Legal notices


Private patient terms & conditions

The private patient terms & conditions form part of a contract between you and Circle which consists of your registration form, the private patient terms and conditions, and your treatment letter. A copy of the current private patient terms and conditions will be sent to you with your treatment letter and further copies are available at the hospital.

Read the private patient terms & conditions here.

Circle Health Website Privacy Policy

What is a privacy policy?

A privacy policy provides users of our website with a clear explanation of what they can expect to happen to any information they provide to us when using the website. This may be information directly provided, such as personal information like names and contact details; it may also include information which is indirectly provided when your device connects with our website.

There are laws, including the General Data Protection Regulation (GDPR), which govern what information we collect and how we collect it – these laws are designed to protect your privacy as an individual. Circle Health is committed to upholding these laws and to being open and transparent about how we use information collected on our website, and how we contact you for marketing purposes where you have opted-in.

Who we are and what we do

In this Privacy Notice we use "we" or "us" or "our" or "Circle" to refer to the Circle group of companies.

Circle Health is a company that runs hospitals, rehabilitation and health services in the UK. This privacy notice relates to website visitors, users of social media and other digital marketing campaigns we run. A separately privacy notice is available for our patients.

Circle is a Data Controller and a Data Processor under the terms of the EU General Data Protection Regulation (GDPR). We are legally responsible for ensuring that all personal information that we process about you is done in compliance with data protection laws. All Data Controllers must notify the Information Commissioner’s Office of all personal information processing activities. Our registration number is Z9921835 and our entry can be found in the Data Protection Register on the Information Commissioner’s Office website.

What personal information do we collect?

Information you give us

When we refer to personal data in this policy, we mean information that can or has the potential to identify you as an individual. Circle Health is the data controller for information submitted through our website. We will use your information to process your enquiry and contact you with relevant information.

This information may be visible to Circle’s IT providers, website developer and hosting company, who all work on behalf of Circle Health. We will share your information with these companies under the strictest data protection arrangements. If you would like further information regarding these third party companies, please contact our DPO using the details found below.

You may give us information about yourself by filling in forms on the website. This may include any personal or medical information you provide when you enquire about any of our services, apply for a job with us or when you report a problem with the site.

The personal information we hold about you may include the following:

  • Name
  • Contact details, such as postal address, email address and telephone numbers
  • Occupation
  • Responses to surveys or questionnaires
  • Correspondence relating to a complaint or claim
  • Your specific information requirements

If you provide it to us through the website, we will also hold information known as a special category of personal data under the law, meaning that it must be handled even more sensitively. The special categories of personal information we hold about you may include the following:

  • Details of your current or former physical or mental health. This may include information about any healthcare you have received (both from Circle directly and other healthcare providers such as GPs or hospitals (private and/or NHS)) and details of medicines previously and currently taken.
  • Details of services you have received from us
  • Details of your lifestyle and social circumstances
  • Details of your nationality, race and/or ethnicity
  • Details of your religion
  • Details of any genetic data or biometric data relating to you
  • Data concerning your sex life and/or sexual orientation.

You may also choose to opt-in to hear from us by email about our latest news, offers, events, health blogs and information about our services. This can be done through the website or by completing a printed sign-up form. This is separate from regular enquiries, so we will only add you to our mailing list where you have told us to do so. You can unsubscribe at any time.

Calls to Circle may be recorded for quality assurance purposes which include assessing the internal effectiveness of calls and also the range of services we provide. We use a company called Infinity who act on our behalf for the call tracking. The content of the calls will not be used for direct marketing purposes.

Please note that while Circle Health takes every possible precaution under UK and international law to protect our website and any information you provide once we have received it via the website, it must be understood that the use of the internet is not without risk and you should always bear this in mind when considering what information you provide.

We cannot guarantee the security of any information you provide to us while it is transiting the internet and any information you send this way will be at your own risk. You will always remain responsible for the security of your own systems and devices.

