LOCUMLINK ASSOCIATES LIMITED T/A LOCUMLINK HEALTHCARE

GDPR Privacy Policy

INTRODUCTION

This GDPR privacy policy describes how Locumlink Healthcare meets its obligations under the General Data Protection Regulation in relation to the processing of personal data.

This policy statement provides full details on the following;

• How we handle personal data.
• What personal data we collect/hold.
• How and why we collect/hold personal data.
• How we use personal data.
• How we secure personal data.
• What third parties have access to personal data.
• Customers legal rights concerning personal data.

1. PERSONAL DATA COLLECTION

1.1 We may collect and process personal data in the following ways:

• When registering with our business.
• When contacted directly via our websites or via our customer services department to request information about our products and services.
• When working with third-party’s to provide services.
• By requesting a product or a service directly from us.
• By replying to a direct marketing campaign.
• When permitted contact details are transferred from other third parties.
• When permitted companies or business partners transfer personal data to us.
• When permitted personal data is secured via other sources.

Note:

1. Never provide personal data on behalf of someone else unless they have reviewed this Privacy Policy.
2. Persons under 16 years of age should not provide any personal data without consent from a parent or guardian.

Personal data: This is data supplied to us when a data subject, or agency provides personal data via our website/s or our cloud-based platform, or by corresponding with us by phone, email or otherwise, and is provided entirely voluntarily. The data may include a person’s name, contact details (such as phone number, email address and postal address), enquiry details and an opinion of our products.

We may automatically collect personal data from our web servers as part of standard details relating to browser and operating systems, additional personal data may be automatically collected from our website, to include pages visited and the date of visit. Personal data may also be automatically collected for security reasons, e.g. to identify attacks on our website, this may include data relating to the Internet protocol (IP) address assigned by an internet service. We may collect some of this information using cookies – see Cookies in Section 7 for further information. We may also collect personal data that is shared as part of a person’s public profile on a third party social network.

We may also receive certain personal data from other contract agencies and/or recruitment agencies within the Irish Jurisdiction.

This information may include:

Personal data collected from the data subject by recruitment agency and/or other third party. It is a contract requirement to provide all personal data requested on this form, failure to provide such personal data may preclude us from completing the contract. The personal data collected may include a person’s name, postal address, contact information, telephone number, email address, or any other personal information.

Please see Section 2 for further details outlining how we use personal data and for details of the purposes for which we use the personal data we obtain from these sources and the legal basis on which we rely to process such information. The remaining provisions of this policy also apply to any personal data we obtain from these sources.

2. HOW PERSONAL DATA MAY BE USED

Use of personal data under EU data protection laws must be justified under one of a number of legal grounds and we are required to set out the grounds in respect of each use in this policy. An explanation of the scope of these grounds is listed below:

2.1 Where valid consent is provided

We may use and process personal data where consent is agreed for the following purposes. (Please note that consent will be agreed via a consent form in relation to any such use and may be withdrawn at any time. Please see withdrawing consent in Section 6 for further details).

• to contact via email, text message, post or telephone with marketing information or for other products and services we provide.
• to share personal data with our authorised agents/partners for the purposes of filling recruitment vacancies/posts.
• to supply brochures and other materials specifically requested from us.
• to share personal data with our authorised agents/partners or our recommended third-party partners to provide marketing/recruitment information about their products and services.

2.2 Where we are required to perform a contract

We may use and process personal data where it is necessary for the performance of a contract.

2.3 Where required to comply with Legal Obligations

We may use personal data to comply with our legal obligations in, (a) assisting an Garda Síochána, or any other public authority or statutory authority for the purposes of criminal or other related investigations, (b) so as to enable legitimate identification in complying with our legal obligations, and (c) to verify the accuracy of the data that we hold.

2.4 Where there is a Legitimate Interest

We may use and process personal data where it is necessary for us to pursue our legitimate interests as a business, and where our reasons for using it outweigh any prejudice to data protection rights, as follows:

• for market research in order to ensure continued improvements in the products and services that we provide.
• to administer our websites and for internal operations, including troubleshooting, testing, statistical purposes.
• for analysis, and profiling to inform our marketing strategy, and to enhance and personalise a customer or visitor experience.
• for marketing activities (other than where we rely on consent) e.g. to tailor marketing communications or send targeted marketing messages via social media and other third-party platforms.
• for the prevention of fraud and other criminal activities.
• to correspond and communicate in legitimate matters.
• for network and information security in order for us to take steps to protect data against loss or damage, theft or unauthorised access.
• to comply with a request in connection with the exercise of a person’s rights, e.g. where we are asked not to contact a person for marketing purposes.
• for reviews, accuracy or other improvements of our databases and IT /cloud based platform systems, e.g. by combining systems or consolidating records we or our group companies hold.
• to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings.
• for general administration including managing queries, complaints, or claims and to send service messages to our customers.

