NURSE CONNECTOR PRIVACY POLICY
Effective Date: 11 August 2026
Last Updated: 11 August 2026
1. INTRODUCTION
Nurse Connector ("Nurse Connector", "we", "us", "our") is operated by [NURSE CONNECTOR LEGAL ENTITY], with registered address at [REGISTERED ADDRESS].
Nurse Connector provides technology-enabled healthcare staffing, workforce matching and related services which may allow nurses and other authorised healthcare professionals to identify and accept available assignments, healthcare organisations to identify suitable healthcare professionals, and individuals or authorised representatives to request appropriate homecare services.
We recognise that the nature of our services may involve highly confidential information, including professional records, identity information and, in limited circumstances, health and patient-related information.
We are committed to processing personal data lawfully, fairly, transparently and securely and only to the extent reasonably necessary for legitimate purposes.
This Privacy Policy explains how we collect, use, disclose, store, transfer and protect personal data and how individuals may exercise their privacy rights.
2. APPLICABLE DATA PROTECTION LAWS
Depending upon where a user, healthcare professional, healthcare organisation, patient or service recipient is located, our processing may be subject to legislation including:
United Kingdom: the UK GDPR, Data Protection Act 2018 and related legislation and regulations, as amended from time to time.
Nigeria: the Nigeria Data Protection Act 2023, applicable directives and guidance issued by the Nigeria Data Protection Commission and other applicable Nigerian privacy requirements.
Kingdom of Saudi Arabia: the Personal Data Protection Law ("PDPL"), its Implementing Regulations, regulations governing transfers of personal data outside the Kingdom, and applicable healthcare-data requirements.
Where another applicable law gives an individual greater protection, we will apply that protection to the extent required by law.
3. WHO THIS POLICY APPLIES TO
This Privacy Policy applies to:
a. nurses and healthcare professionals;
b. prospective healthcare professionals;
c. healthcare organisations and their representatives;
d. homecare clients;
e. patients and service recipients;
f. relatives, guardians and authorised representatives of patients;
g. visitors to our websites and applications;
h. contractors and service providers; and
i. anyone who communicates or otherwise interacts with Nurse Connector.
4. OUR ROLE IN RELATION TO PERSONAL DATA
Depending on the circumstances, Nurse Connector may act as:
a. an independent data controller where we determine why and how personal data is processed;
b. a processor acting on the documented instructions of a healthcare organisation or other controller;
c. a joint controller where Nurse Connector and another organisation jointly determine purposes and means of processing.
The legal role applicable to a particular processing activity will be determined by the actual circumstances and not merely by the terminology used in a contract.
Where Nurse Connector processes patient information solely on behalf of a healthcare organisation, the relevant healthcare organisation may remain primarily responsible for the patient's healthcare record and certain privacy requests.
5. PERSONAL DATA WE MAY COLLECT
5.1 Identity and contact information
We may collect names, addresses, dates of birth, telephone numbers, email addresses, photographs, identification documents, nationality and other information required to verify identity.
5.2 Professional information
For healthcare professionals we may process:
- nursing or healthcare professional registration numbers;
- professional licences;
- qualifications;
- employment history;
- clinical experience;
- specialties and competencies;
- training certificates;
- continuing professional development information;
- references;
- right-to-work information;
- professional restrictions or conditions;
- professional indemnity information;
- background, safeguarding or criminal-record checks where legally permitted;
- availability and assignment history.
5.3 Financial and transaction information
Where required for payment or billing we may process bank details, payment information, transaction records, invoices, payment status, tax-related information and related financial data.
We may use regulated third-party payment providers and may not directly store complete payment-card information.
5.4 Location and technical information
Where enabled or necessary for matching or service delivery, we may process approximate or precise location information, IP addresses, device identifiers, browser information, login records, application activity and security logs.
Users may control certain location permissions through their device settings, although disabling them may affect some functionality.
5.5 Patient and health information
Nurse Connector is designed to minimise the amount of patient-identifiable health information held by the platform.
Where necessary to arrange, administer, coordinate or support a homecare or healthcare assignment, we may process limited information concerning a patient's:
- identity;
- contact information;
- care requirements;
- relevant health condition;
- mobility or accessibility needs;
- medication-related information where necessary;
- risks relevant to safe care;
- emergency contact;
- safeguarding information;
- care location;
- relevant clinical instructions provided by an authorised healthcare provider.
Healthcare professionals must not upload, photograph, copy or otherwise place complete patient records on Nurse Connector unless an expressly designated secure feature permits it and such processing is necessary and authorised.
5.6 Communications
We may record communications with support teams and retain messages transmitted through the platform for security, safeguarding, dispute-resolution and service-administration purposes.
6. HOW WE OBTAIN PERSONAL DATA
We may obtain personal data:
a. directly from the individual;
b. from healthcare organisations;
c. from authorised relatives, representatives or guardians;
d. from professional regulatory bodies and publicly accessible professional registers;
e. from identity, background-check and credential-verification providers;
f. from payment providers;
g. from referees or previous employers where lawful;
h. automatically through use of our technology;
i. from public authorities where permitted or required by law.
