reach24's Privacy Policy
Our promise to you:
When you use reach24, you trust us with your personal data. We are committed to keeping that trust. That starts with helping you understand our privacy practices.
We ask that you read our privacy practices carefully as it contains important information on who we are, the types of personal data we collection, how it is used and shared and your rights in relation to this data.
This notice applies to users of reach24’s services anywhere in the world, including users of reach24’s Apps, Websites, features, or other services.
Effective date: 1st September 2020
Introduction
reach24 (“we”, “us”) act as data controller for the purpose of e-privacy laws applicable in the United Kingdom (the “Data Protection Law”). Through our site: https://www.reach24.co.uk (the “platform”), we operate a marketplace for Clients and temporary workers to find each other. We are registered with Information Commissioner’s Office and our registration number is A8706448.
Our contact details:
Reach24 Limited
Television House
269 Field end Road
London HA4 9XA
This policy specifically applies to:
Clients: anyone who uses reach24's platform to avail the services of Temporary Workers
Temporary Workers: anyone who registers on the platform with the intention of taking up Temporary assignments
Referees: anyone who provides references (personal, professional, Trade, etc)
Suppliers: anyone who supplies to reach24
Visitors: anyone who visits the reach24 website with an intention to use the services
This notice also governs reach24’s other collections of personal data in connection with reach24’s services. For example, we may collect other personal data in connection with our mapping technology and features.
Types of personal data we collect and use
All those subject to this notice is referred to as “users” in this notice.
1. Data provided by users. This includes:
• User profile: We collect data when users create or update their reach24 accounts. This may include their name, email, phone number, login name, and password, address (including previous addresses), profile picture, payment, or banking information (including related payment verification information), IP addresses, etc.
• Background check and identity verification: We collect background checks and identity verification information for Workers and Clients. This may include information such as your official and maiden names, gender, photographs, Criminal Record checks, professional, personal, or trade references, check from professional bodies (e.g., from NMC for Nurses to validate their eligibility to practice). We may use government identification documents, such as Right to work documents like Passports and images, National or Biometric ID cards, Birth Certificates, National Insurance Numbers, birthdate, signature, and photo. We may use the photos and ID documents submitted by users to verify their identities, such as through facial recognition technologies, Screenshot of verification video calls, etc. For more information, please see the section titled “How we use personal data.”
• Career and education data: we collect information and supporting documentation including academic and professional qualifications, training, competencies, employment history and references, and indemnity insurance cover.
• Demographic data: We may collect demographic data about users, including through user surveys.
• User content: we collect the information users submit when they contact reach24 customer support, provide ratings or compliments for users or workers. This may include feedback, photographs, or other recordings collected by users.
Special Categories of Data: We may collect the following special categories of Personal Information about you:
• occupational health information including vaccination/immunisation status and history ("Occupational Health Data")
• the identity of your professional indemnity insurer which may indicate trade union membership ("Trade Union Data"); and
• where a photographic ID is provided (for example by way of a copy of your passport, driving licence or other photographic ID documents) an inference may be made as to your race, ethnicity, and/or religious beliefs ("ID Data").
2. Data created during the use of our services. This includes:
• Location data: We collect precise or approximate location data from a user’s mobile device if enabled by the user to do so. For Temporary Workers, reach24 collects this data when the reach24 app is running in the foreground (app open and on-screen) or background (app open but not on-screen) of their mobile device. reach24 uses location data to create login and log out times for Agency Workers and autogenerate timesheets. Agency workers may use the reach24 app without enabling location data to prevent reach24 from collecting location data from their mobile devices. However, this may affect some functionality available in the reach24 apps. For example, a Temporary worker who has not enabled location data collection will have to manually enter their login and logout times to create their timesheets while on assignments.
• Transaction information: We collect transaction information related to the use of our services, including the type of services requested or provided, order details, delivery information, date and time the service was provided, amount charged, distance travelled, and payment method.
• Usage data: We collect data about how users interact with our services. This includes data such as access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and third-party sites or services used before interacting with our services.
• Device data: We may collect data about the devices used to access our services, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion data, and mobile network data.
• Services Data: includes information about how you use our services, details of which services you have received from us, choices you have made on the Platform (including, for example, settings and favourite IHPs), information as to Vacancies posted and applied for, Assignments, cancellations, ratings, reviews, responses to surveys and requests for feedback, information about your use of our services, correspondence and communications with you and information about any complaints or enquiries you make to us.
• Community Data: includes any information you send to other Members via the Platform's community function.
• Marketing and Communications Data: this includes your preferences in receiving marketing from us and your communication preferences.