3. THIRD PARTIES WHO MAY PROCESS PERSONAL DATA

3.1 Healthcare Service Providers

We may share data with other Healthcare Service Providers. These Companies may use personal data in similar ways to that outlined in Section 2 of this policy document.

Our cloud based platform/websites may also contain personal data supplied from third parties for the purposes of recruitment processing activities. Third party agencies who operate/use our cloud based platform for the purpose of logging personal data acknowledge that we will transfer this data to healthcare service providers.

When we use social plug-ins on our websites from social networks such as Facebook, Twitter, Instagram, and Google+, we integrate them as follows:

Social plug-ins are deactivated on our websites (i.e. no data is transmitted to the operators of these networks). To use one of these networks, click on the respective social plug-in to establish a direct connection to the server of the respective network.

A user account holder on the network, who has activated the social plug-in, can be associated to the network visit to our websites/cloud based platform.

When a social plug-in is activated, the network transfers the content that becomes available directly to the user’s browser, which integrates it into our websites. In this situation, data transmissions can also take place that are initiated and controlled by the respective social network. Connection to a social network, the data transfers taking place between the network and a user system, and user interactions on that platform are governed solely by the privacy policies of that network.

The social plug-in remains active until deactivated or deleted in cookies.

3.2 Contracted suppliers and Healthcare service providers

We may disclose personal data to our third-party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to a customer on our behalf. Such third parties may include cloud services providers (such as hosting and email management) or advertising agencies, administrative services or other third parties who provide services to us.

When we use third party service providers, we only disclose to them any personal data that is necessary for them to provide their service and we commit to ensuring valid Data Protection Agreements are in place with all third parties so as to ensure all personal data is secure and only used in accordance with our specific contract terms and conditions.

3.3 Third parties who provide products and services

Personal data which we collect may be transferred to third parties with customer consent.

Such data is shared in a secure manner, using a consistent security protocol. When we share data with other parties we ensure that they only use the data for the purpose it was collected.

4. STORAGE OF PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)

Data provided to us may be transferred to countries outside the EEA. By way of example, this may happen where any of our group companies are incorporated in a country outside of the EEA or if any of our servers or those of our third-party service providers are from time to time located in a country outside of the EEA. These countries may not have similar GDPR data protection laws.

If we transfer data outside of the EEA in this way, we will ensure that appropriate security measures are taken with the aim of ensuring that data privacy rights continue to be protected as outlined in this policy. These steps include imposing contractual obligations on the recipient of personal data or ensuring that the recipients are subscribed to ‘international frameworks’ that aim to ensure adequate protection of personal data.

The use of our services whilst outside the EEA, may involve the onward transfer of data outside the EEA in order to provide those services.

5. HOW LONG DO WE KEEP PERSONAL DATA

When we collect/receive personal data, the length of time we retain it is determined by a number of factors including the purpose for which we use that data and our obligations under GDPR and related laws. We do not retain personal data for longer than is necessary.

We may need personal data in the bringing or in defence of a legal claim, in which case we will retain personal data for a period of seven years after the last occasion on which we have used the personal data as specified in Section 2 of this policy document.

The only exceptions to this are; (a) where the law requires us to hold personal data for a longer period or (b) when requested to have the data deleted if we do not need to hold it in connection with any of the reasons permitted in Section 6 of this policy document.

6. DATA SUBJECTS RIGHTS

6.1 Rights as a ‘Data Subject’

A data subject, has the right of access (Art. 15 GDPR), right to rectification (Art. 16 GDPR), right to erasure (Art. 17 GDPR), right to restriction of processing (Art. 18 GDPR) and right to data portability (Art. 20 GDPR). A person’s rights as a Data Subject include the following:

1. Information on the type of personal data we hold and what we do with that information.
2. To request how long we hold personal data.
3. Rectify any inaccurate personal data we hold.
4. To erase personal data we hold.
5. Prevent us from using personal data in certain cases, including if you believe that the personal data we hold is inaccurate, or our use of personal data is unlawful.
6. To receive personal data in a structured, commonly used and machine-readable format and to have that data transmitted to another data controller.