Information we may collect automatically

In order to ensure that your visit to our website is as easy and productive for you as we can make it, we use tools (such as Google Analytics) to collect certain types of ‘background’ information every time you click on our website pages. This will include:

  • Technical information, used to connect your computer to the Internet, such as browser type and version, Internet Protocol (IP) address, time zone setting, browser plug-in types and versions, operating system and platform.
  • Information about your visit, including all webpages visited by you on the site, services you viewed or searched for, page response times, time spent on each page, page interaction information (such as scrolling, clicks, and what you hold your mouse over), and any phone number used to call us.
  • Information about your browsing sessions help us track user interaction with our website so that we can use this information to improve your experience.

Automated Decision Making

We use third party providers such as Google, Facebook and other social media platforms to display relevant and focused adverts to target audiences. This is a form of automated decision making, undertaken by third parties, which can be based on specific criteria. For instance, adverts may be displayed in Google search results to reflect your search terms, or an event promotion on Facebook based on criteria such as demographics, location and job title. You have a right to not be subject to decisions that are made about you by computer alone. To update your preferences for advertising in this way, please contact these third party providers directly.

We also use ‘geotargeting’ to display relevant, local content to you on our websites. For instance, you may see information specific to our hospital in Reading if you live in the Berkshire area. We may also use cookies for retargeting purposes, which enable us to display relevant Circle adverts on other websites which may be of interest. Please see our cookie policy for more information.

Information from third parties

We may receive information about you if you use other Circle websites or use other services we provide. Sometimes we exchange your information with certain other organisations (known as ‘third parties’) and we receive information from them about you which can help us to deliver effective patient care. This includes your personal information and special categories of personal data. Such third parties may include:

  • Consultants and their medical secretaries to process your enquiry or appointment booking
  • NHS providers and GP practices
  • Private medical insurers
  • Solicitors (personal injury claims for treatments)
  • If you engage with us through social media platforms.

How we use and store your personal information

Using your information

We will not share the information you provide to us, or which we collect automatically, with any other organisations to use for marketing or commercial purposes. Where we collect any information from you either directly or automatically (as described above) it will only be used in accordance with this privacy policy.

In order to comply with any changes in the law, or to offer a better user experience, we may update this policy periodically. If these changes result in any material difference to the manner in which we process your personal data then we will alert you to these changes when you next visit our website. You should check this page from time to time to ensure that you are happy with any changes.

Where we retain any information you provide to us, we will use it to better understand your needs and to provide you with the best service we can offer. This may include holding information for the following purposes:

  • To answer an enquiry sent by you. For example, we will use your personal information to reply regarding a consultation request. In order to achieve this, we may pass on your information to external medical secretaries and consultants in order to provide you with information regarding a specified consultant.
  • Internal record keeping and database maintenance
  • To improve our products and services using anonymous statistics
  • From time to time, we may also use your information to contact you for market research purposes. Such contact will be strictly optional and imposes no obligation. We may contact you by email, phone or mail. We may use the information to customise the website according to your interests.
  • To enable us to contact you where you have opted-in to hear from us.

Outside these circumstances, there may be rare occasions when we are required by law (for example, to comply with law enforcement or national security regulations) to pass on information to certain authorities or government agencies. In such cases, we will abide by data protection principles and share the minimum information necessary.

The table set out in the Schedule below summarises the purposes for which we process your personal information and our legal justification for each of our processing activities. If you would like any further details on our purposes for processing your personal information, please contact the DPO using the details found below.

How long do we keep personal information for?

We will only keep your personal information for as long as reasonably necessary to comply with our legal and regulatory obligations. If you would like further information regarding the periods for which your personal information will be stored, please contact our DPO for further details.

Transfers to third countries

We (or third parties acting on our behalf) may store or process information that we collect about you in countries outside the European Economic Area ("EEA"). Under the EU General Data Protection Regulation (GDPR), companies transferring information outside of the EEA must ensure that such transfers are subject to appropriate safeguards to ensure an adequate level of data protection. Where we make a transfer of your personal information outside of the EEA we will take the required steps to ensure that your personal information is protected.

Your Rights

Under data protection law you have certain rights in relation to the personal information that we hold about you. These include rights to know what information we hold about you and how it is used. You may exercise these rights at any time by contacting Circle’s DPO (our DPO’s contact details can be found below).

There will not usually be a charge for handling a request to exercise your rights. If we cannot comply with your request to exercise your rights we will usually tell you why. There are some special rules about how these rights apply to health information as set out in the relevant legislation. If you make a large number of requests, or it is clear that it is not reasonable for us to comply with a request, then we do not have to respond or we can charge you for responding.