3. Data from other sources, including:
• Criminal Offences Data: Our Clients require us to carry out a criminal records check in order to satisfy themselves that there is nothing in a healthcare professional’s criminal convictions history which makes them an unsuitable for carrying out an Assignment with vulnerable individuals. Therefore, we may carry out a DBS check or collect a copy of the DBS Certificate. We may also require a statement about the information contained in the DBS Certificate.
• User feedback, such as ratings, feedback, or compliments.
• Users participating in our referral programs. For example, when a user refers to another person, we receive the referred person’s personal data from that user.
• Users or others providing information in connection with claims or disputes.
• reach24 business partners through which users create or access their reach24 accounts, such as payment providers, social media services, or apps or websites that use reach24’s APIs or whose APIs reach24 uses.
• Vendors who help us verify users’ identity, background information, and eligibility to work, for regulatory, safety, and security purposes.
• Publicly available sources.
• Marketing service providers.
reach24 also collects and uses aggregated, anonymous or pseudonymised data, such as statistical or demographic data. If we combine any of this data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.
How do we use personal data?
reach24 collects and uses data to enable a safe, reliable, and convenient platform for Temporary work-seekers to find suitable Clients to work for. We also use the data we collect:
• To enhance the safety and security of our users and services
• For customer support
• For research and development
• To send marketing and non-marketing communications to users
• In connection with legal proceedings
reach24 does not sell or share user personal data with third parties for their direct marketing, except with users’ consent.
Personal data collected is used for purposes including:
1. Providing services and features
reach24 uses the data we collect to provide, personalise, maintain, and improve our products and services.
This includes using the data to:
• Create and update users’ accounts.
• Verify Temporary Workers, background history, and eligibility to work.
• Offer, process, or facilitate payments for our services.
• Offer, obtain, provide, or facilitate insurance, invoicing, or financing solutions in connection with our services.
• Track and share the progress of Temporary Workers while travelling for assignments.
Enable features that allow users to share information with reach24, such as when a Client submit a compliment or feedback about a Temporary Worker on assignment, when Client or Temporary Worker refer a business or another worker.
• Enable features to personalize users’ reach24 accounts, such as creating bookmarks for favourite Clients, and to enable quick access to repeat Clients. We may, for example, present a Temporary Worker with opportunities with Clients based on their previous ratings and to recommend to Clients Workers based on their previous experience.
• Perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyse usage and activity trends.
2. Safety and security
We use personal data to help maintain the safety, security, and integrity of our services and users. This includes:
• Screening Temporary Workers and Clients before enabling their use of our services and at subsequent intervals, including thorough reviews of background checks, where permitted by law, to help prevent the use of our services by unsafe and unreliable Workers and undesirable Clients.
• Using feedback data from Clients and their representatives to help identify unsafe or unreliable Temporary Workers and if possible, help them to improve their work culture, reliability, and Service. We also use relevant feedback data from Temporary Workers to assess Clients and help them improve service delivery and practices.
• If required reach24 may use information derived from driver’s license photos, and other photos submitted to reach24, for safety and security purposes. This includes reach24’s Real-Time ID Check feature, which prompts a Temporary Worker to share a selfie before starting an assignment with a Client to ensure that the Temporary Worker using the app matches the reach24 account we have on file. This also includes comparing photographs from public databases to verify user identity.
• Profile usage, and other data to prevent, detect and combat fraud or unsafe activities.
• Using user ratings and feedback to encourage compliance with our Community Guidelines and as grounds for deactivating Temporary Workers with low ratings.
3. Customer Support
reach24 uses the information we collect (including recordings of customer support calls with notice to and the consent of the user) to provide customer support, including to:
• Direct questions to the appropriate customer support person
• Investigate and address user concerns
• Monitor and improve our customer support responses and processes
4. Research and development
We may use the data we collect for testing, research, analysis, product development, and machine learning to improve the user experience. This helps us to improve and enhance the safety and security of our services, improve our ability to prevent the use of our services for illegal or improper purposes, develop new features and products, and facilitate insurance and finance solutions in connection with our services.
5. Marketing
reach24 may use the data we collect to market our services to our users. This includes sending users (both Clients’ and Workers’) communications about reach24 services, features, promotions, studies, surveys, news, updates, and events. Please note when using the data for marketing purposes, we will use anonymous data and will not use any identifiable data of any of our users unless we have explicit written consent to do so.
We may also send communications to our users about products and services offered by our Group businesses who offer similar services. For example, if a Nurse registers with reach24 and provides services through reach24, then we may also provide that Nurse with similar Nurse work opportunities available with our group concerns. Similarly, if a Client is unable to find a suitable resource through reach24, then we may recommend potential alternative services which our sister Agency business may be able to offer. Although we may send users communications about opportunities or services available from reach24’s sister concerns or group Companies, we do not share users’ personal data to, or with, such group partners or others for purposes of their own direct marketing or advertising, except with users’ consent.