The right of consent to the processing of personal data by us may be revoked at any time. The legality of processing personal data before revocation remains unaffected. We may further process such data pursuant to another applicable legal basis, e.g. for the fulfilment of our legal obligations.

A data subject has the right to object at any time to the processing of personal data (Art 21 GDPR). In such circumstances we will only process personal data if we can prove compelling legitimate reasons that outweigh a person’s interests, rights and freedoms, or for the establishment, exercise or defence of a legal claim.

If a person believes that the processing of personal data violates legal requirements, that person has the right to lodge a complaint with the Offices of the Data Protection Commissioner (Art. 77 GDPR).

7. SECURITY / COOKIES / LINKS / SOCIAL PLUGINS

We at all times use technical and organisational security measures to protect the personal data supplied and managed by us against manipulation, loss, destruction and access by third parties. Our security measures are continually improved in line with technological developments.

Unfortunately, the transmission of data via the internet is not completely secure. We will do our utmost to protect personal data, however we cannot guarantee the security of all data whilst in transit to our website, transmission is at the user’s own risk.

Where we have given (or where chosen) a password which enables access to an account, the user is responsible for keeping this password confidential. Do not share this password with any other person.

7.1 Use of 'cookies'

By clicking on to a link of an offer or by activating a social plug-in, personal data may reach providers in countries outside the European Economic Area (EEA) that, from the point of view of the European Union ("EU"), may not guarantee an "adequate level of protection" for the processing of personal data in accordance with EU standards. Please be aware of this alert before clicking on a link or activating a social plug-in and thereby triggering a transfer of data.

7.2 Statement on the use of cookies, the analysis of usage data and the use of analysis

We use cookies and similar software tools such as HTML5 Storage or Local Shared Objects (together "cookies") to identify a person’s interests and particularly popular areas of our websites and use this data to improve the design of our websites and make them even more user-friendly. For the same purposes we use the analysis tools Adobe Analytics and Google Analytics, cookies may also be used here.

7.3 Functions and use of cookies

Cookies are small files that are placed on a desktop, notebook or mobile device by a website visited. From this we can, for example, recognise whether there has already been a connection between a device and our websites, or which language or other settings the user prefers. Cookies may also contain personal data.

By using our cloud based platform/websites, the user agrees to the use of cookies.

A user may visit our website without consenting to the use of cookies. The user can refuse such use and delete cookies at any time by making the appropriate settings on the user’s device.

7.4 Links to other websites

Our website may contain links to other websites run by other organisations which we do not control. This policy does not apply to such websites and Apps so we encourage reading of their privacy statements. We are not responsible for the privacy policies and practices of other websites and Apps (even to those using links that we provide) and we provide links to those websites solely for user information and convenience. We specifically disclaim responsibility for their content, privacy practices and terms of use, and we make no endorsements, representations or promises about their accuracy, content or thoroughness. Disclosure of personal data to third party websites is at the user’s own risk.

In addition, if linked to our website from a third-party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party website and recommend that all users check the policy of all third-party websites.

7.5 Social plugins

We use so-called social plugins (buttons) of social networks such as Facebook, Google+ and Twitter.

When visiting our website, these ‘buttons’ are deactivated by default, i.e. without intervention they will not send any data to the respective social networks. These ‘buttons’ are activated by clicking on them. They remain active until deactivated or deleted.

After their activation, a direct link to the server of the respective social network is established. The contents of the ‘button’ are then transmitted from the social network directly to the user’s browser and incorporated in the website.

After activation of a ‘button’, the social network can retrieve data, independently of whether interaction with the ‘button’ took place. When logged on to a social network, the network can assign a visit to the website of the user account. A social network cannot assign a visit to websites operated by our other group companies unless and until activation.

8. Newsletter

Data provided in subscribing to a newsletter offered on our website will only be used in order to provide the newsletter, unless agreed for further use. Subscription to the newsletter can be withdrawn at any time using the unsubscribe option provided.

9. Contact Us

Customers may contact our offices with any questions or suggestions regarding the processing of personal data or if they wish to amend/update their personal data, please contact the offices of;

Locumlink Healthcare
32 Ranelagh Road,
Ranelagh,
Dublin
D06 Y027

At Locumlink Healthcare, we recognize our responsibility to reduce our environmental impact and contribute to a sustainable future. As a leading healthcare recruitment agency, we are committed to achieving Net Zero carbon emissions by 2050.

