Scope and overview

This privacy notice is issued on behalf of the Acacium Group and all its group companies. A full list of our group companies and their trading names can be found on our website: acaciumgroup.com/our-brands/. All reference to the Acacium Group refer to these companies. If you require a printed copy of this privacy notice or our group companies, please contact us using the details below.

This privacy notice applies to you when you apply to work temporarily or permanently with Acacium Group as a candidate.

When we mention “we”, “us” or “our” in this privacy notice, we are referring to any company in the Acacium Group.

The controller for your personal data is ICSG Limited. 

Please contact us using the details below:

Email us at dpo@acaciumgroup.com

Write to us at: Data Protection Officer, Acacium Group, 9 Appold Street, London, EC2A 2AP

If you have any concerns about the personal data we use about you, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, and the details about how to do so are the end of this privacy notice. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please feel free to contact us in the first instance.

We regularly review this privacy notice and will update it where necessary. We will notify you of any significant changes, however we do recommend you regularly review this privacy notice, via the supplied link to make sure you have the most up to date information. This privacy notice was last updated on 30/04/2025.

1. When will this privacy notice apply?

There are certain laws that we must comply with whenever we process your personal data, particularly the UK GDPR and Data Protection Act 2018.  ‘Personal data’ means any information about you specifically as an individual and ‘processing’ means any use of your personal data, to include collecting it in the first place.

This privacy notice explains how we make sure we comply with those laws in respect of your personal data.  In particular, this privacy notice will apply to personal data that we collect from you when:

• you complete an application form via the website for a job opportunity;
• you complete a registration form via our website to join our database;
• you meet us at a recruitment fair and give us your details to start the recruitment process;
• you speak to us on the telephone (which may be recorded for quality and monitoring purposes) in relation to applying for a job opportunity and we take you through the recruitment process;
• you email your CV or documents relating to a job opportunity or joining our database to one of our recruitment team and we contact you to start the recruitment process.; or
• you provide your details on a social media site or job board site, indicating that you are looking for job opportunities and we contact you to start the recruitment process.

We are committed to ensuring that your privacy is protected. If you provide us with personal data, you can be assured that it will only be used in accordance with this privacy notice.

2.What is the lawful basis for using your personal data?

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. This means that we must process your information in compliance with our regulatory framework and the law .There is a list of possible lawful bases in the UK GDPR and you can find out more about them on the ICO’s website.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data for purposes below. These are commonly called the lawful basis for processing.:

• Performance of a Contract – processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering a contract
• Legitimate Interest – processing is necessary for the purpose of the legitimate interests pursued by us or a third party, except where such interests are overridden by your interests or fundamental rights and freedoms that require protection of your personal data
• To comply with legal requirements: this applies where there are legal duties or requirements for us to use your personal data in a certain way, for example if we are required to share it in connection with legal proceedings and as a result of a specific court order. It could also apply where a regulator, such as the ICO or General Medical Council, requires us to share certain information in connection with matters they are investigating.
• Consent – you have given your consent to the processing of your personal data for the purposes detailed in this privacy notice.

We will only use your personal data for the purposes for which we collected it, unless we lawfully and reasonably consider that we need to use it for another reason and that reason is compatible with the law and the original purpose in this privacy notice.

Please note that throughout the recruitment process and while you are a candidate you will not be subject to any solely automated decision making, meaning that only humans, and not AI, will make decisions about any potential job opportunities.

The table below sets out the personal data that we collect and use about you and the lawful basis we will rely on, as set out above.

In certain circumstances you will be obliged to provide us with personal data for a legal/statutory requirement or to enter into a contract. Where this is the case, we have identified these instances in the table below with an “*.” If you fail to provide the personal data when requested, we may not be able to accept you as a candidate or continue to place you into job opportunities.

