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Pharmacist Privacy Notice
Working draft v0.6 · 28 September 2026 · pilot only. This notice explains how Precision Meds Ltd uses information about pharmacists who register, develop a profile, learn, seek work or deliver services through the platform. It must be fact-checked against the live systems before real applicants submit data. Acknowledging this notice is not blanket consent to processing.
1. Controller and contact
Precision Meds Ltd, company 14921658, Executive Suite Great North Road, Little Paxton, St. Neots, England, PE19 6EN, is the controller for pharmacist accounts and professional profile administration. Email [email protected] for a privacy request or question. A practice may be a separate controller for its patient records and for information it holds about a clinical assignment; its own notice may apply. Project arrangements determine any different role for Precision Meds in handling patient data. No patient records should be uploaded to a general pharmacist profile.
2. What we collect and where it comes from
We obtain account and contact details, password hashes and access records; GPhC number, registration and revalidation information; identity, photograph, address and qualification evidence; CV, work history, skills, systems, indemnity and other credentials; development goals, assessments, reflections, training and competency records; work preferences, availability, interests, offers, confirmations, timesheets and project records; invoice and payment details; administrator review decisions, correspondence and security logs. Some roles may require right-to-work, Smartcard or DBS check evidence and secure workspace/device checks. We should normally keep the minimum result of a DBS check instead of a full certificate.
Most information comes from you. We may obtain public GPhC register information, professional verification results, authorised background-check results and assignment information from client practices. Where information comes from another source, we will give the required privacy information within the applicable period unless an exception applies. Optional diversity information, such as ethnicity, must have a separate explanation and choice before collection. Do not enter patient details or another person's sensitive information in profile fields.
3. Purposes and proposed lawful bases
| Purpose | Information involved | Proposed Article 6 basis |
|---|---|---|
| Create and secure your account, manage profile, development features and enquiries | Account, profile, logs, communications | Steps at your request before a contract and performance of the platform contract; legitimate interests in security where necessary |
| Assess professional eligibility and suitable work, verify GPhC/credentials and maintain an auditable review | Professional and verification information, assessments, approval and check logs | Steps before an engagement; legitimate interests in safe, reliable services and prevention of misuse; legal obligation only where a specific duty applies |
| Match work, avoid schedule conflicts, administer offers, confirmed services and platform invoices | Preferences, availability, schedules, service and finance records | Steps before and performance of an agreed engagement; legitimate interests in planning and resolving disputes where necessary |
| Meet accounting, tax, professional, safeguarding and legal duties | Relevant payment, eligibility, incident and audit records | Legal obligation where identified; legitimate interests in establishing or defending claims where appropriate |
| Operate and protect the service and improve its reliability | Access, device and limited usage records | Legitimate interests in secure, reliable operation, assessed against your rights |
| Optional diversity or optional marketing | Only the specifically requested details | A separately identified Article 6 basis and, where needed, additional condition; withdraw consent if consent is used |
We must document a legitimate-interest assessment for each use of that basis. Information about health or ethnicity is special-category data and requires a specific Article 9 condition in addition to Article 6. DBS certificate or criminal-offence data requires Article 10 authorisation, an applicable Data Protection Act 2018 Schedule 1 condition and safeguards, including an appropriate policy document where required. The precise conditions and whether optional fields or raw certificates are collected remain a publication decision. Do not treat a mandatory account acknowledgement as consent for optional processing.
4. Necessity and choices
Account contact and security details are needed to provide an account. Identity, registration, qualification and relevant safety evidence may be needed before approval for particular work; without them we may be unable to verify eligibility or offer that role. Availability and development information help matching and personalisation, but entering a free day does not accept a shift. Optional diversity and marketing fields are not required for an account or work eligibility. The precise required fields for each stage must match the live form and be explained at collection.
