1. Who We Are

ANL Healthcare (Pty) Ltd (“ANL,” “we,” “our,” “us”) is a global healthcare-recruitment company founded in 2003. We source and place nurses, physicians, and allied health professionals worldwide.

2. Regulatory Framework

1. EU General Data Protection Regulation (GDPR)
2. US Health Insurance Portability and Accountability Act (HIPAA)
3. South Africa Protection of Personal Information Act (POPIA)
4. Any equivalent data-privacy laws in territories where we operate

3. What Data We Collect

Identification details, professional credentials, employment history, medical clearances, reference checks, immigration documents, and contact information.

4. Why We Collect It

To match candidates with roles, verify credentials, secure visas/work permits, and maintain statutory records.

5. Legal Bases for Processing

1. Performance of a contract (recruitment agreement)
2. Compliance with legal obligations (licensing, immigration, taxation)
3. Legitimate interest (staffing services for healthcare partners)
4. Consent (marketing updates, newsletter)

6. Storage & Security

Data are encrypted in transit (TLS 1.2+) and at rest (AES-256). Access is role-based and logged. We host data on ISO 27001–certified servers with daily backups and disaster-recovery replication.

7. International Transfers

When personal data moves outside the EEA or the UK, we use Standard Contractual Clauses or an equivalent adequacy mechanism.

8. Retention Schedule

Recruitment files are retained for seven years after final placement or last contact, unless local law requires a longer period.

9. Your Rights

Access, rectification, erasure, restriction, data portability, and objection. To lodge a complaint with a supervisory authority.

10. Contact Us

Email: privacy@anlhealthcare.com | Tel: +44 (0) 203 432 4418

Purpose: To guarantee uninterrupted staffing services to clients and candidates during any disruptive event.

1. Governance

Our Board reviews and approves the Business Continuity Plan (BCP) annually. A dedicated Resilience Officer coordinates all activities.

2. Risk Assessment

1. Cyber-attack or data-centre outage
2. Pandemics and public-health emergencies
3. Political unrest or travel restrictions
4. Natural disasters affecting candidate pipelines

3. Mitigation Strategies

1. Systems: Cloud-native ATS & CRM with 99.9% SLA and multi-region backups
2. People: Cross-trained recruiters and 24/7 on-call duty roster
3. Sites: Remote-first workforce with secure VPN and MFA
4. Suppliers: Dual-sourcing for verifications, licensure agencies, and travel logistics

4. Incident Response

Activation within 30 minutes. Senior management triages incidents; communications issued to clients and candidates within 2 hours.

5. Testing & Review

Semi-annual tabletop exercises plus one full failover drill every 12 months. Results logged and improvement actions tracked.

ANL Healthcare maintains a zero-tolerance approach to modern slavery, forced labour, and human trafficking, in line with the UK Modern Slavery Act 2015 and comparable laws worldwide.

1. Scope

This policy applies to all employees, contractors, suppliers, and partner facilities.

2. Due Diligence

1. Pre-contract supplier audits and risk screening
2. Verification of candidate identity, migration status, and consent
3. No recruitment fees charged to candidates—costs borne by hiring entities

3. Training & Accountability

Annual mandatory training for all staff. KPIs include zero incidents of forced labour and full compliance reporting.

4. Reporting Concerns

Whistle-blowing hotline: +44 (0) 203 432 4418 (24 hrs) | Email: ethics@anlhealthcare.com.
Reports are investigated confidentially within 5 working days.

Our ethical framework aligns with the following international standards:

1. WHO Global Code of Practice on the International Recruitment of Health Personnel
2. Philippine Overseas Employment Administration (POEA) Rules
3. GCC Labour Regulations
4. Joint Commission International (JCI) credentialing guidelines
5. Primary-source verification via DataFlow, CGFNS, or equivalent
6. Equal Opportunity & Non-Discrimination Principles

1. Obligations of ANL Healthcare

1. Transparent recruitment with written job offers and no hidden costs
2. Full disclosure of contract terms, compensation, and location
3. Adherence to destination-country licensure and immigration laws
4. Continuous monitoring of partner facilities for ethical workplace conditions

2. Obligations of Partner Facilities

1. Provide fair wages and safe working environments
2. Respect freedom of movement and right to retain personal documents
3. Support ongoing professional development of international staff
4. Co-operate with any audit initiated by ANL or regulatory bodies