Your rights include:

  • The right to access your personal information

    You are entitled to a copy of the personal information we hold about you and details about how we use it. Please note that in some cases we may not be able to fully comply with your request. For example, if your request involves the personal data of another person and it would not be fair to that person to provide it to you.

  • The right to restriction of processing

    In some circumstances, you can ask us to suspend the use of your personal data. Sometimes we won’t be able to comply with your request if it is necessary to keep your information in order to perform tasks which are in the public interest, including public health, or for the purposes of establishing, exercising or defending legal claims.

  • The right to data portability

    You can ask us to transfer your personal information to you or to another individual or organisation. The information must be transferred in an electronic format.

  • The right to object to processing

    You can ask us to stop processing your information where we are relying on legitimate interests as the legal ground for processing (when we refer to ‘legitimate interests’, this means that we have an appropriate business need to process your personal information and this business need does not cause harm to you).

  • The right not to be subject to automatic decisions 

    You have a right to not be subject to decisions that are made about you by computer alone. To find out more about the way we use automated decision making, please see the section of this Privacy Notice titled ‘Automated Decision Making’).

  • The right to withdraw consent

    In some cases we need your consent in order for our use of your personal information to comply with data protection legislation. Schedule 1 sets out instances where we will rely on your consent for the purpose of processing your personal information. You have the right to withdraw your consent at any time. You can do this by contacting Circle’s DPO whose details can be found below.

  • The right to complain to the Information Commissioner's Office

    You can complain to the Information Commissioner's Office if you are unhappy with the way that we have managed any of your rights above, or if you think we have not complied with our legal obligations. More information can be found on the Information Commissioner’s Office website. Making a complaint will not affect any other legal rights or remedies that you have.

Security and storage

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

Our cookie policy

What are cookies?

According to the Information Commissioner’s Office (ICO), a cookie is “a small file of letters and numbers that is downloaded on to your computer when you visit a website. Cookies are used by many websites and can do a number of things, eg remembering your preferences, recording what you have put in your shopping basket, and counting the number of people looking at a website.

The rules on cookies are covered by the Privacy and Electronic Communications Regulations. The Regulations also cover similar technologies for storing information, eg Flash cookies. The Regulations were revised in 2011, and the ICO is responsible for enforcing these rules.”

View guidance about cookies from the ICO here


Does Circle use cookies?

Yes. Circle Health uses both session-based and persistent cookies. Session-based cookies are only stored while on your current visit to the website, so will be deleted when you close your browser. Persistent cookies are used to remember any site preferences for when you next visit our website, so they will stay on device after you close your browser.

How we use cookies

We may use cookies on our website to help us analyse web traffic or customise this website to your needs, likes and dislikes by gathering and remembering information about your preferences. They are also used for statistical analysis purposes, which make no use of personally identifiable data.

We may also use cookies for retargeting purposes, which enable us to display relevant Circle adverts on other websites which may be of interest.

They are also designed to enhance your experience of our website. For instance, recording when you complete or minimise a survey, so you do not get asked again when you visit other pages on the website.

Overall, cookies help us to provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

The table below explains the cookies we use and why:

  • Google Analytics - These cookies collect information about how visitors use our site. We use the information to compile reports and to help us improve our website. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
  • Functional cookie - This is a simple token used by Java applications to identify your unique session on the website. Typically used to maintain the integrity of your session while transacting information with a website (accessing secure areas, forms submissions etc.)
  • Cookie Control - When you click "I agree" on the Cookie Control user interface (a message on the screen when you first visit our website), a cookie is set in order to remember your preference.
  • Retargeting - When you visit particular parts of our website, a cookie is stored to enable us to show relevant Circle adverts on other websites you visit.
  • Security - We use cookies to support our website security measures.
  • Social media conversion tracking - We use a Facebook pixel tracking cookie which tracks how users have interacted with our website after seeing our post or advert on Facebook. This allows us to track a return on investment from running Facebook advertising.
  • Call tracking - We need cookies to enable our call tracking supplier to effectively monitor calls coming through to Circle. For instance, if you originally came to Circle’s website through a search engine.

