ICA Privacy & Data Protection Policy

International Care Alliance (ICA)
Last updated: December 19, 2025

1. Who We Are

International Care Alliance (“ICA,” “we,” “our,” or “us”) is a Bermuda-based healthcare recruitment and workforce solutions organisation. We connect qualified healthcare professionals with healthcare organisations and private care recipients in Bermuda and internationally, operating in collaboration with vetted global partners.

2. Regulatory & Legal Framework

ICA is committed to complying with all applicable data-protection and privacy laws, including but not limited to:

  • Bermuda Personal Information Protection Act 2016 (PIPA)
  • EU General Data Protection Regulation (GDPR), where applicable
  • UK GDPR, where applicable
  • US Health Insurance Portability and Accountability Act (HIPAA), where applicable
  • Any equivalent or successor legislation in jurisdictions where we or our partners operate

Where multiple laws apply, ICA applies the highest applicable standard of data protection.

3. Personal Information We Collect

We may collect and process personal information including, but not limited to:

  • Identification and contact details
  • Professional qualifications, licences, and employment history
  • Reference checks and background verifications 
  • Immigration and work-permit documentation 
  • Medical clearances and fitness-to-work documentation 
  • Compliance and regulatory records

All personal information collected is relevant, necessary, and proportionate to our services.

4. Purpose of Collection

Personal information is collected and used for the following purposes:

  • Recruitment, placement, and workforce management 
  • Credential verification and compliance checks 
  • Immigration, licensing, and work-permit processing 
  • Contractual administration with candidates and healthcare partners 
  • Regulatory reporting and statutory record-keeping 
  • Communications related to services, updates, or opportunities

5. Lawful Basis for Processing

In accordance with PIPA and other applicable laws, ICA processes personal information based on one or more of the following lawful grounds:

  • Performance of a contract or steps taken prior to entering a contract 
  • Compliance with legal or regulatory obligations 
  • Legitimate business interests related to ethical healthcare recruitment 
  • Consent, where required (e.g. marketing communications)

Consent may be withdrawn at any time without affecting prior lawful processing.

6. Data Storage & Security

ICA implements appropriate technical and organisational safeguards to protect personal information, including: 

  • Encryption of data in transit and at rest
  • Role-based access controls and audit logging
  • Secure cloud-based systems with recognised security certifications
  • Regular backups, system monitoring, and disaster-recovery measures

Access to personal information is limited to authorised personnel only.

7. International Data Transfers

Where personal information is transferred outside Bermuda, ICA ensures that:

  • Adequate safeguards are in place
  • Transfers comply with PIPA requirements and applicable foreign laws 
  • Contractual protections or equivalent mechanisms are used to maintain data security and confidentiality

8. Retention of Personal Information

Personal information is retained only for as long as necessary to fulfil its purpose or comply with legal obligations.
Unless a longer period is required by law, recruitment and placement records are generally retained for up to seven (7) years following final placement or last engagement

9. Individual Rights

In accordance with PIPA and applicable laws, individuals have the right to: â—Ź Access their personal information â—Ź Request correction of inaccurate or incomplete data

  • Request erasure or restriction of processing where appropriate
  • Object to certain uses of their personal information
  • Withdraw consent where processing is based on consent

Requests may be made using the contact details below

10. Contact Information

Data Privacy Enquiries:
Email: info@internationalcarealliance.com
Registered Office: Bermuda

Business Continuity & Operational Resilience Policy

Purpose

To ensure continuity of services to healthcare organisations, partners, and care recipients during disruptive events.

1. Governance

ICA’s leadership reviews and approves the Business Continuity Plan (BCP) annually. A designated senior manager oversees operational resilience and incident response

2. Risk Assessment

Key risks include:

  • Cybersecurity incidents or system outages
  • Public health emergencies or pandemics
  • Travel or immigration disruptions
  • Natural disasters or supply-chain interruptions
  • Partner or vendor service failures

3. Mitigation Measures

  • Systems: Secure, cloud-based platforms with redundancy and regular backups
  • People: Cross-trained staff and flexible operational coverage
  • Locations: Remote-enabled operations with secure access protocols
  • Suppliers: Multiple approved vendors for critical services

4. Incident Response

Incidents are escalated promptly. Senior management coordinates response actions, and relevant stakeholders are informed as appropriate.

5. Testing & Review

The BCP is reviewed and tested periodically to ensure effectiveness, with updates implemented as required

Anti-Slavery & Human Trafficking Policy

International Care Alliance maintains a zero-tolerance policy toward modern slavery, forced labour, and human trafficking.

1. Scope

This policy applies to all ICA employees, contractors, partners, suppliers, and associated facilities

2. Due Diligence

  • Ethical screening of recruitment partners and suppliers
  • Verification of candidate identity, consent, and migration status
  • No recruitment or placement fees charged to candidates
  • Transparency in contracts, compensation, and conditions

3. Training & Accountability

Staff receive regular training on ethical recruitment and compliance. ICA monitors adherence and investigates any reported concerns.

4. Reporting

Concerns may be reported confidentially to:
Email: info@internationalcarealliance.com

All reports are reviewed promptly and handled with discretion.

Partner Compliance & Ethical Recruitment Framework

ICA aligns its practices with internationally recognised standards, including:

  • WHO Global Code of Practice on the International Recruitment of Health Personnel 
  • Ethical credential verification standards 
  • Destination-country licensing and immigration laws â—Ź Equal opportunity and non-discrimination principles

1. ICA Commitments

Transparent, ethical recruitment practices

  • Clear written offers and contract terms
  • Ongoing compliance monitoring
  • Protection of candidate rights and dignity

2. Partner Obligations

  • Provide safe, lawful, and fair working environments
  • Respect workers’ freedom of movement and document retention rights
  • Support professional development
  • Cooperate with audits or regulatory reviews

3. Regulatory Alignment Statement

ANL Healthcare and the International Care Alliance operate in alignment with international recruitment standards and applicable regulatory frameworks across the United States, United Kingdom, Bermuda, the Caribbean, Africa, and the Middle East. All placements are subject to destination-country licensing, credentialing authority approval, immigration authorization, and employer onboarding requirements.

Compliance Micro-disclaimer

Inclusion in our talent network does not constitute licensure or employment eligibility. Final placement outcomes remain subject to regulatory authority approval, employer credentialing decisions, and immigration authorization.


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+66 (123) 456-3455

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