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Privacy Policy
Anthony Collins Solicitors
Applicant Privacy Notice
Introduction
Anthony Collins Solicitors LLP (ACS) collects and processes personal data about Job applicants as part of its recruitment process, and if the applicant is successful, its onboarding process.
We are committed to being transparent about how we collect and use that data and meeting our data protection obligations, as set out in the Data Protection Act 2018 and the UK's implementation of the General Data Protection Regulation (UK GDPR).
This notice explains why and how we process your personal data, and explains the rights you have around your data, including your right to access it and to object to the way it is processed. Please see the section on ‘Your rights as a data subject’ for more information.
ACS is registered with the Information Commissioner under registration number Z5469866.
Our Data Protection Coordinator is Sam Coley, Head of Risk, Compliance and Knowledge, who you can contact at sam.coley@anthonycollins.com or on 0121 212 7475 if you would like further information about this privacy notice.
Personal Data
‘Personal data’ is any information that relates to a living, identifiable person. This can include your name, contact details, and other information we gather as part of our relationship with you.
It can also include ‘special categories’ personal data (sometimes referred to as ‘sensitive personal data’), which is information about a person’s race or ethnic origin, religious, political or other beliefs, physical or mental health, trade union membership, genetic or biometric data, sex life or sexual orientation. The collection and use of these types of data is subject to stricter controls. Similarly, information about criminal convictions and actual or alleged criminal offences are limited in the way we can process it.
We are committed to protecting your personal data, whether it is ‘special categories’ or not, and we only process data if we need to for a specific purpose, as explained below.
We collect your personal data mostly through our contact with you, through individuals you have nominated to provide us with information, the Disclosure and Baring Service and/or from third parties who can validate any information you have provided us as part of the application process, such as your educational qualifications
Processing your data
In general terms we process your data to fulfil our responsibilities to you, our staff, including to establish and maintain your contract of employment with us. Below lists more specific purposes for processing your data, and the legal basis for each type of processing.
Non sensitive personal data we may process
· Your name, contact details (i.e. address, home and mobile phone numbers, email address) and emergency contacts (i.e. name, relationship and home and mobile phone numbers);
· Proof of identity and entitlement to work;
· Details of your current salary and salary expectations
· Notice period;
· Professional qualifications and memberships.
· Education
· Work Experience
· References
· Dates you are available for interview;
· Your public LinkedIn profile where you have applied via LinkedIn; and/or
Any other personal data you have asked us to consider as part of your application.
Your nationality and immigration status, proof of identity and information from related documents, such as your passport or other identification and immigration information.
Lawful basis for processing
Where the processing is necessary for:
i. The performance of a contract (of employment) to which you are a party, or to take steps at the request of the data subject prior to entering into a contract;
ii. Compliance with a legal obligation to which, we, as a controller (and employer) are subject;
iii. Purposes of legitimate interests pursued by a controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data;
Where the processing is necessary for compliance with a legal obligation that we are subject to.
Special Category personal data we may process
Details of any disabilities or any reasonable adjustments you require to assist you during the application process
Lawful basis for processing
Where the processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as it is authorised by domestic law or a collective agreement pursuant to domestic law providing for appropriate safeguards for the fundamental rights and the interests of the data subject;
Criminal Records Data
Details of unspent (and depending on the vacant role, spent) criminal convictions.
Lawful basis for processing
Processing of personal data relating to criminal convictions and offences … shall be carried out only under the control of official authority or when the processing is authorised by domestic law (the Rehabilitation of Offenders Act 1974) providing for appropriate safeguards for the rights and freedoms of data subjects.
Statistical monitoring
ACS will process, if volunteered, information about your racial or ethnic origin, gender, your sexual orientation, religion or similar beliefs, marital status, disabilities, socio economic background including your parents’ educational background.
This information will be anonymised. It will be processed to allow us to measure the effectiveness of the measures we have implemented to ensure that we do not discriminate against candidates based on not just their race, religion, gender or sexual orientation, but also their socio-economic background, as well as assessing how effective any measures we take to encourage applications from under represented groups.
You are under no obligation to provide this information, and it will not be used as part of any selection process.
Additional processing
At times, we may further process data which we have already collected. We will only do this if the new purpose for processing it further is compatible with the original purpose that the data was collected for. We will tell you about any further processing before carrying it out unless we are legally prohibited from doing so.