We may use the data we collect to personalize the marketing communications (including advertisements) that we send, including based on user location, past use of reach24’s services, and user preferences and settings. However, no identifiable data of any of our Workers or Clients will be shared unless with explicit written consent.
6. Non-marketing communications
reach24 may use the data we collect to generate and provide users with payslips or invoices; inform them of changes to our terms, services, or policies; or send other communications that aren’t for the purpose of marketing the services or products of reach24.
7. Legal proceedings and requirements
We may use the personal data we collect to investigate or address claims or disputes relating to the use of reach24’s services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.
8. Automated decision-making
We use personal data to make automated decisions relating to use of our services. This includes:
• Matching available Temporary Workers to users requesting services. Users can be matched based on availability, proximity, and other factors.
• Determining Temporary Worker and Client ratings and deactivating Temporary Workers and Clients with low ratings.
• Deactivating users who are identified as having engaged in fraud or activities that may otherwise harm reach24, its Clients, and others.
9. Data sharing and disclosure
Some of reach24’s products, services, and features require that we share data with other users or at a user’s request. We may also share data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes.
To whom do we disclose your information?
1. Clients
We may need to disclose Temporary Workers' Personal Information to Clients as part of the services and use of the Platform. For example, we will share Temporary Workers' Identity Data, Contact Data, Temporary Worker Profile Data, Employment Status Data and Career History and Education Data with Clients when you apply for an assignment (as defined in our Terms and Conditions). We will also share limited Identity Data with Clients to enable them to invite Temporary Workers to apply for opportunities.
2. Service Providers
We use third-party service providers to help us to administer certain activities and services on our behalf, such as IT, hosting and cloud services, payment processing services, verification services marketing services, data analytics providers, Research partners including those performing surveys or research projects in partnership with reach24 or on behalf of reach 24, Consultants, lawyers, accountants, and other professional service providers, customer support services and DBS check services. We may share Personal Information about you with such third-party service providers solely for the purpose of enabling them to perform services on our behalf and they will operate only in accordance with our instructions.
3. Anonymous statistics
reach24 prepare and develop anonymous, aggregate, or generic data and statistics for various reasons such as aggregate usage statistics including "page views" on the Platform analysing how users use our content and for marketing.
4. Third parties when required by law
reach24 will disclose Personal Information to comply with applicable law or respond to valid legal process, including from our regulators, law enforcement or other government agencies (in which case such agencies or regulators will be acting as controllers as well); to protect the users of the Platform (e.g. to prevent spam or attempts to defraud them); to operate and maintain the security of the Platform (e.g. to prevent or stop an attack on our systems or networks); or to protect our rights or property.
5. For legal reasons or in the event of a dispute
reach24 may share users’ personal data if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns. This includes sharing personal data with law enforcement officials, public health officials, other government authorities, or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies; to protect reach24’s rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services.
This also includes sharing personal data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.
6. With consent
reach24 may share a user’s personal data other than as described in this notice if we notify the user and they consent to the sharing.
Data retention and deletion
reach24 only retains user profile and other personal data for as long as a user maintains their reach24 account. We may retain certain user data after receiving an account deletion request if necessary, such as to comply with legal requirements or for purposes of safety, security, fraud detection, prevention, and research and development for up to 7 years. For example, if reach24 deactivates a user’s account because of safeguarding issues or malpractices, reach24 may retain certain information about that account to prevent that user from opening a new account in the future.
Data that is not required to retain for purposes of regulatory, tax, insurance, litigation, or other legal requirements will be deleted.
We retain a Client’s and Temporary Worker’s personal information for 7 years after the deletion of their account. reach24 may be unable to delete a user’s account if there are unresolved disputes however, upon resolution of this issue we will delete the account.
Grounds for processing
We only collect and use personal data where we have lawful grounds to do so. These include processing user personal data to provide requested services and features, for purposes of reach24’s legitimate interests or those of other parties, to fulfil our legal obligations, or based on consent.
Such grounds may vary depending on where our users are located, but generally include processing personal data:
1. To provide requested services and features
To provide our services, we must collect and use certain personal data. This includes:
• User profile data, which we use to establish and maintain user accounts; verify user identity; communicate with users about their assignments, and accounts; and enable users to receive earnings
• Background information, which is used to verify an applicant’s eligibility to be a Temporary Worker or Service provider.
• Usage data, which is necessary to maintain, optimise, and enhance reach24’s services, including to determine incentives, connect Clients and Workers, and calculate Fees and Worker remuneration.