Who does this apply to?	Personal data	Purpose	Lawful basis

Temporary and permanent candidates	Basic contact details: full legal name; telephone number; email address; and postal address*	To enter into a contract with you for our services To enable you to have a preference as to how we contact you To enable us to communicate and manage our relationship with you while finding you suitable job opportunities and while you work with us To enable you to receive job alerts for suitable job opportunities To enable us to send you business communication relating to working with Acacium Group To enable us to identify you when placing you into a potential job opportunity	Performance of a Contract
Temporary and permanent candidates	Basic contact details: full legal name; telephone number; email address; and postal address*	To conduct background checks to ensure you are safe to work with Acacium Group’s clients and individuals To enable us to send you any legal or regulatory changes that may affect you, for example changes to tax regulations	Legal Obligation
Temporary and permanent candidates	Identity documents: passport; visa; birth certificate; driving licence; or adoption certificate*	To verify that your identity is correct	Legal Obligation
Temporary and permanent candidates	Proof of address documents: driving licence; bank statement; utility bills; or financial statements*	to verify your address is correct	Legal Obligation
Temporary and permanent candidates	Date of birth*	To verify your identity against required documentation To conduct background checks to ensure you are safe to work with Acacium Group’s clients and individuals	Legal Obligation
Temporary candidates	Next of kin	To be able to contact someone on your behalf in the event of an emergency	Legal Obligation
Temporary and permanent candidates	Proof of your immigration status and legal right to work*	To demonstrate that you can legally work in the country where the job opportunity is	Legal Obligation
Temporary and permanent candidates	Proof of a change of name*	To verify your identification for legal and regulatory requirements if other documents are in a different name To confirm that we have the most accurate and up to date information	Legal Obligation
Temporary and permanent candidates	Proof of a valid registration with your required regulatory body*	To verify professional qualifications and fitness for you to legally work in your profession	Legal Obligation
Temporary and permanent candidates	Proof of a valid registration with your required regulatory body*	To be able to place you as a qualified professional in suitable job opportunities	Performance of a Contract
Temporary candidates	Previous employment history with other agencies*	To assess criteria to determine if you qualify for Agency Worker Regulation rights	Legal Obligation
Temporary and permanent candidates	Full employment history and evidence of relevant qualifications*	To find you suitable job opportunities in your preferred and experienced profession To verify professional qualifications and relevant employment history	Performance of a Contract
Temporary nursing candidates	Evidence of professional skills checklists*	To conduct background checks to ensure you are safe to work with Acacium Group’s clients and individuals To verify professional skills to ensure that you are placed in a position where you can safely meet the required competencies To suitably match you to a role	Performance of a Contract
Temporary candidates	Answers to competency interview questions*	To verify professional qualification and experience To ascertain the type of role you require To find you suitable job opportunities in your preferred profession	Performance of a Contract
Qualified temporary candidates	Proof of a valid professional indemnity insurance*	To ensure you have adequate professional indemnity insurance in place	Legal Obligation
Qualified temporary candidates	Proof of a valid professional indemnity insurance*	A requirement for us to obtain and maintain insurance policies	Legitimate Interests
Temporary and permanent candidates	Referee details and contents of a reference*	To conduct background checks to ensure you are safe to work with Acacium Group’s clients and individuals by gaining at least two references To verify your experience and fitness to work in your chosen profession To confirm that you can work for an agency by ensuring that you are not exceeding working hours or are not claiming any other statutory benefits whilst working for us, for example sick pay or maternity pay	Legal Obligation
Temporary and permanent candidates	Referee details and contents of a reference*	To find you suitable job opportunities in your preferred profession and match your experience and skills	Performance of a Contract
Temporary candidates	Evidence of core competency assessments*	To verify your compliance in core competencies to enable us to find you suitable job opportunities To offer you the opportunity to achieve core competencies	Performance of a Contract
Temporary candidates	Photographs or digital images*	To provide you with an ID badge to wear while you are working, to evidence your identity and safeguard our vulnerable clients	Legitimate Interests
Temporary candidates	Financial information: bank details; umbrella company details; limited company details; evidence of a tax code; or evidence of statutory benefits*	For us to meet legal requirements around tax and payment including payment for the work that you do, payment of expenses and payment of annual leave	Legal Obligation
Temporary candidates	Details relating to: pregnancy; paternity; adoption; or surrogacy*	To ensure that you are meeting Working Time Regulations requirements and are taking/planning sufficient rest breaks and annual leave	Legal Obligation
Temporary candidates	Details of your availability to work and a record of shifts or placements completed with us*	To enable us to find you suitable employment when you wish to work	Performance of a Contract
Temporary candidates	Card payment details*	To process your payment for criminal checks if conducted through Acacium Group To process your payment for core competency assessment certificates if conducted through Acacium Group To allow you to purchase required uniforms to enable you to represent us at work	Performance of a Contract
Temporary candidates	Appraisal details*	To allow us to assist in processing revalidation requirements (nurses and doctors)	Legal Obligation
Temporary candidates	Appraisal details*	To continually assess your suitability to perform your role To offer support to you and continue to offer you employment	Performance of a Contract
Temporary and permanent candidates	Details of incidents and complaints prior to joining Pulse Healthcare Limited or while working with us*	To conduct background checks to ensure a safer recruitment process To ensure that you are fit to work in your chosen profession To carry out or assist with any legal or regulatory investigations	Legal Obligation
Temporary and permanent candidates	Market research	To improve our services To find out how you heard of us To recommend other relevant professionals to us	Legitimate Interests