Our Approach to Net Zero

To reach this goal, we are implementing a practical, science-based strategy that focuses on:

1. Measuring & Reducing Our Carbon Footprint

Conducting a comprehensive carbon audit of our operations.

Reducing energy consumption in our offices by switching to renewable energy sources.

Encouraging remote work and digital recruitment solutions to cut down on travel-related emissions.

2. Sustainable Business Practices

Minimizing paper use by transitioning to fully digital processes.

Partnering with eco-conscious suppliers for office materials and technology.

Encouraging our clients and candidates to engage in sustainable healthcare practices.

3. Offsetting Remaining Emissions

Investing in certified carbon offset programs, such as reforestation and renewable energy projects.

Supporting local environmental initiatives that align with our values.

Holding Ourselves Accountable

We will track and report our progress annually, adjusting our strategies to ensure we stay on course. Transparency is key, and we will share updates with our stakeholders, including candidates, clients, and employees.

By embedding sustainability into our core operations, we aim to make a positive impact on both the healthcare sector and the planet. Together, we can build a healthier and greener future.

Join Us on Our Journey

If you’d like to learn more about our Net Zero strategy or collaborate with us on sustainability initiatives, please get in touch at info@locumlink.ie

Locumlink Healthcare is committed to achieving Net Zero omissions by 2050. Our goal is to formally declare 2025 our formal baseline year. As you will see, we have been on this journey for several years already but will commence the process of documenting formally in 2025.

We continuously focus on practical steps that Locumlink Healthcare can take to minimize its carbon footprint and improve sustainability practices in its operations. The focus will be on reducing energy consumption, improving travel practices, and adopting green recruitment technologies.

Company Overview:

Locumlink Healthcare provides recruitment services to healthcare providers, specializing in placing qualified healthcare professionals in hospitals, clinics, and medical facilities. As part of our commitment to environmental sustainability, we are implementing this Carbon Reduction Plan to minimize our carbon footprint, improve energy efficiency, and create a sustainable environment for both our employees and clients.

Details of completed carbon reduction plans to date

• 100% technology-based
• Elimination of paper over 25+ years; went from 100% paper, manual operation to 100% tech-enabled, electronic operation
• Candidates have access to app for day-to-day management of shifts with Head office support by phone as needed
• Significant reduction in travel since 2019 (down 90%) as we conduct all client meetings online with exceptional visits to sites where required
• ISO 9001: 2015 accredited

Here is an overview of progress to-date:

1. Reducing Head Office Energy Consumption

Objective: Decrease energy usage in office spaces and reduce emissions associated with electricity consumption.

• Switch to Energy-Efficient Lighting: Replace all incandescent bulbs with LED lights to reduce electricity usage by up to 80%. Completed
• Install Smart Thermostats: Implement smart thermostats to optimize heating and cooling, reducing unnecessary energy consumption.Status: Completed
• Encourage Power Off Policy: Employees will be encouraged to turn off lights, computers, and other office equipment when not in use. Status: Completed
• Use Renewable Energy Sources: Where possible, switch to energy suppliers that use renewable energy sources (e.g., wind or solar) Status: Constantly under review
• Conduct Energy Audits: Perform regular energy audits to identify areas of energy wastage and implement improvements.Status: Constantly under review

Target: Measure and monitor consumption in baseline year 2025 with the objective to reduce office energy consumption going forward (figure to be defined)

2. Reducing Travel-Related Emissions

Objective: Minimize the carbon footprint associated with employee commuting and business-related travel.

• Encourage Remote Work: Where feasible, continue to allow remote working arrangements, reducing the need for commuting. Completed
• Support Use of Public Transport: Offer subsidies or reimbursements for employees who use public transportation to get to work. Status: Constantly under review
• Promote Carpooling and Bike Usage: Set up a carpooling program and encourage employees to bike to work by offering bike storage facilities and incentives.Status: Constantly under review
• Limit Business Travel: Shift to virtual meetings for interviews, client meetings, and other events whenever possible. Completed - Meet in person when necessary and required for business relationships.
• Offset Carbon Emissions from Travel: For essential business travel, purchase carbon offsets to mitigate the environmental impact.

Target (TBC) following evaluation in baseline year 2025: Achieve a 20% reduction in carbon emissions from business-related travel over the next two years.

3. Sustainable Recruitment Practice

Objective: Adopt recruitment practices that promote sustainability and reduce the environmental impact of recruitment processes.

