Privacy & Data Protection Policy

1. Overview & Commitment to Healthcare Professionals

Locum Ireland Umbrella Limited ("Locum Ireland", "we", "our", or "us") operates an Irish umbrella company and payroll technology platform providing statutory payroll, invoicing, and tax accounting services to medical doctors, nurses, dentists, and veterinary specialists.

We are committed to safeguarding the personal, financial, and professional data of our contractors in accordance with the General Data Protection Regulation (EU 2016/679) and the Irish Data Protection Act 2018.

2. Information We Collect

To provide compliant umbrella payroll and Revenue reporting, we collect:

• Identity Information: Full name, PPSN (Personal Public Service Number), passport / photo ID copies, work permits.
• Professional Credentials: IMC (Irish Medical Council), NMBI, Dental Council, or VCI registration certificates.
• Financial Data: Bank account IBAN and BIC for direct payroll disbursement, tax credits, and RPN notices from Irish Revenue.
• Timesheets & Work Records: Shifts worked, hospital facilities, agreed hourly/daily rates, client authorizations.
• Statutory Expenses: Motor travel mileage, subsistence receipts, and CPD invoices eligible under Revenue Enhanced Reporting Requirements (ERR).

3. Purpose and Legal Basis for Processing

We process personal data on the following legal bases:

• Contractual Necessity (Article 6(1)(b)): To execute timesheet billing, hospital invoicing, and payroll disbursement.
• Legal & Statutory Obligation (Article 6(1)(c)): To remit PAYE, PRSI, and USC to the Irish Revenue Commissioners, file VAT returns, and fulfill statutory Companies Registration Office (CRO) duties.
• Legitimate Interests (Article 6(1)(f)): To maintain platform security, prevent payroll fraud, and ensure professional indemnity coverage.

4. Document Locker & AES-256 Cloud Encryption

All uploaded identification, Garda vetting, and medical qualification documents are stored in private, encrypted European cloud storage lockers protected by AES-256 at rest and TLS 1.3 in transit. Access is strictly constrained to authorized payroll officers under least-privilege audit controls.

5. Third-Party Disclosures & Revenue Transmissions

We do not sell, rent, or monetize your data. Data is shared exclusively with authorized statutory entities:

• Irish Revenue Commissioners: For automated real-time payroll submissions (PMR/RPN) and ERR notifications.
• Banking Clearing Partners (SEPA): For direct weekly wage remittances to your Irish bank account.
• Client Hospitals / Staffing Agencies: Invoices and timesheet approval verifications (sensitive tax credits are never disclosed).

6. Your Data Rights

Under GDPR, you have the right to access your personal data, request rectification of inaccurate records, request erasure (subject to statutory Revenue 6-year retention mandates for accounting records), and obtain data portability.

To exercise any rights, please contact our Data Protection Officer at support@locumireland.ie or write to D24 NRAO, Dublin, Ireland.