Section 1 – Identity and contact details of controller
For the purposes of applicable data protection legislation, European Telemedicine Clinic, S.L., with registered office at C/ Marina 16-18, Floor 33, 08005 Barcelona, Spain, and Tax Identification Number (NIF): ESB62799689 (hereinafter referred to as "ETMC" and/or "TMC"), acts as the data controller in relation to the processing of your personal data described in this Privacy Notice.
For any questions regarding the processing of your personal data, you can contact:
Email: dpo@unilabs.com
Section 2 – What personal data we collect
TMC processes the following personal data related to the Career Scan Tool:
- Identification and Contact Information: First name, Last name, Email address, Country of residence (where collected)
- Professional Information: Career Scan responses, Personalised career profile results, Professional interests, Medical registration status, Country of medical registration, Communication preferences
- Recruitment and Marketing Preferences: Preferences relating to recruitment opportunities, Consent preferences regarding professional updates, educational content, events, Academy courses and similar communications.
The provision of personal data is voluntary. However, certain information may be necessary for us to generate your Career Scan results or contact you regarding recruitment opportunities.
Section 3 – Purposes of the processing and legal basis
Personal data will be processed for the following purposes and in accordance with the legal basis as set out below:
| Purpose | Legal basis |
|---|
| To administer the Career Scan, process your responses and generate your personalised career profile. | Legitimate interests pursued by TMC in attracting and identifying suitable candidates. |
| To contact you regarding relevant recruitment opportunities with TMC and Unilabs. | Consent |
| To maintain a talent pool of potential candidates for current and future recruitment needs. | Legitimate interests. |
| To send professional updates, educational content, Academy courses, research information and invitations to events where you have chosen to receive them. | Consent. |
| To manage and record your communication preferences and consent choices. | Consent and compliance with legal obligations. |
TMC has a legitimate business interest in attracting, identifying and recruiting qualified radiologists and other healthcare professionals and maintaining a pipeline of potential candidates to support current and future workforce needs.
Where processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.
Section 4 – Source of Personal Data
Personal data is collected directly from you when you voluntarily complete the electronic Career Scan and submit your information. A privacy notice is provided before your personal data is collected.
Section 5 – Profiling or Automated Decision Making
TMC uses automated processing to analyse the responses you provide through the Career Scan and generate a personalised career profile. This constitutes profiling under applicable data protection legislation. The profiling is used solely to provide you with personalised career insights and to assist TMC in understanding potential recruitment interests. No decisions are made solely by automated means that produce legal or similarly significant effects on you.
Section 6 – Categories of recipients of the personal data
Your personal data may be shared with the following categories of recipients:
- Within TMC and its group companies, including authorised personnel within the Human Resources function, Talent Acquisition teams, and hiring managers where necessary for recruitment-related purposes.
- Within Unilabs and its group companies, including authorised personnel within the Human Resources function, Talent Acquisition teams, and hiring managers where necessary for recruitment-related purposes.
- With service providers acting on behalf of TMC, including: Jobvite, for recruitment and applicant management; Brevo, for communications management where you have consented to receive communications; and the supplier responsible for the development, hosting, maintenance, and support of the Career Scan solution.
All such service providers process personal data on behalf of TMC under written contractual arrangements and solely in accordance with TMC's documented instructions.
Section 7 – Data retention period
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it. 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.
When personal data is no longer needed or has reached its retention period it is deleted. Personal data might be kept for a longer period of time where it is necessary in accordance with legal requirements.
| Purpose | Retention period |
|---|
| Recruitment engagement and candidate pool management | We will retain your details in our recruitment talent pool for a maximum of five years following your last interaction with TMC or Unilabs, unless you object to this processing sooner. |
| Professional updates and marketing communications | Until you withdraw your consent, or for a maximum of 5 years following your last interaction with TMC or Unilabs, whichever occurs first. |
| Suppression records following withdrawal of consent | A minimal record may be retained to ensure you are not contacted again. |
Section 8 – Transfer of personal data
TMC tries to ensure that sharing of personal data with recipients, as per Section 6 above, is restricted to the European Economic Area (EEA), where EU General Data Protection Regulation applies, or Your jurisdiction, or to a country that is recognized as granting an adequate level of protection.
However, should Your personal data be transferred to countries whose level of protection of personal data has not been deemed adequate according to the applicable data protection regulations, to ensure an appropriate level of protection to your personal data transferred to those countries, TMC puts in place relevant safeguards such as the signature of data transfer agreements (e.g. standard contractual clauses ('SCCs') issued by the European Commission when GDPR applies).
Such sharing is essentially related to the location and hosting location of service providers we rely on. Please write to the following address if you wish to obtain copies of such contracts and/or more information on this topic: dpo@unilabs.com.
Section 9 – Data subjects rights
In relation to your personal data, you have the following rights:
- Right to object: You can object to TMC processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about Your particular situation which makes you want to object to processing on this basis. Please contact TMC, providing details of your objection.
- Access to your personal data: You can request access to a copy of your personal data that TMC holds, along with information on what personal data TMC uses, why it's used, to who it is shared, how long it is kept and whether it has been used for any automated decision making. You can make a request for access free of charge. In compliance with the GDPR, TMC will respond to a valid subject access request without undue delay and at the latest within one month of receiving the request. In some circumstances, TMC can extend the time to respond by a further two months. For example, when the request is complex. In this case, TMC will notify You within one month of receiving Your access request and explain to You why the extension is necessary.
- Consent: If you provide consent to use personal data, You can withdraw your consent at any time.
- Rectification: You can ask TMC to change or complete any inaccurate or incomplete personal data held about you.
- Erasure: You can ask TMC to delete your personal data where it is no longer necessary for TMC use, You have withdrawn consent, or where TMC has no lawful basis for keeping it. Please be aware that TMC may have legal obligations to retain your data.
- Portability: You can ask TMC to provide You or a third party with some of the personal data that we hold about You in a structured, commonly used, electronic form, so it can be easily transferred.
- Restriction: You can ask TMC to restrict the personal data that is used where You have asked for it to be erased or where You have objected to TMC use of it.
- No automated-decision making: Automated decision-making takes place when an electronic system uses personal data to make a decision without human intervention. You have the right not to be subject to automated decisions that will create legal effects or have a similar significant impact on You, unless (i) You have given us Your consent (ii) it is necessary for a contract between You and TMC, or (iii) is otherwise permitted by law. You also have certain rights to challenge decisions made about you.
Section 10 – Means of exercising
To exercise Your rights please fill out the web form available at this link.
The exercise of Your rights is free of charge.
Section 11 – Right to lodge a complaint with Data Protection Authority (DPA)
If You are unsatisfied with the way in which TMC has handled Your personal data or any privacy query or request that You have raised to TMC and you didn't receive a satisfactory answer from TMC and/or the TMC DPO, You have the right to lodge a complaint with the Data Protection Authority of the Member State of Your habitual residence, place of work or place of the alleged infringement.
The Data Protection Authority of Spain is Agencia Española de Protección de Datos (AEPD).
To find the appropriate contact details of the other European Data Protection Authorities, please visit the EU Commission's directory of Authorities.
For other jurisdictions:
- For UK, find ICO's contact information here.
- For Switzerland, FDPIC here.
Please contact TMC for further help.