• Digital Interviewing: Promote the use of video conferencing tools for interviews, reducing the need for travel and paper-based processes. Status: Constantly under review - Pls note: Compliance of candidates sometimes requires meeting in person, e.g. Garda Vetting requirements
• Cloud-Based Software: Use cloud-based platforms for data storage, minimizing the need for physical paperwork and reducing energy consumption related to on-site servers. Status: Completed
• Paper Reduction: Move all documents related to recruitment (CVs, candidate forms, job listings) to digital platforms, reducing paper usage. Status: Completed
• Green Certifications for Clients: Encourage clients to adopt green practices in their own recruitment processes and workplaces, including promoting sustainability in healthcare settings. Status: Constantly under review
• Promote Green Job Opportunities: Actively seek and highlight healthcare facilities or roles that emphasize sustainability in their operations. Status: Constantly under review

Target: Further eliminate – if possible - paper use in recruitment processes by the end of the first year. We believe we have achieved maximum reduction but will continue to monitor.

4. Waste Management and Recycling

Objective: Minimize waste generated from office activities and promote recycling.

• Office Waste Reduction: Reduce office waste by encouraging employees to bring reusable containers, avoid single-use plastics, and recycle paper, cans, and bottles. Status: Completed
• Implement a Recycling Program: Set up separate bins for recyclable materials such as paper, plastics, and e-waste in the office. Status: Completed
• Sustainable Office Supplies: Transition to using eco-friendly office supplies (e.g., recycled paper, biodegradable cleaning products). Status: Constantly under review
• Electronic Waste Disposal: Partner with a certified e-waste recycling company to dispose of old electronics responsibly. Status: Completed

Target: Achieve further reductions in office waste within the first year, following assessment.

5. Employee Engagement and Training

Objective: Raise awareness and encourage employees to actively participate in the agency's sustainability efforts.

• Sustainability Training: Provide training on sustainable practices, carbon reduction techniques, and the importance of reducing carbon footprints. Status: Constantly under review
• Employee Carbon Footprint Tracking: Offer tools or apps that allow employees to track their carbon footprint and reward those who make significant reductions. Status: Researching
• Green Committee: Establish a Green Committee to oversee and promote sustainability initiatives, including monthly meetings to assess progress and brainstorm new ideas. Status: Constantly under review

Target: Engage 80% of employees in sustainability initiatives within the first six months.

6. Partnerships and Advocacy

Objective: Build partnerships with organizations that focus on sustainability, and advocate for green practices within the healthcare recruitment sector.

• Partner with Sustainability-Focused Clients: Actively pursue partnerships with healthcare facilities and organizations that prioritize sustainability in their operations. Status: Constantly under review
• Advocate for Green Policies in Healthcare: Work with industry leaders to promote sustainability in healthcare recruitment practices. Status: Constantly under review
• Support Green Charities and Causes: Dedicate a percentage of profits each year to support environmental organizations and initiatives that promote sustainability. Status: Researching

Target: Form at least two strategic partnerships with sustainability-driven healthcare providers in the next year.

7. Carbon Footprint Measurement and Reporting

Objective: Continuously monitor and measure the carbon footprint to assess the effectiveness of the plan.

• Baseline Carbon Footprint Assessment: Conduct an initial carbon footprint assessment to measure the agency’s baseline emissions across all operations. Status: 2025 goal
• Regular Reporting: Provide quarterly reports on carbon emissions, progress towards reduction targets, and any challenges faced. Agreed
• Continuous Improvement: Regularly assess and refine the carbon reduction plan based on new technologies, employee feedback, and industry developments. Agreed

Target: Achieve a 25% reduction in overall carbon emissions within two years of implementing the plan.

Conclusion:

This Carbon Reduction Plan outlines practical steps for Locumlink Healthcare to reduce its carbon footprint and become a more environmentally responsible business. By focusing on energy efficiency, sustainable recruitment practices, reducing travel emissions, and engaging employees, the agency will play a key role in promoting sustainability in the healthcare recruitment sector.

Introduction

Locumlink Healthcare is committed to the highest standards of openness, probity and accountability.

An important aspect of accountability and transparency is a mechanism to enable staff and other members of the Company to voice concerns in a responsible and effective manner. It is a fundamental term of every contract of employment that an employee will faithfully serve his or her employer and not disclose confidential information about the employer’s affairs. Nevertheless, where an individual discovers information which they believe shows serious malpractice or wrongdoing within the organisation then this information should be disclosed internally without fear of reprisal, and there should be arrangements to enable this to be done independently of line management (although in relatively minor instances the line manager would be the appropriate person to be told).