Can I decline or remove cookies?

Yes. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. To find out how you can you modify and control cookies, visit this information page on the ICO website. 

Updating personal information we hold about you

We store and handle all personal information we hold about you according to the rules laid down by the law and the codes of practice which govern information processing.

If you believe that any information we are holding about you is wrong or incomplete, please contact us and we will amend any information found to be incorrect.

You may contact us at any time to unsubscribe from any of our services or to request that we remove your details from our records (with the exception of direct healthcare data).

Our Online Marketing

You will only receive marketing information from us where you have indicated consent to receive it. Please contact the local site directly if, for example, you are receiving marketing information not related to the website. We pay for advertising on Google (Google Adwords), where we provide relevant content based on search terms. We also use Facebook for Business, paying for targeted adverts about relevant content, blogs and events. You can unsubscribe from marketing delivered by us at any time. Contact your local Circle site or email dpo@circlehealth.co.uk

Terms and Conditions

This website is developed and operated as a service by Circle Health. By visiting and using this website, you are agreeing to these terms and conditions of use which are governed and construed by UK law:

  • You are agreeing to use this website and all subsidiary sites for lawful purposes including but not limited to your agreement not to introduce any malicious or technologically harmful material such as viruses, Trojans, worms, logic bombs or any attack on this website or subsidiary websites including but not limited to denial-of-service attacks.
  • You are agreeing not to attempt to gain unauthorised access to this website or the server on which it is stored or any associated servers, computers or databases.
  • You are agreeing to use this website in a way that does not infringe the rights of anyone else.
  • You are agreeing to contact us should you wish to direct another website to connect with this website by user clicks.
  • You are agreeing to request permission from us should you wish to associate your website with this one or to say that your website is endorsed by Circle Health.
  • You are agreeing to not hold Circle Health responsible for the content or information provided or held by any other organisation whose website you access via any link on the Circle Health website. You also agree to not seek redress from Circle Health for any claims or disputes which may arise from your use of third party websites.
  • We will always report any unlawful or suspicious activity to the relevant law enforcement bodies and will cooperate fully in any criminal proceedings against you.

Disclaimer

Although we always endeavour to provide content on our website that is relevant and up-to-date, we cannot guarantee or provide any conditions or warranties that the information will be:

  • current
  • secure
  • accurate
  • complete
  • free from potentially harmful code or other mechanisms such as bugs or viruses

While we provide a description of the clinical and other services offered by Circle Health, individual advice should always be sought in a consultation with a medical professional.

Any loss or damage experienced by the user or any associate as a result of visiting or using the Circle Health website will not be the responsibility of Circle Health. This applies in all circumstances including where the loss or damage was predictable, arose in the normal course of events or where the organisation or its agents had been previously advised that the loss or damage was likely to occur.

Additionally, Circle Health will not be held responsible for any direct, indirect or consequential losses; any loss or damage caused by civil wrongs (‘tort’, including negligence), breach of contract or otherwise; the use of this website and any websites that are linked to or from it; the inability to use this website and any websites that are linked to or from it.

There may be circumstances where Circle Health will accept liability for:

  • death or personal injury arising from our negligence
  • fraudulent misrepresentation
  • any other liability which cannot be excluded or limited under applicable law.

Other information

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over any other website. Therefore, we cannot accept responsibility for the protection and privacy of any information which you provide whilst visiting such sites, and such sites are not governed by this privacy statement.

As with any website, you should exercise caution and look at the privacy policy or statement applicable to the website in question.

Contact us about our privacy policy

Should you wish to contact us about our privacy policy or our general approach to privacy and confidentiality, you can use this link to contact us online and we will direct your enquiry to the appropriate department.

Circle has appointed a data protection officer (“DPO”). The DPO helps ensure that Circle complies with data protection law and acts as a contact point for all patients.

You can contact our DPO by:

  • Telephone: 0207 034 5250
  • E-mail: dpo@circlehealth.co.uk
  • Post: Data Protection Officer, 32 Welbeck Street, London, W1G 8EU.

SCHEDULE 1

About the information we collect and hold

In the table below we have set out the individual purposes for which we will process your personal information and the legal justification for doing so. In some instances, we are also required to identify an additional legal justification where we are processing special categories of personal information (eg. medical information). Beside each legal justification, we have cited the relevant article of the EU General Data Protection Regulations (GDPR).