Who we may share your data with
For some processing purposes we share your data with third parties. This is a list of the information we may share with external recipients, and for what purpose:
Our IT system providers have access to data so that we can ensure that our systems operate effectively and that we are running current versions of software.
Financial and quality auditors view data to monitor that we are complying with statutory and regulatory requirements and to confirm that we are complying with the requirements of the Lexcel practice quality mark.
We may share your personal data with other legal professionals, statutory regulators, and/or the Courts where necessary to comply with legal or regulatory obligations imposed on us or you.
We may also share your personal data, with your consent, as part of the recruitment, selection, or onboarding process, for example, to obtain references from your nominated referees
Use of Artificial Intelligence
Where we receive a large volume of applications for an advertised role, we may use technologies that incorporate artificial intelligence (“AI”), including machine learning, natural language processing, and other automated data analysis tools to allow us to screen applications to identify applicants that best fit the job requirements.
The output of such analysis, both shortlisted and rejected applications are subject to professional oversight and validation by qualified HR staff.
Any personal data processed using AI will be handled in accordance with applicable UK data protection legislation, our internal policies, and the safeguards described in this section. We do not rely on AI for automated decision-making that produces legal effects or similarly significant impacts on individuals without meaningful human review.
If you have any questions or concerns about our use of AI, object to our use of AI in respect of your application, or seek to have a human review of any decision made using AI, please contact our Data Protection Coordinator.
How we store your data
Your personal data may be held in both physical and electronic formats.
Electronic data, including emails, is stored in our servers, which are all located in the UK. All providers of cloud services that we use are accredited to the ISO27001 standard.
We rarely transfer employee personal data outside the UK. If we need to do this, we will ensure that the recipient: -
· Is subject to data protection laws deemed by the UK as meeting the data protection test in relation to the transfer such that the standard of data protection in the third country is not materially lower than in the UK;
· Is subject to contractual terms that ensure that the standard of data protection for the data subject in relation to the transferred personal data is not materially lower than in the UK; or
where the transfer is otherwise permitted under the UK GDPR, for example, with your prior consent or where necessary for the performance of a contract with you.
How long we keep your data.
If you are unsuccessful, we will normally retain your personal data for 6 months from the date you were notified that you were unsuccessful, unless:
· You have confirmed that you wish to be notified of any similar vacancies, in which case your details will be retained for a further [ months/year]; or
· An intervening event occurs that requires us to retain that information for longer.
Once that retention period has ended, your personal data will be securely and irretrievably destroyed.
Information relating to any actual or alleged criminal offences or convictions, including any DBS certificates, will only be retained for 6 months, irrespective of whether your application is successful.
If your application is successful, we will retain the DBS certificate number, but not the contents of the certificate. We will also additionally retain information provided by you as part of your employment file, including, for example, your prior employment history and educational qualifications. For further information as to how and why we process personal data during an individual’s employment with us and how long we retain this information, please see our employee privacy notice.
Your rights as a data subject
As a data subject, you have the following rights in relation to your personal data processed by us:
· To be informed about how your data is handled;
· To gain access to your personal data;
· To have errors or inaccuracies in your data changed;
· To have your personal data erased, in limited circumstances;
· To object to the processing of your personal data for marketing purposes or when the processing is based on the public interest or other legitimate interests;
· To restrict the processing of your personal data, in limited circumstances;
· To withdraw your consent (see below);
· To obtain a copy of some of your data in a commonly used electronic form, in limited circumstances;
· Rights around how you are affected by any profiling or automated decisions.
Withdrawing consent
If we are relying on your consent to process your data, you may withdraw your consent at any time.
Exercising your rights, queries, and complaints
For more information on your rights, if you wish to exercise any right or for any queries you may have or if you wish to make a complaint, either in relation to how we have processed your personal data or handled any request you have made, please contact our Data Protection Coordinator at sam.coley@anthonycollins.com or on 0121 212 7475.
Complaint to the Information Commissioner
You have a right to complain to the Information Commissioner's Office (ICO) about the way in which we process your personal data. You can make a complaint on the ICO’s website https://ico.org.uk.
Please note that the ICO will not, generally, consider a complaint until you have exhausted our internal complaints process first.
To view our full privacy policy that includes how we use cookies on our website please go to https://www.anthonycollins.com.