The Public Interest Disclosure Act, gives legal protection to employees against being dismissed or penalised by their employers as a result of publicly disclosing certain serious concerns. The Company has endorsed the provisions set out below to ensure that no members of staff should feel at a disadvantage in raising legitimate concerns.

It should be emphasised that this policy is intended to assist individuals who believe they have discovered malpractice or impropriety. It is not designed to question financial or business decisions taken by the Company nor should it be used to reconsider any matters which have already been addressed under harassment, complaint, disciplinary or other procedures.

Scope of Policy

This policy is designed to enable employees of the Company to raise concerns internally and at a high level and to disclose information which the individual believes shows malpractice or impropriety. This policy is intended to cover concerns which are in the public interest and may at least initially be investigated separately but might then lead to the invocation of other procedures e.g. disciplinary. These concerns could include:

• Financial malpractice or impropriety or fraud
• Failure to comply with a legal obligation or Statutes
• Dangers to Health & Safety or the environment
• Criminal activity
• Improper conduct or unethical behaviour
• Attempts to conceal any of these

Safeguards

Protection - this policy is designed to offer protection to those employees of Locumlink Healthcare who disclose such concerns provided the disclosure is made:

• in good faith
• in the reasonable belief of the individual making the disclosure that it tends to show malpractice or impropriety and if they make the disclosure to an appropriate person (see below). It is important to note that no protection from internal disciplinary procedures is offered to those who choose not to use the procedure. In an extreme case, malicious or wild allegations could give rise to legal action on the part of the persons complained about.

Confidentiality - Locumlink Healthcare will treat all such disclosures in a confidential and sensitive manner. The identity of the individual making the allegation may be kept confidential so long as it does not hinder or frustrate any investigation. However, the investigation process may reveal the source of the information and the individual making the disclosure may need to provide a statement as part of the evidence required.

Anonymous Allegations - this policy encourages individuals to put their name to any disclosures they make. Concerns expressed anonymously are much less credible, but they may be considered at the discretion of the Company. In exercising this discretion, the factors to be taken into account will include:

• The seriousness of the issues raised
• The credibility of the concern
• The likelihood of confirming the allegation from attributable sources

Untrue Allegations - If an individual makes an allegation in good faith, which is not confirmed by subsequent investigation, no action will be taken against that individual. In making a disclosure the individual should exercise due care to ensure the accuracy of the information. If, however, an individual makes malicious or vexatious allegations, and particularly if he or she persists with making them, disciplinary action may be taken against that individual.

Procedures for Making a Disclosure

On receipt of a complaint of malpractice, the member of staff who receives and takes note of the complaint, must pass this information as soon as is reasonably possible, to the appropriate designated investigating officer as follows:

Complaints of malpractice will be investigated by the appropriate Director unless the complaint is against the Director or is in any way related to the actions of the Director. In such cases, the complaint should be passed to the Chief Executive / Business Owner for referral.

In the case of a complaint, which is any way connected with but not against the Director, the Chief Executive / Business Owner will nominate a Senior Manager or external party to act as the alternative investigating officer.

Complaints against the Chief Executive / Business Owner should be passed to the Chairman who will nominate an appropriate internal / external investigating officer.

The complainant has the right to bypass the line management structure and take their complaint direct to the Chairman (or Business Owner). The Chairman (or Business Owner) has the right to refer the complaint back to management if he/she feels that the management without any conflict of interest can more appropriately investigate the complaint.

If there is evidence of criminal activity then the investigating officer should inform the police. The Company will ensure that any internal investigation does not hinder a formal police investigation.

Timescales

Due to the varied nature of these sorts of complaints, which may involve internal / external investigators and / or the police, it is not possible to lay down precise timescales for such investigations. The investigating officer should ensure that the investigations are undertaken as quickly as possible without affecting the quality and depth of those investigations.

The investigating officer, should as soon as practically possible, send a written acknowledgement of the concern to the complainant and thereafter report back to them in writing the outcome of the investigation and on the action that is proposed. If the investigation is a prolonged one, the investigating officer should keep the complainant informed, in writing, as to the progress of the investigation and as to when it is likely to be concluded.

All responses to the complainant should be in writing and sent to their home address marked “confidential”.