• Transaction information
• Information relating to customer support
2. For purposes of the legitimate interests of reach24 or other parties
This includes using personal data to maintain and enhance our users’ safety and security. For example, we use personal data to prevent the use of our services by Workers who have engaged in inappropriate or dangerous behaviours in the past and have been banned from our platform, such as by retaining data of banned users to prevent their use of Reach24’s apps. We also use usage data to prevent matching Clients and Work seekers for whom there is a higher risk of conflict (for instance, because they have been subject to previous complaints).
This also includes purposes such as combating fraud; improving our services, direct marketing, research, and development; and enforcing reach24’s Terms of Service.
3. To fulfil reach24’s legal obligations
For example, reach24 is subject to laws and regulations that require it to collect and retain data about our Temporary Workers, and to provide copies of such data to the government or other authorities. We collect and use personal data to comply with such laws.
reach24 may also share data with CQC, Social Services, or law enforcement regarding criminal acts or safeguarding enquiries, or requests by third parties pursuant to legal processes.
3. With consent
reach24 may collect and use personal data based on the user’s consent. For example, we may collect personal data through voluntary surveys. Responses to such surveys are collected on the basis of consent and will be deleted once no longer necessary for the purposes collected.
A user who has provided consent to a collection or use of their personal data can revoke it at any time. However, the user will not be able to use any service or feature that requires the collection or use of that personal data.
Choice and transparency
reach24 enables users to access and control the data that reach24 collects, including through:
• In-app settings
• Device permissions
• In-app ratings pages
• Marketing opt-outs
reach24 also enables users to request access to copies of their data, changes, or updates to their accounts, deletion of their accounts, or that Reach24 restricts its processing of user personal data.
1. Privacy settings
Settings menus in the reach24 app for Workers give them the ability to set or update their location-sharing preferences and their preferences for receiving mobile notifications from reach24. Workers may enable or disable this feature through the Settings > Privacy menus or the Safety Centre in the reach24 app.
• Notifications: account and opportunity updates
We provide Workers with opportunity notifications and updates related to their field of expertise on their account. These notifications are a necessary part of using the reach24 app and cannot be disabled. However, workers may choose the method by which they receive these notifications through the Settings > Privacy menus in the reach24 app.
• Notifications: discounts and news
Workers may enable reach24 to send push notifications about offers and news from reach24. Push notifications may be enabled or disabled through the Settings > Privacy menus in the reach24 app.
2. Device permissions
Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the device owner’s permission, and these platforms have different methods for how that permission can be obtained. iOS devices notify users the first time the reach24 app requests permission to access certain types of data and give users the option to grant or refuse permission. Android devices notify users of the permissions that the reach24 app seeks before their first use of the app and the use of the app constitutes a grant of such permission.
3. Ratings
After every assignment, Workers and Clients can rate each other based on various categories. An average of those ratings is associated with a user’s account and is displayed to other users for whom they provide or receive services. For example, Client ratings are available to Workers who have advertised vacancies, and Clients can see Worker ratings of those whom they want to invite to apply for a specific shift or those who have submitted themselves against a specific opening.
This 2-way system holds everyone accountable for their professionalism and behaviours. Accountability helps create a respectful, safe, and enjoyable environment for Workers and Service Users. Workers can see their average rating in the main menu of the reach24 app. Clients also can see their average rating after tapping their profile photo on the reach24 website.
4. Marketing opt-outs
Users may also opt-out of receiving emails and other messages from reach24 by following the unsubscribe instructions in those messages. We may still send users who have opted out non-promotional communications, such as information about their accounts.
5. User data requests
reach24 provides users with a variety of ways to learn about, control, and submit questions and comments about reach24’s handling of their data.
• Accessing data: Users can ask for an explanation of the data we collect from them and how we use it.
• Receiving data: Users can ask for a copy of data that reach24 collects from them with their consent or as necessary to provide our services.
• Changing or updating data: Users can edit the name, phone number, email address, payment method, and photo associated with their account through the Settings menu in reach24’s app or website portal. They may also ask that reach24 change or update their data, including if they believe such data is inaccurate or incomplete.
• Deleting data: Users may request deletion of their account at any time through the Settings > Privacy menus in the reach24 app, or through reach24’s website.
• Objections, restrictions, and complaints: Users may request that we stop using all or some of their personal data, or that we limit our use of their data. reach24 may continue to process data after such objection or request to the extent required or permitted by law.
In addition, users may have the right to file a complaint relating to reach24’s handling of their personal data with the data protection authority in their country. For example, users in the UK, they submit such complaints to the Information Commissioner’s Office at the address below.
How to complain
You can complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Updates to this notice
We may occasionally update this notice. Use of our services after an update constitutes consent to the updated notice to the extent permitted by law. If we make significant changes, we will notify users in advance through the reach24 app or other means such as email. We encourage users to periodically review this notice for the latest information on our privacy practices.