Purpose for processing personal information

Description

Legal justification for processing personal information

Additional legal justification for processing special categories of personal information

To answer an enquiry sent by you through our website or via social media.

For example, we will use your personal information to reply regarding a consultation request. In order to achieve this, we may pass on your information to external medical secretaries and consultants in order to provide you with information regarding a specified consultant.

To take steps prior to entering into a contract with us for the provision of healthcare services (Article 6(b)).

Our providing you with healthcare and other related services (Article 9(2)(h).

To maintain our internal record keeping and customer database.

Circle has a need to maintain its customer records to ensure accurate and up-to-date information and preferences are available for you.

We have a business need, or ‘legitimate interest’ to use your personal information and such business need does not cause harm to the individual (Article 6(f)).

Our providing you with healthcare and other related services (Article 9(2)(h).

For market research purposes.

From time to time, we may use your information to contact you for market research purposes. Such contact will be strictly optional and imposes no obligation. We may contact you by email, phone or mail. We may use the information to customise the website according to your interests.

We have a business need, or ‘legitimate interest’ to process your personal information and such business need does not cause harm to you (Article 6(f)).

 

No special category data will be processed under this purpose, so no additional legal justification applies.

To contact potential patients about Circle’s products or services.

Circle engages in marketing but we are conscious of your rights and expectations when we carry out our marketing activities. We will only send information about products or services directly to you where you have specifically confirmed your consent to do so. You can unsubscribe from these communications at any time.

We will only contact you if you have provided your consent for us to do so (Article 6(a)).

We will only contact you if you have provided your consent for us to do so (Article 9(2)(a)).

To contact medical professionals about Circle’s products and services.

Where Circle has a legitimate interest to contact local medical professionals and practice staff, we may contact you about our products and services.

We have a business need, or ‘legitimate interest’ to process your personal information and such business need does not cause harm to you (Article 6(f)).

 

No special category data will be processed under this purpose, so no additional legal justification applies.

To comply with our legal or regulatory obligations, and defend or exercising our legal rights.

There may be rare occasions when we are required by law (for example, to comply with law enforcement or national security regulations) to pass on information to certain authorities or government agencies. In such cases, we will abide by data protection principles and share the minimum information necessary.

The processing is necessary in order for us to comply with our legal obligations (Article 6(c)).

The processing is necessary for establishing, exercising or defending legal claims (Article 9(2)(f)).

To confirm your place at a Circle event and contact you with information about it.

When you choose to sign-up to attend one of our events, we will need to contact you to confirm your place, your dietary requirements and any event changes. We may send out a reminder email shortly before the event, and also contact you shortly afterwards, with relevant information.

We have a business need, or ‘legitimate interest’ to use your personal information and such business need does not cause harm to the individual (Article 6(f)).

No special category data will be processed under this purpose, so no additional legal justification applies.

If you apply for a job with Circle.

 

When you choose to apply for a role at Circle Health, we will use your personal information to process your application and contact you with relevant information.

To take steps prior to entering into a contract with us following a job application (Article 6(b)).

To comply with our equal opportunities monitoring obligations (Article 9(2)(b).

Tracking internal effectiveness of our customer facing services.

We use Infinity (call tracking) and other analytical tools to track how our website is performing and ensure it’s of the highest quality. We also use call tracking for training purposes, to ensure we’re providing the best information when you call.

We have a business need, or ‘legitimate interest’ to use your personal information and such business need does not cause harm to the individual (Article 6(f)).

No special category data will be processed under this purpose, so no additional legal justification applies.

Most of the consultants treating patients in our facilities are not Circle employees but rather self-employed practitioners.  They practice their specialities in accordance with the terms of our Practicing Privileges policy.  

In 2014, the Competition and Markets Authority (CMA) issued an Order regulating the relationships between private hospital groups and consultants who treat private patients or refer them for tests at group facilities (“Referring Clinicians”).