Investigating Procedure

The investigating officer should follow these steps:

• Full details and clarifications of the complaint should be obtained.
• The investigating officer should inform the member of staff against whom the complaint is made as soon as is practically possible. The member of staff will be informed of their right to be accompanied by a trade union or work colleague at any future interview or hearing held under the provision of these procedures. At the discretion of the investigating officer and dependant on the circumstances of the complaint an alternative representative may be allowed e.g. the individual’s legal representative.
• The investigating officer should consider the involvement of the Company auditors and the Police at this stage and should consult with the Chairman / Chief Executive / Business Owner if appropriate
• The allegations should be fully investigated by the investigating officer with the assistance where appropriate, of other individuals / bodies.
• A judgement concerning the complaint and validity of the complaint will be made by the investigating officer. This judgement will be detailed in a written report containing the findings of the investigations and reasons for the judgement. The report will be passed to the Chief Executive, Chairman or Business Owner as appropriate.
• The Chief Executive / Chairman / Business Owner will decide what action to take. If the complaint is shown to be justified, then they will invoke the disciplinary or other appropriate Company procedures.
• The complainant should be kept informed of the progress of the investigations and, if appropriate, of the final outcome.
• If appropriate, a copy of the outcomes will be used to enable a review of Company procedures.

If the complainant is not satisfied that their concern is being properly dealt with by the investigating officer, they have the right to raise it in confidence with the Chief Executive / Business Owner / Chairman, or one of the designated persons described above.

If the investigation finds the allegations unsubstantiated and all internal procedures have been exhausted, but the complainant is not satisfied with the outcome of the investigation, Locumlink Healthcare recognises the lawful rights of employees and ex-employees to make disclosures to prescribed persons or body (e.g. the Health and Safety Executive). A full list of prescribed people and bodies can be found on the Government Website (www.gov.uk).

At Locumlink Healthcare, we are committed to fostering an inclusive, equitable, and diverse environment where all individuals feel valued, respected, and empowered to reach their full potential. We recognize that diversity in backgrounds, perspectives, and experiences enhances innovation, strengthens our community, and drives sustainable success.

Our Commitment to Equity: We strive to ensure fair treatment, access, opportunity, and advancement for all individuals while actively identifying and eliminating barriers that have prevented full participation. Our policies and practices are designed to promote equal opportunities and address systemic inequalities.

Our Commitment to Diversity: We celebrate and embrace the differences that make each person unique, including but not limited to race, ethnicity, gender, sexual orientation, age, disability, religion, socioeconomic status, and cultural background. We believe that diverse teams drive creativity and excellence.

Our Commitment to Inclusion: We cultivate an environment where all voices are heard, respected, and valued. We encourage open dialogue, active listening, and collaboration to create a culture of belonging. Inclusion is not just about representation; it is about ensuring meaningful participation and contribution from everyone.

Our Actions:

• Implementing policies and programs that support diversity, equity, and inclusion across all levels of our organization.
• Providing training and development opportunities to build awareness and foster an inclusive culture.
• Actively recruiting, retaining, and promoting individuals from diverse backgrounds.
• Partnering with organizations and communities that share our commitment to ED&I.
• Regularly reviewing our progress and holding ourselves accountable to continuous improvement.

We believe that our commitment to ED&I strengthens our organization and contributes to a more just and equitable society. We invite all individuals to join us in fostering a culture where everyone can thrive.

Introduction

This document provides guidelines for resolution and the treatment of complaints made by our customers and staff.

Policy Statement

At Locumlink Healthcare, we believe that if a customer wishes to file a complaint or express dissatisfaction, it should be easy for them to do so. It is Locumlink’s policy to receive complaints and consider them as an opportunity to learn, adapt, improve and provide a better service.

In addition, where possible, a quick resolution of complaints, in a way that respects and values the feedback, can be one of the most important factors in recovering the confidence about the service offered by the company.

Purpose

This policy is intended to ensure that Locumlink Healthcare handles complaints fairly, efficiently and effectively. The company’s objective is to ensure that its complaints procedure is properly and effectively implemented.

What is a complaint?

A complaint is any expression of dissatisfaction about the service or staff offered by Locumlink Healthcare.

Who can make a complaint?

Anyone who has used the services of Locumlink or any service user in which Locumlink has supplied staff to.

Time limit for making a complaint:

A complaint must be filed within 6 months of the incident, or within 6 months of the complainant becoming aware of the incident.

The time limit shall not apply if Locumlink is satisfied that the complainant had good reasons for not making the complaint within the time limit and, notwithstanding the delay, it is still possible to investigate the complaint effectively and fairly.

If we do not see a good reason for the delay or we think it is not possible to properly consider the complaint or any part of it, we will write to the person making the complaint to explain this.

Procedure for Making a Complaint

If possible, depending on the nature of the complaint, we believe it is best to deal with things as soon as possible and in the easiest and most direct way.