5. Recipients and location
Authorised Precision Meds staff and reviewers see only the information needed for their roles. A client practice may receive the minimum credentials, availability, assignment and work information needed to assess or manage an engagement. The UK-hosted platform, database and uploaded documents store pharmacist data in the UK, as confirmed by Precision Meds. The platform also uses service providers for hosting, email delivery and, where enabled, verification, security or payment functions; professional advisers, regulators and authorities may receive relevant information where necessary or required by law. Before publication, verify the actual provider names, sub-processors and support-access locations against contracts and settings; the repository does not prove those facts.
Precision Meds does not intend to send pharmacist account data to a separate organisation outside the UK. If a provider or separate overseas organisation receives or remotely accesses it, the transfer position and any required safeguard must be explained here before that use begins. Access by an authorised member of the same UK legal entity while abroad is a different question from disclosure to a separate overseas organisation; it still needs suitable security. Do not infer transfer status from server location alone.
6. How long we keep information — proposed periods
These periods are a draft policy, not a claim that automatic deletion is already running. We review and keep a limited record for longer only where a specific accounting, clinical governance, complaint, safeguarding or legal-claim reason applies, with the reason and review date recorded.
| Category | Proposed period or trigger |
|---|---|
| Unused registration code and pending signup | Delete within 30 days after code expiry; the code itself expires after 30 minutes |
| CV and unsaved extraction | While your account is open, with no inactivity timer; delete on request or account closure |
| Ordinary profile, photo and current preferences | While the account is open; ordinarily delete within 90 days after closure, except necessary assignment/claim records |
| Raw identity/selfie | Ordinarily delete within 90 days after the verification decision; keep a minimal result/date/reviewer record where justified |
| GPhC screenshot | Replace at the next successful check, normally within 12 months; keep the minimal check outcome and revalidation/recheck date while professional access continues |
| Raw DBS certificate information, if required | Normally securely destroy within six months after the suitability decision; keep only justified minimum check metadata |
| Routine learning records | While the account is open and ordinarily within 12 months after closure; assignment-specific competence and governance records may be held for six years after the last relevant assignment |
| Confirmed work, hours, invoices and payments | Accounting evidence for six years from the end of the relevant company financial year, then review |
| Security/access logs | Normally rolling 12 months unless a documented incident or claim requires longer |
| Backups | Proposed rolling 90 days, subject to verification of the actual backup cycle and restoration controls |
The detailed category rules, exceptions and implementation checks are in the internal retention schedule. A CV deletion request or account closure does not erase an invoice or other record that we lawfully need to retain. You may ask about a particular record at [email protected]. Before this becomes a final notice, confirm that each period is actually implemented across database tables, uploaded files, email/export copies and backups.
7. Rights and complaints
Depending on the basis and circumstances, you may request access, correction, erasure, restriction or portability, or object to processing. You have a right to object to processing based on legitimate interests, including profiling for that purpose; tell us at [email protected]. You may withdraw consent for an optional use at any time without affecting earlier lawful processing. We will verify requests proportionately and explain any lawful restriction. You can complain to the Information Commissioner's Office at [ico.org.uk](https://ico.org.uk/) and seek a judicial remedy. If a data protection officer is legally required or appointed, add that person's contact before publication.
8. Decisions, messages and cookies
Readiness indicators and matching suggestions support staff review. Verify before publication whether any eligibility, approval or work decision is made solely by automation with legal or similarly significant effect; if so, explain the logic, significance, consequences and applicable rights. We send necessary account, verification and assignment messages. Optional marketing requires a separate applicable choice. The platform uses essential session and security technology; any optional analytics or cookies require a verified description and appropriate controls.
9. Changes
The published notice will carry a version and effective date. We will explain material changes in an appropriate way and retain an auditable copy. A privacy notice tells you about processing; it is not itself a contract or a request for blanket consent.
Publication facts still to verify: actual provider and support-access locations, implementation of the proposed retention periods, rights owner and DPO position, Article 9/10 conditions, optional fields, real automated decisions, cookies, and patient/client data roles. This draft is suitable for pilot review but should not be presented as settled privacy information for real applicants until these facts are completed.