Kingdom. Before any automated decision is made, we will obtain your explicit consent before processing your data. If as a candidate, you confirm that you do not have the Right to Work in the UK and you do have the right to work in the UK, please contact Priory and we will review.

16. Data portability

You may have a right to data portability under the UK General Data Protection Regulation (GDPR).

The right to data portability allows you to obtain and reuse a copy of your personal data for:

Your own purposes
For us to send the information to a new provider on your behalf (where technically feasible)

It allows you to move data, copy data and transfer data.

The right to data portability ensures that it is done in a safe and secure way without affecting its usability. However, it will only apply to information concerning you which you have provided to us and where it is held electronically (so does not include paper records).

This may include data such as:

Username
Email address
Website or search usage history
Traffic and location data

You can make a data portability request verbally or in writing when we are processing your information:

By automated means and rely on your consent to use your personal data
When we use your data as part of a contract you have with us

We will ensure that we provide your information in a ‘structured’, ‘commonly used’ and ‘machine-readable’ format.

You can find further information on the Information Commissioner’s Office website: https://ico.org.uk/your-data-matters/your-right-to-data-portability/

If you would like to make a data portability request please email personaldata@priorygroup.com. Please note that as part of the process we may be required to verify your identity.

We will aim to respond to your request within a month but may respond within a further 2 months if the request is complex or we have received a number of requests from you.

17. Additional rights

You may also have the right to:

Object to processing of personal data that is likely to cause, or is causing, damage or distress
Prevent processing for the purposes of direct marketing
Object to decisions being taken by automated means
In certain circumstances, have inaccurate personal data rectified, blocked, erased or destroyed
Data portability

If you believe you have any of these additional rights and you wish to exercise them, please let us know.