If you have a complaint relating to the service that Locumlink is offering, we advise you to raise it with the person you deal with on a day-to-day basis by phone or email. This will allow us to resolve the issue for you there and then or, where possible, have it resolved within 5 working days.

If the complaint is relating to an agency staff member and a formal complaint is being made, then below steps should be followed:

The complaint can be received by phone in the initial stages but must also be submitted in writing so it can be accurately logged and to ensure that there is no misunderstanding on the complaint being made.

We can be contacted directly by phone to our Support Centre on 01-4956666 and followed up with an email to complaints@locumlink.ie.

What should be included in the complaint:

• State the name of the person whom the complaint is being against.
• The date / time / location name and ward the person worked on
• List your specific concerns starting with the most important concern
• Advise what you are hoping to achieve (for example, a response from the agency staff member, restriction from ward/restriction from location or shift time, explanation of what occurred on date/time or if a detailed written response is required from the staff member, etc.)
• State your preferred method of communication: it will assist the Complaints Officer if extra information and/or copies of relevant documents are attached to your complaint.

Investigation

On receipt of a written or verbal complaint the investigating officer must:

1. Provide written acknowledgment to the complainant within 5 working days. If this is not feasible, do so as soon as reasonably practicable.
2. Ensure that the complaint is logged on the client account and if the complaint is staff related that it is also logged on the candidate events log. A complaint will remain open until it has been fully investigated and resolved and both parties are happy with the outcome.
3. If a complaint is staff related, then the person in question must be contacted by phone to advise of the complaint and the outcome of that call logged on the event log. If it is a written complaint, then they can also be issued with the written complaint received from the client to allow a response which will then be sent to the client for their records.
4. A full response, unless there are exceptional circumstances, will be provided within 10 working days. Should additional time be necessary, the complainant will be informed and given an explanation for the delay.

Upon receiving your complaint, we will inform you who is handling it. If your complaint is straightforward, we will usually ask somebody from our support team to look into it straight away and get back to you within 24 hours.

In some cases, if the complaint is more serious and cannot be dealt with at the point of contact, we will escalate this to the Complaints Officer. We will set out to you our understanding of your complaint and ask you to confirm that we have got it right. We will also ask you to tell us what outcome you are hoping for.

If the complaint has been received in writing and requires a response from the agency staff placed in your service by Locumlink, we will need to forward that complaint to them by email so they can provide a detailed response to the complaint being made.

We will aim to resolve concerns as quickly as possible and expect to deal with the vast majority within 10 working days.

If your complaint is more complex, we will let you know within this time why we think it may take longer to investigate and tell you how long we expect it to take. We will give you regular updates on any progress made.

The person who is investigating your complaint will aim first to establish the facts. The extent of this investigation will depend on the complexity and the seriousness of the issues that you have raised. In complex cases, we will draw up an investigation plan. In some instances, we may ask you to meet to discuss the complaint in more detail.

Locumlink will keep a record of all communication relating to any complaint. This will be held on our client and candidate file and can be reported on any time in the future if required. All communication received in relation to any complaint will be shared with our client and if appropriate will be shared with the candidate to whom the complaint is being made against. Where a complaint cannot be dealt with at a local level and is escalated to HSE HR, all records held in relation to the complaint will be shared with HR Shared Services, National HR.

Overview of Communications Protocol, Resolution Process Summary, Escalation Process Summary, Reporting Process

1. Maintain a dedicated channel specifically for serious complaints to ensure that they are handled separately from regular feedback or inquiries. This includes ensuring that key stakeholders are appropriately informed of process, progress and outcomes, including HR Shared Services and National HR, where appropriate.
2. Upon receiving a serious complaint, promptly acknowledge the receipt to the complainant. Provide clear information on the next steps and the expected timeline for resolution.
3. Assign Complaint Handler - provide details to users and provide suitable contact details.
4. Investigate the complaint to gather all relevant information and perspectives. This may involve speaking with the complainant, any parties involved, and reviewing any supporting documentation or evidence. Ensure confidentiality throughout the investigation process.
5. Keep the complainant informed about the progress of the investigation. Provide updates on the steps being taken, any findings or conclusions, and the estimated timeframe for resolution.
6. Assess the situation.
7. Take appropriate action.
8. Inform the complainant about the outcome of the investigation and the actions taken. Explain the rationale behind the decision and provide any necessary instructions or support.
9. Confirm the outcome with other defined stakeholders as necessary.