We require certain information in order to consider your application (for example, evidence of qualifications and work history). Please note that if you do not provide all of the personal data we request from you, then we may not be able to consider your application further.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your data changes during the course of the recruitment process.
If you are successful in your application and commence work with us, a separate staff privacy notice will apply to the use of your personal data during your period of work.
Recruitment process
We use AllHires to process applications for roles advertised on our website.
Sources of personal data
We may obtain personal data about you from various sources, including:
- you,
- recruitment agencies and employment businesses,
- our third-party portal through which applications are sifted and shared (currently AllHires),
- background check providers (currently Experian),
- credit reference agencies,
- the Disclosure and Barring Service,
- statutory and other official bodies, e.g. the Home Office (including UK Visas and Immigration),
- professional advisers,
- occupational health consultants (currently Health Management),
- past employers,
- referees,
- universities and other educational institutions,
- professional industry bodies and regulatory authorities, e.g. the SRA and Law Society,
- automated technologies, e.g. CCTV, cookies, server logs and other similar technologies,
- public sources including social media.
We may also create personal data about you, e.g. interview documentation or if we speak on the phone before a formal interview then we may make written records of some of the conversation.
Types of data we collect
We will collect personal data about you at various stages in the recruitment cycle, including:
- personal details: name(s), title, username or similar identifier, gender, date of birth, age, nationality, languages, marital status, passport number, NI number and a copy of your driver’s licence,
- contact details: home and work addresses, mobile number and work and personal email addresses,
- information included in references,
- any other information included on CVs, applications forms, and covering letters: qualifications, skills, level of experience, education history, details of previous employment, employment dates, salary, benefits information and professional memberships,
- health questionnaires and medical examination reports and personal data gathered for health and safety purposes including any accident report or claim log in the event of an accident at our premises,
- immigration status details: copies of your passport, biometric residence permit and other immigration documents (including immigration history),
- background checks: data revealed by background checks, including criminal record checks,
- interview and assessment data: submissions for any assessment at interview stage, Watson Glaser test results, special arrangements required for interview, interview notes, notes from shortlisting exercises and any post-interview feedback,
- practising certificate details (if you are a solicitor),
- systems data: data gathered using our CCTV system and building entry and exit records,
- photographs,
- IT data: personal data relating to your use of our website, e.g. IP address, login data, traffic data, weblogs, browser type and version, time zone setting and location, browser plug-in types and versions, and operating system.
We may also process the following types of special category data:
- information about your race or ethnicity, religious or philosophical beliefs, sexual orientation and political opinions,
- trade union membership,
- information about your health, e.g. medical condition, health and sickness records,
- biometric data and passport information.
We may also process information about any criminal convictions and offences.
We have in place an appropriate policy document and safeguards which we are required to maintain when processing special category data and criminal convictions data.
How we use your data
We will use your personal data for a variety of different purposes, including:
- making a decision about your recruitment or appointment,
- determining the terms on which you will work for us,
- checking you are legally entitled to work in the UK,
- submitting immigration applications on your behalf or assisting you with applications,
- complying with our obligations as a sponsor (including in relation to retaining records of the recruitment process and details of applicants who applied for the role),
- carrying out background checks after an offer has been made,
- requesting references,
- communicating with you about your application and the recruitment process,
- assessing your skills, qualifications and suitability for a particular job or task,
- assessing education, training and development requirements,
- dealing with legal disputes involving you, or our employees, including accidents on our premises,
- complying with our legal or regulatory requirements,
- complying with health and safety obligations,
- using your personal data in life or death situations, e.g. in the event of an accident where we have to give your personal details to medical personnel,
- equal opportunities monitoring,
- protecting and defending our rights or property,
- succession and organisational planning,
- administering and protecting our business and to comply with our security policies,
- retaining details about you in case there are future employment opportunities for which you may be suited.
Legal grounds
We have a legitimate interest in carrying out most of the processing described above, which is not overridden by your interests, fundamental rights, or freedoms. When we rely on this legal basis our legitimate interests may include the following:
- the efficient running of our business,
- the management of the recruitment process and employment/engagement of staff,
- to enable us to take legal advice and to defend claims.
Otherwise, we tend to rely on the following grounds:
- compliance with a legal or regulatory obligation,
- performance of a contract with us or steps taken at your request prior to entering into a contract,
- consent (which we may occasionally ask you for).
In rare circumstances we may rely on the fact that the processing is necessary to protect your vital interests or the interests of someone else.