In accordance with this Order, hospital operators are prohibited from entering into any incentive schemes that are designed to encourage Referring Clinicians to refer private patients to, or treat private patients at, their facilities. Circle Health does not operate any such schemes. The Order also requires hospital operators to disclose information about certain arrangements they have with Referring Clinicians, including: ownership interests held by Referring Clinicians in the hospital operator; the provision of certain “high value” facilities to Referring Clinicians; the availability of “low value” basic amenities for Referring Clinicians; and any remuneration for services provided by Referring Clinicians to the hospital.   Set out below is information about the arrangements we have with Referring Clinicians:

Remunerative arrangements

No Referring Clinician holds any equity or financial interest in Circle.

We engage a small number of Referring Clinicians to provide certain clinical services and/or to undertake certain managerial and governance functions at our hospitals. Attached below, listed by each facility, is a list of Referring Clinicians who provide such services and the remuneration they receive:


Circle Bath

Name Role/Title Services/Responsibilities Remuneration
Ben Colleypriest JAG Endoscopy Lead Advises on clinical audit matters; attends local executive board £4,000 annually
Neil Bradbury Deputy Medical Director Provides clinical management services; attends meetings of executive board and Group Hospital Executive £2,500 monthly
Andrew Chambler Clinical Chair Overall responsibility for clinical governance at Circle Bath; chairs local executive and attends Hospital Executive meeting £3,750 monthly

 


Circle Reading

Name Role/Title Services/Responsibilities Remuneration
Peter Hale Clinical Chairman Overall responsibility for clinical governance at Circle Reading; chairs local executive board and attends Hospital Executive meetings £3,750 monthly
Margaret Myszor JAG Lead Consultant Advises on clinical matters relating to JAG accreditation £833 monthly
Shabham Iyer Infection Control Lead Advises the Infection Prevention and Control Committee (IPCC) £1,000 monthly
Bernie Marden Paediatric Advisor Advises local executive board regarding outpatient treatment of children at Circle Reading £500 monthly

 


Circle Nottingham

Name Role/Title Services/Responsibilities Remuneration
Stefano Sansone Clinical Lead Leads the clinical unit specialty for Endoscopy; attends local executive board £833 monthly
Anand Patel Clinical Lead Leads the clinical unit specialty for Dermatology; attends local executive board £833 monthly
Martin Powell Clinical Lead Leads the clinical unit specialty for Gynaecology; attends local executive board £833 monthly
Attila Kovacs Clinical Lead Leads the clinical unit specialty for Orthopaedics; attends local executive board £833 monthly
Ben Gooding Clinical Lead Overall responsibility for clinical governance at Circle Nottingham; chairs local executive board and attends Hospital Executive meetings £3,750 monthly

 


Facilities

We provide certain facilities to Referring Clinicians at the following rates:


Circle Bath Hospital

    • consulting rooms at £11 per hour
    • office space at £50 per week
    • secretarial services at £12.74 – £13.43 (ex-VAT) per hour

Circle Reading Hospital

    • consulting rooms at £11 per hour
    • secretarial services at £16.21 (ex-VAT) per hour, depending on experience

Circle Nottingham

Silver Level (£20 per hour)

    • consulting rooms hire
    • meet & greet
    • patient reception services
    • nurse
    • diary management with patient liaison through a direct telephone number & personal contact
    • appointment management

Gold level (£35 per hour)

    • Silver Level services plus transcription, production and mailing of clinic letters/reports

Platinum level (£50 per hour)

    • Gold Level services plus sending invoices, collecting fees and reconciling payments

Basic amenities

At each of our hospitals, we provide consultants with the following basic amenities: 

  • In-housing training programmes to promote clinical and operational safety
  • Patient admission, billing, and related administrative services
  • Complimentary refreshments and parking
  • General marketing and promotional activities

We also host informational meetings and events from time to time to which Referring Clinicians are invited to attend.  While the cost of such events depends on the number attendees, the average cost is less than £1,000.

Circle supports equality through fair pay. We ensure our male and female employees are paid equally for the same roles and responsibilities by regularly undertaking internal audits and reviewing pay bands. Circle has a robust recruitment process and policies that promote and embed a culture of diversity and inclusion. We will continue to recruit and remunerate our employees on merit and in a fair, open, and transparent manner.

To see gender pay data required under the Equality Act, please choose Circle Nottingham, Circle Reading or Circle Bath.

View the original pdf.