3. What special category or criminal data does Acacium Group process about you?

Through your application and throughout your time as a candidate, it will be necessary for us to collect and use personal data about your medical history and any illnesses that you have. This information is called “special category data.” Depending on the job opportunity we may also process about you which concerns criminal convictions, via a criminal records bureau (such as the Disclosure and Barring Services). When we collect special category data and criminal conviction data about you we will provide you with additional information about how we will use your special category data and criminal conviction data.

4. What additional personal data do we collect, use and process about you throughout your working time with us? 

Whilst you apply and then are registered with us we may be required to collect and use further personal data. This personal data may be obtained from you directly or from third parties as set out below:

• Clients – we may obtain feedback forms post-placement or to support an investigation;
• Occupational health providers – to assess your suitability to register and remain working once you are a candidate;
• Providers of criminal background checks – to assess your suitability to remain working once you are a candidate;
• Umbrella companies – to facilitate payment for work completed and to ensure you are being paid correctly;
• Referees – to obtain updated references to assess your suitability to remain working once you are a candidate;
• Regulatory bodies – to ensure you can legally remain practising in your chosen profession; or
• Law Enforcement Agencies – to comply with any requests for access to personal data
• Why is your personal data shared across the Acacium Group of companies?

The personal data you provide will be shared within the Acacium Group. This will enable us to deliver our services to you, increase the number of job opportunities available, and enhance the services offered by the Acacium Group, to ensure that our legal and regulatory obligations are achieved.

5. Which third parties is your personal data shared with?

We will share your personal data with the third parties set out below:

• Providers of criminal record checks;
• Occupational health providers;
• Clients and potential clients (corporate and individuals);
• Our professional advisors, including accountants, solicitors, insurers;
• Training providers;
• Auditors;
• Referees;
• Secondary recruitment agencies, managed services providers and master vendors;
• Third parties who provide operational services for us, for example, payroll providers, IT providers and call centres;
• Regulatory or law enforcement agencies; or
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them

Please notice this list is not exhaustive.

We require that all third parties respect the security of your personal data and adhere to data protection laws. Where we share your personal data with third parties providing operational services to us, we only allow them to process your personal data for specific purposes in accordance with our instructions.

6. How will your data be used for marketing?

We may occasionally send you information that we believe would be of interest to you or provide current advice that is relevant. As a candidate or someone who has shown an interest in working with us, we will occasionally send you information we feel would be of interest to you, help secure you a new role and show you the benefits of working with us.

The types of communication you receive include:

• Questionnaires/Surveys: To gather feedback on services received; opinions may be collected and analysed to improve the quality of services we offer.
• Discounts that could be available to you while working for us;
• Competitions, incentives and promotions;
• Referral schemes;
• Exclusive events and training;
• Charities that we support; or
• Relevant job opportunities from our group companies.