How we use your special category data
We may use your special category data for the following purposes:
- equal opportunities monitoring/reporting: we use data about your race or national or ethnic origin, religious or philosophical beliefs, health or your sexual orientation to ensure meaningful equal opportunity monitoring and reporting,
- immigration and right to work checks: we use data about your race or national or ethnic origin as well as data relating to your immigration history, passport and biometric residence permit and other immigration documentation (including checks using the Employer Checking Service), to conduct right to work checks as well as retaining immigration documents, complying with our obligations as a sponsor, applying for and assigning certificates of sponsorship, and submitting immigration applications,
- emergency scenarios: we use our knowledge of your health-related personal data in the event of illness or injury or some other related emergency,
- bringing or defending legal claims,
- adjustments: we use data about your physical or mental health or disability status to consider if we need to provide any adjustments for the recruitment process, to determine whether you are suitable for the role or to consider if we need to make any adjustments to the role you are applying for.
Legal grounds
Where we process special category data, we usually rely on the following additional legal grounds (subject to any additional conditions in each case):
- carrying out our obligations and exercising our specific rights under employment, social security and social protection law,
- where you have given your explicit written consent,
- substantial public interest,
- where you have made the information public,
- to establish, exercise or defend legal claims,
- to protect your vital interests.
How we use information about criminal convictions
We may use information about criminal convictions and offences (including data relating to alleged commission of offences):
- to determine whether to employ or engage you, and
- when submitting immigration applications to the Home Office.
We carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for your role and in order to prevent fraud given that our roles involve dealing with clients and client money and require a high degree of trust and integrity.
Legal grounds
Where we process data relating to criminal convictions, we usually rely on the following additional legal grounds (subject to any additional conditions in each case):
- carrying out our obligations and exercising our specific rights under employment, social security and social protection law,
- where you have given your explicit written consent,
- substantial public interest,
- where you have made the information public,
- where it is necessary for the purpose of, or in connection with, any legal proceedings (including prospective proceedings),
- where it is necessary for obtaining legal advice or for establishing, exercising or defending legal claims,
- where it is necessary for reasons of substantial public interest and is necessary for:
- the prevention or detection of an unlawful act or the prevention of fraud, or
- complying with, or assisting other persons to comply with, a regulatory requirement which involves a person taking steps to establish whether another person has committed an unlawful act, or been involved in dishonesty, malpractice or other seriously improper conduct.
Data sharing
In addition to the information set out on our privacy page, your data may also be shared with the following:
- members of our HR team, interviewers involved in the recruitment process, senior staff (including partners) and IT staff if access to the data is necessary for their roles,
- your named referees when requesting a reference,
- background checking companies (including Experian),
- the Home Office (including UK Visas and Immigration),
- occupational health advisers and other medical professionals,
- third parties operating plugins or content on our website (e.g. Twitter) or other social media platforms which you choose to interact with.
International transfers
It is sometimes necessary to share data we collect from you in the course of the recruitment process outside the UK, e.g.:
- with our service providers located outside the UK, or
- if you are based outside the UK.
These transfers are subject to special rules under data protection law. Click here for more details.
Automated decision making
Automated decision making takes place when an electronic system uses personal data to make a decision without human intervention. Automated decision making is subject to strict rules under the GDPR. We do not envisage that any decisions will be taken about you using automated means during the recruitment process, however we will update this notice if the position changes.
Retention
Personal data will be stored in a range of different places, including on your application record, within our document management system and in emails.
We retain personal data processed in connection with recruitment as follows:
- If your application is successful, we retain the relevant personal data as part of your personnel file in our document management system.
- If your application is unsuccessful, we will retain the information included in your application for up to 1 year. Where you have agreed for us to do so, we may retain it for longer and use it to contact you about any other relevant employment opportunities that arise.
- Where we sponsor a person from outside the UK, we are required by the Home Office to keep personal data about the other applicants to demonstrate that we are complying with the applicable law.
We will not retain your data for longer than necessary for the purposes set out in this notice. If you would like to know more, please contact our DPO.
Your rights
Under certain circumstances, you have rights in relation to your personal data, including the right to:
- Request access to your personal data – you may receive a copy of the personal data we hold about you.
- Request correction of the personal data we hold about you – we will correct any incomplete or inaccurate data we hold about you.
- Request erasure of your personal data – you may ask us to delete or remove personal data where there is no good reason for us continuing to process it.
- Object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object on this ground.
- Request restriction of processing of your personal data – you may ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing.
- Request the transfer of your personal data to another party.
- Withdraw consent in the limited circumstances where you have provided your consent to the collection, processing and transfer of your personal data. After we have received notification that you have withdrawn your consent in relation to a particular purpose, we will no longer process your information for that purpose, unless we have another legitimate basis for doing so in law.
- Lodge a complaint regarding the processing of your personal data with the Information Commissioner’s Office or any other relevant supervisory authority.
Contact us
If you want to exercise any of the above rights, please contact:
Individuals in the UK or outside the EEA
Data Protection Officer, Stevens & Bolton LLP, Wey House, Farnham Road, Guildford, Surrey, GU1 4YD.
DPO@stevens-bolton.com.
Individuals in the EEA
Our EU Representative is Pembroke Privacy Ltd., 3-4 Upper Pembroke Street, Dublin 2, Ireland.
EURep@pembrokeprivacy.com.