Circle Health Holdings Limited

Circle Clinical Services Limited

Circle Nottingham Limited

Modern Slavery and Human Trafficking Statement 2017

1: Introduction

Circle Health Holdings Limited is the holding company for Circle Health Limited, a UK healthcare group (the “Circle”) operating hospitals and providing clinical services to NHS-funded, self-paying, and privately-insured patients.

Circle is committed to preventing acts of modern slavery and human trafficking within its business and supply chain, and requires that its suppliers are similarly committed. To this end, we undertake the following steps to ensure we comply with relevant UK legislation and to mitigate the risk of modern slavery and human trafficking occurring in our supply chain, including:

  • conducting due diligence process of all our existing suppliers;
  • complying with our Modern Slavery Policy (“MSP”) when setting out our audit, monitoring, and reporting processes; and
  • incorporating the key elements of our MSP into contractual approach to engaging new suppliers.

2: Policies

As part of our commitment to combating modern slavery, we have adopted an MSP and a Whistleblowing Policy. As we work with a range of suppliers to provide high quality healthcare services to our patients, we also seek to ensure our suppliers are aware of our MSP and adhere to the same high standards that we do.

3: Due diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, Circle has a documented process for approving third-party suppliers. Circle requires suppliers to complete a questionnaire confirming their compliance with quality, environmental aspects, health and safety, information security, equal opportunities, recruitment standards, and other relevant aspects. A full supplier review process is completed before appointment or on contract renewal, and ad hoc reviews are undertaken if any concerns arise. Our Modern Slavery Questionnaire forms an additional part of the overall review process and, where it flags up any concerns, we investigate further before we decide whether to engage that supplier. We maintain an Approved Supplier Register that records all vetted third-party suppliers to the business.

Our procedures are designed to:

  • establish and assess areas of potential risk in our business and supply chains;
  • monitor potential risk areas in our business and supply chains;
  • reduce the risk of slavery and human trafficking occurring in our business and supply chains; and
  • provide adequate protection for whistle-blowers.

4: Risk and compliance

Circle regularly evaluates the nature and extent of its exposure to the risk of modern slavery occurring in its supply chain by annual reviews of existing and new business areas and any affected policies.

Overall, we consider the healthcare sector to be low risk for acts of slavery and human trafficking, apart from single-use surgical instruments and uniform suppliers and outsourced support functions, which are medium risk areas. All current suppliers have been thoroughly assessed and are marked low risk in the Approved Supplier Register.

We will continue to ensure all our suppliers adhere to our MSP. We enforce a strict code of compliance and do not tolerate slavery and human trafficking within our supply chains. Where warranted, we will exercise our right to terminate our relationship with the supplier if we become aware that it has failed to comply with modern slavery legislation.

5: Effectiveness and KPIs

Circle uses key performance indicators (KPIs) annually to measure how successful we have been in ensuring that slavery and human trafficking are not taking place in any part of our business or supply chains. These are as follows for 2017:

  • number of known incidents of slavery and human trafficking linked to Circle either by its operations, business relationships or supply chain (currently nil);
  • percentage and number of suppliers investigated on suspicion of human trafficking and slavery (nil);
  • percentage and number of suppliers signed up to Circle MSP requirements (100%/289); and
  • percentage of procurement and HR staff trained on the issue of human trafficking and slavery and the application of our MSP (100%).

6: Training

Our employees are required to act in line with our policies (including MSP) that promote integrity and respect for each other. Our Circle Credo stresses that “everyone matters”, irrespective of their job or background. Further training is provided to procurement and HR teams. It covers modern slavery and human trafficking and includes information on where the risks lie and how to minimise and prevent them. Employees are taught the benefits of stringent measures to tackle slavery and human trafficking, as well as the consequences of failing to eradicate slavery and human trafficking from our business and supply chains.

7: Further actions and sign-off

Following our review of our actions this financial year to prevent slavery or human trafficking from occurring in our business or supply chains, we intend to continue reviewing KPIs annually and monitoring the robustness of the systems and controls we have in place.

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes Circle's slavery and human trafficking statement for the financial year commencing 1 January 2017 and ending 31 December 2017.

 

Signature:

 

Director

Circle Health Holdings Limited

29 May 2018

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