• Clicking on the unsubscribe link at the bottom of any marketing emails we send you
• Emailing us at dpo@acaciumgroup.com

Please note that legal and service updates relating to you working with us are not direct marketing and cannot be opted out of.

We endeavour to respond to your request to stop marketing as soon as possible but this can take up to 28 business days. During this period, you may still receive some marketing communications..

7. Job opportunity messages

We will need to contact you to let you know what job opportunities we have available and to see if you are available for work. As this is not classed as direct marketing, you will not be able to opt-out of receiving this type of communication from the company you are registered with.

8. How long do we keep your personal data for?

We will only keep your personal data for as long as is necessary for the purposes for which it was collected. In order to determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of your personal data and the likelihood of a suitable job opportunity arising. We will also consider whether there are any specific legal or regulatory requirements which require us to keep your personal data for a particular period of time, such as evidence of right to work checks.

9. Will we transfer your personal data outside the United Kingdom?

As a global business, we may transfer your personal data globally within Acacium Group or to third-parties who are outside of the United Kingdom (UK) in connection with the purposes outlined within this privacy policy. This includes the use of both Acacium Group companies and third party companies to assist with administrative activities connected to job roles, including monitoring compliance of agency workers, identifying job/work opportunities as well as finance activities such as credit control and payroll activity. In all instances the actual data accessible by the Acacium Group or third party company remains hosted in our UK data environment, and is accessed via a remote secure link.

Whenever we transfer your personal data outside of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Government; or

• In the absence of an adequacy decision, other legally permitted grounds such as (a) for regular and routine transfers of data the International Data Transfer Agreement or the UK addendum to the EU’s Standard Contractual Clauses; or (b) for non-routine and irregular transfers of data then an appropriate derogation, notably where it is necessary in order to connect you with a particular role and so is necessary in connection with the performance of a contract with you. In the case of (b) this may include circumstances where you are interested in a role with a business that operates globally and where it is necessary to share your CV with a part of their business based outside the UK.  

If you would like further information about the methods used to transfer personal data outside of the EEA, please contact us at dpo@acaciumgroup.com.

10. Our use of artificial intelligence AI

Artificial Intelligence (or “AI”) is a term used for a range of technologies that can replace manual processes and solve complex tasks by carrying out functions that previously required human action.

We may use personal data as part of the development and training phase of an AI solution, for example where it is not possible to use anonymised data.

We use AI to support our existing activities. To use AI, we combine information you have provided to us directly, information we derive about you from your use of our services or your interactions with us, and information from other people and organisations. We use AI for different purposes such as:

• Job Description Review Software: To help us construct, manage, and store job descriptions with text analysis and keyword optimization.
• CV Reformatting: To enhance CV’s for consistency and readability.

• CV Matching: To align job roles with CV skills.

• Chatbot Activity: To manage simple queries and provide guidance.

• Recording: To record data obtained trough media or communications for quality, training, and queries resolution.

• Targeted Social Media Searches: To find potential candidates on social media.

• Qualifying Screening Tools: To screen and rank CVs and personal statements based on criteria set by employers.

Please note that throughout the recruitment process and while you are a candidate you will not be subject to a solely automated decision making, as the final decisions will be taken by humans (albeit based on the outputs produced by AI).

11. How do we safeguard your personal data?

We have implemented appropriate security measures to prevent your personal data from accidental loss, alteration, unauthorised disclosure, or access.

In addition, we limit access to your personal data to only those employees, agents, contractors and other third-parties who have a business need to know. They will only process your personal data on our instructions and subject to the applicable law.

Additionally, we have established procedures to address any suspected personal data breaches and will notify you and any applicable regulators if legally required.

12. What is a cookie and why do we use it?

Cookies are small files that are sent to your device when you visit a website or app. They stay on your device and are sent back to the website or app they came from when you visit it again. For more information about cookies please visit www.allaboutcookies.org. You can control and delete cookies through your browser settings for more information on how to do this please visit www.allaboutcookies.org/manage-cookies.