Where someone supplies information concerning another individual, that person represents that they have lawful authority to do so.
7. PURPOSES FOR WHICH WE USE PERSONAL DATA
We may process personal data to:
a. create and administer accounts;
b. verify identity;
c. authenticate nursing and professional registrations;
d. assess suitability for healthcare assignments;
e. connect professionals with healthcare organisations or homecare opportunities;
f. administer bookings and assignments;
g. facilitate lawful payments;
h. manage cancellations, complaints and disputes;
i. protect patients and vulnerable persons;
j. detect fraud, impersonation and misuse;
k. maintain platform security;
l. investigate incidents;
m. comply with professional, healthcare, employment, tax and regulatory obligations;
n. respond to regulators, courts or law-enforcement authorities where lawfully required;
o. maintain records required by law;
p. improve and develop the platform;
q. communicate important service information;
r. send marketing communications where legally permitted;
s. establish, exercise or defend legal claims.
We will not use patient health information for unrelated advertising.
8. LAWFUL BASIS FOR PROCESSING
Depending on the applicable jurisdiction and processing activity, we may rely on:
a. performance of, or steps preparatory to, a contract;
b. compliance with a legal obligation;
c. legitimate interests, where those interests are not overridden by individuals' rights;
d. consent or explicit consent where required and appropriate;
e. protection of vital interests in genuine emergencies;
f. establishment, exercise or defence of legal claims;
g. employment, social-security or social-protection requirements;
h. provision or management of health or social care where legally applicable;
i. substantial public-interest grounds recognised by applicable legislation; or
j. another lawful basis expressly permitted under applicable data-protection legislation.
We do not automatically treat consent as the appropriate legal basis merely because information is sensitive.
9. HEALTH AND OTHER SENSITIVE PERSONAL DATA
Health information and certain other information are subject to heightened protection.
Where Nurse Connector processes such information, we will apply additional safeguards appropriate to its sensitivity.
These may include:
- strict access controls;
- role-based permissions;
- authentication requirements;
- encryption where appropriate;
- logging and monitoring;
- data minimisation;
- confidentiality obligations;
- processor agreements;
- incident-management procedures;
- privacy impact assessments;
- retention controls.
Access must be limited to individuals with a legitimate professional or operational need.
10. PATIENT CONFIDENTIALITY
Patient confidentiality is fundamental to use of Nurse Connector.
Healthcare professionals using the platform must comply with their professional confidentiality duties and applicable healthcare laws.
Patient information may only be accessed where necessary for a legitimate clinical or care-related purpose.
Healthcare professionals must not:
a. search for records out of curiosity;
b. access information concerning friends, colleagues, public figures or relatives without a legitimate care-related reason;
c. disclose patient information to unauthorised persons;
d. take unauthorised screenshots, photographs or recordings;
e. store identifiable patient records on personal devices;
f. discuss identifiable patients on social media or public messaging services;
g. retain patient information following an assignment except where legally authorised or required.
Confidentiality obligations continue after an assignment ends and after a user's Nurse Connector account has been closed.
11. PROFESSIONAL REGISTRATION AND CREDENTIAL VERIFICATION
By registering as a healthcare professional, a user authorises Nurse Connector, where lawful, to verify information with relevant professional regulators, credential-verification providers, employers and other appropriate bodies.
Verification does not constitute a guarantee by Nurse Connector that a person will remain suitable for every assignment.
Healthcare professionals remain responsible for maintaining valid registration, licences, authorisations, competency, appropriate insurance or indemnity and any other requirement necessary for their practice.
12. SHARING PERSONAL DATA
We may disclose relevant personal data to:
a. healthcare organisations;
b. healthcare professionals;
c. authorised homecare clients or representatives;
d. professional regulators;
e. credential and identity-verification providers;
f. background-check providers;
g. payment providers and banks;
h. hosting, cybersecurity and technology providers;
i. professional advisers, auditors and insurers;
j. government, tax, regulatory, safeguarding or law-enforcement authorities where legally permitted or required;
k. prospective purchasers or investors in connection with a genuine corporate transaction, subject to appropriate confidentiality protections.
We require service providers handling personal information on our behalf to comply with appropriate contractual privacy and security obligations.
Patient information will only be shared to the extent reasonably necessary and legally authorised.
13. HEALTHCARE ORGANISATIONS
Healthcare organisations using Nurse Connector may independently determine purposes for which they process information concerning nurses, employees, patients and other individuals.
Their processing may therefore be governed by their own privacy policies.
Nurse Connector is not responsible for independent processing undertaken by another controller outside Nurse Connector's instructions or systems, except to the extent liability cannot legally be excluded.
14. INTERNATIONAL DATA TRANSFERS
Because Nurse Connector may operate across the United Kingdom, Nigeria and Saudi Arabia and may use international technology providers, personal data may need to be processed outside the country in which it was collected.