We use the following cookies on our website:

Type of cookies	Description
Strictly Necessary Cookies	These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
Performance Cookies	These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance.
Functional Cookies	These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function properly.
Targeting Cookies	These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

By default, only Strictly Necessary cookies are active. Strictly Necessary cookies allow the Website to be accessible, and without them some parts of the Website will not work. They are essential for the basic functionalities of the Website to operate.

Performance, Functional or Targeting cookies are disabled by default, but you have the chance to activate them the first time you access the Website in the Cookie banner (by clicking the “Accept all” button or via your customized settings).

We use industry standard cookies, as appropriate, to track your behaviour online and gain statistical information at an aggregated level to monitor the operation of the Website, to improve the Website based on performance and to assess the effectiveness of campaigns.

example, we track the number of visits to the Website, where each visitor came from (i.e. the website you visited prior to coming to the Website) and where each visitor goes to from the Website (i.e. the website you visit after leaving ours).

After you have visited our website we may send you personalised adverts via third-party platforms such as Facebook, Google or LinkedIn. These adverts are delivered to you so we can continue to engage with you and display new opportunities that may be of interest

We use Google Analytics to receive anonymised reports on how long visitors stay on our website, whether they apply for jobs and which of our jobs and web pages are getting the most views and interactions. This information allows us to improve user experience and make sure the content is relevant and interesting

13. Third-Party Cookies

When you use the Website, you may encounter links to third-party websites and/or content from third parties.

The Website may also offer you the opportunity to further engage with us and share information with others using social networks.

The third party content is added to our Website so we can keep you up to date with carefully selected information that you may find relevant or of interest, however this can result in these third-party providers storing additional cookies on your device that we have no control over.

Consequently, we suggest you check the websites of any such third parties and their respective privacy and cookie policies for more information about their cookies and how you can manage them.

Please note however that if you choose to access third party sites through this Website, the cookies we have listed in the previous section may not form an exhaustive list.

14. What rights do you have in relation to your personal data?

You have a number of rights in relation to how we use your information, these are explained in the table below:

Your Rights	Explanation
Your right of access	You have the right to ask us for copies of your personal data. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for.
You right to rectification	You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. We may, however, refuse your request if we consider that the information is accurate having looked into it.
Your right to erasure	You have the right to ask us to delete your personal information. This might not include all your information, particularly if it relates to types of information we are required to keep for certain periods of time (for instance right to work checks).  Please ask if you have any further questions.
Your right to restriction of processing	You have the right to ask us to limit how we can use your personal information, although this is subject to certain limitations.
Your right to object to processing	You have the right to object to the processing of your personal data. This might not apply to all your information. You can inform us of any concerns you have regarding the processing of your data and you have the right to discuss this with us
Your right to withdraw consent	This right arises at any time we are relying on the consent you have provided to us to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide our services to you. We will advise you if this is the case at the time you withdraw your consent.
Your right to data portability	You have the right to ask that we transfer the personal data that you gave us to another organisation, or to you, in certain circumstances.
Your right to not to be subject of automated individual decision-making:	This right provides you with the right to not be subject to a decision that is based solely on automated processing if that decision produces legal or similarly significant effects on the individual. This right also includes the right to be informed about the existence of automated decision making, including profiling, and to receive meaning information about the logic involved, as well as the significance and envisaged consequences of such processing. As explained above, however, although some of our activities are automated they are not used to profile or otherwise make decisions about you.

15. Exercising your rights

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

In most cases we will deal with your request as soon as possible, and at the latest, within one calendar month of your request. If we need more time, we will inform you of this.

To find out more about your personal data rights, click here

Please note that we do not charge for any such requests unless there are exceptional circumstances.

16. How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using our contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

At the ICO’s address

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Calling the ICO’s Helpline number: 0303 123 1113

Or visiting the  ICO’s Website: https://www.ico.org.uk/make-a-complaint

17. Updates of this Policy

We regularly review and update this privacy notice as needed. We recommend that you regularly review this privacy notice to ensure you have the most up to date information.

This privacy notice was last updated on 30/04/2025.