Where international transfer restrictions apply, Nurse Connector will use an appropriate lawful mechanism and safeguards.
This may include adequacy mechanisms, approved contractual safeguards, standard contractual provisions, transfer risk assessments or another method permitted by applicable law.
Sensitive Saudi personal data will not be routinely transferred outside the Kingdom without consideration of applicable PDPL transfer requirements and required safeguards.
15. DATA SECURITY
Nurse Connector will maintain reasonable and proportionate technical and organisational safeguards appropriate to the nature of the personal information processed.
Our security programme may include encryption, access management, authentication, monitoring, vulnerability management, secure development procedures, backups and incident-response processes.
However, no electronic platform can guarantee absolute security.
Users must protect their passwords, devices and authentication credentials and must immediately inform Nurse Connector if they suspect unauthorised access.
16. DATA BREACHES
Nurse Connector maintains procedures to identify, assess, contain, investigate and document suspected personal-data breaches.
Where legally required, we will notify the relevant supervisory authority and affected individuals within applicable statutory requirements.
Healthcare professionals, healthcare organisations and contractors must report any suspected loss, disclosure, inappropriate access or other compromise of patient or Nurse Connector information immediately upon discoverythrough [SECURITY/PRIVACY CONTACT].
No user should attempt to conceal a data-security incident.
17. DATA RETENTION
We retain personal data only for as long as reasonably necessary for the purpose for which it was collected, including legal, professional, tax, employment, safeguarding, insurance and dispute-resolution requirements.
Different categories of information may therefore have different retention periods.
Professional, assignment, contractual and financial records may be retained following account closure where required to establish compliance or defend legal claims.
Patient information will be subject to heightened minimisation and retention controls.
Where information is no longer required, it will be securely deleted, destroyed or irreversibly anonymised in accordance with our retention policy.
18. CHILDREN AND PERSONS WHO CANNOT PROVIDE LEGALLY VALID CONSENT
Nurse Connector is not intended for healthcare professionals under the lawful working age.
Where homecare is requested for a child or another individual who cannot legally make the relevant decisions themselves, we may process information supplied by a parent, legal guardian or other properly authorised representative in accordance with applicable law.
19. MARKETING
We may send information about Nurse Connector services where the recipient has consented or where another lawful marketing basis applies.
Recipients can unsubscribe from non-essential marketing communications at any time.
Service messages concerning assignments, accounts, safety, security, legal requirements or material platform changes are not marketing and may continue to be sent where necessary.
20. COOKIES AND SIMILAR TECHNOLOGIES
Our websites and applications may use cookies and similar technologies for authentication, functionality, security, analytics and, where permitted, marketing.
Where applicable law requires consent for non-essential technologies, they will not be activated until the required consent has been obtained.
Users may change relevant preferences through our cookie-management facilities.
21. AUTOMATED MATCHING
Nurse Connector may use technology to rank or recommend assignments or professionals based on relevant criteria such as availability, qualifications, competencies, preferences or location.
A recommendation does not constitute a clinical judgment or guarantee of suitability.
Where applicable legislation gives individuals rights concerning solely automated decisions producing legal or similarly significant effects, Nurse Connector will provide the required protections.
22. YOUR PRIVACY RIGHTS
Depending on applicable law, individuals may have rights including:
- to receive information about processing;
- to request access;
- to request correction;
- to request deletion;
- to restrict certain processing;
- to object to certain processing;
- to withdraw consent where processing is based on consent;
- to request portability;
- to challenge certain automated decisions;
- to complain to an appropriate supervisory authority.
These rights are subject to applicable statutory exemptions.
Requests should be sent to [PRIVACY EMAIL].
We may need to verify identity before responding.
23. ACCOUNTABILITY AND DATA-PROTECTION GOVERNANCE
Nurse Connector will maintain appropriate privacy governance proportionate to the nature and scale of its activities.
This may include:
- records of processing;
- data-protection impact assessments;
- processor agreements;
- transfer assessments;
- incident logs;
- retention schedules;
- security controls;
- workforce confidentiality agreements;
- privacy and security training;
- appointment of a Data Protection Officer or responsible privacy lead where required.
24. THIRD-PARTY WEBSITES
Nurse Connector may contain links to third-party websites or services.
Nurse Connector does not control independent third-party processing and users should review the privacy policies of those providers.
25. REGULATORY COMPLAINTS
Individuals may also have the right to complain to the competent data-protection authority in their jurisdiction, including the UK Information Commissioner's Office, Nigeria Data Protection Commission or competent Saudi data-protection authority.
We encourage users to contact us first so that we have an opportunity to investigate and resolve a concern.
26. CHANGES TO THIS POLICY
We may update this Privacy Policy to reflect changes in law, regulation, technology or Nurse Connector's services.
Where a change is material, we will provide reasonable notice through the platform, email or another appropriate communication method.