- 1. Introduction
Data controller: The partners of Dehns (“the Firm”), head office located at: St Bride’s House, 10 Salisbury Square, London. EC4Y 8JD
As part of any recruitment process, the Firm collects and processes personal data relating to job applicants.
The Firm is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations. The Firm can be contacted concerning data protection matters at firstname.lastname@example.org.
- 2. What information does the Firm collect?
2.1 The Firm collects a range of information about you throughout the application and recruitment process. This may include:
·Your name, address and contact details, including email address and telephone number;
·Details of your qualifications, skills, experience and any employment history;
·Information about your current level of remuneration, including benefit entitlements;
·Whether or not you have a disability which the Firm needs to make reasonable adjustments for during the recruitment process;
·Information about your entitlement to work in the UK; and
·Equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health, and religion or belief.
2.2 The Firm collects this information in a variety of ways. For example, data might be contained in application forms, CVs, or collected through interviews or other forms of assessment including online tests. The source of such information will normally be you. Where you have not provided the data directly to the Firm, the source will usually be the recruitment agency you have given consent to in order for such data to be disclosed.
2.3 The Firm may also collect additional personal data about you from third parties, such as references supplied by former employer or academic institution, as relevant. The Firm will usually only seek information from third parties once a formal job offer has been made to you and will inform you that it will be doing so.
2.4 Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).
- 3. Why does the Firm process personal data?
3.1 The Firm needs to process data to take steps at your request prior to entering into a contract with you. It also needs to process your data to enter into a contract with you.
3.2 In some cases, the Firm needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant's eligibility to work in the UK before employment starts.
3.3 The Firm has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows the Firm to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide on a successful applicant. The Firm may also need to process data from job applicants to respond to and defend against legal claims.
3.4 Where the Firm relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of employees or workers and has concluded that they are not.
3.5 The Firm processes health information if it needs to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment.
3.6 Where the Firm processes other special categories of data, such as information about ethnic origin, sexual orientation, health, religion or belief, age, gender or marital status, this is done for the purposes of equal opportunities monitoring with the explicit consent of job applicants, which can be withdrawn at any time.
3.7 The Firm may be obliged to seek information about criminal convictions and offences where necessary and as permitted by law.
3.8 The Firm will not use your data for any purpose other than the recruitment exercise for which you have applied.
- 4. Who has access to data?
4.1 Your information will be shared internally for the purposes of the recruitment exercise. This may include members of the HR team, partners, managers and/or other appropriate interviewers involved in the recruitment process.
4.2 For some positions, the Firm will carry out an online assessment of relevant skills and considers that it has a legitimate interest in doing so as part of an overall assessment of suitability for employment. Your name and email address will be used for such purposes. If selected for online assessment, you will be informed about this in advance by email and reminded of your rights in relation to this process. The Firm’s online assessment provider has a separate privacy notice available to you as a data processor.
4.3 In the event of a technical issue with your application, the Firm’s online recruitment service or assessment providers may need to be provided with access to the relevant sections of the Firm’s systems. Access requests are made on a specific case-by-case basis and only where necessary to resolve technical problems.
4.4 Other than 4.2 and 4.3 above as and when applicable, the Firm will not share your data with third parties unless your application for employment is successful and it makes you an offer of employment (see 2.3 above).
4.5 The Firm will not transfer your data outside the European Economic Area.
- 5. How does the Firm protect data?
5.1 The Firm takes the security of your data seriously. It has internal controls in place to ensure that your data is not inappropriately accessed or destroyed. Your data is not accessed internally except by the Firm’s partners or appropriate employees in the proper performance of their duties. Where the Firm engages third parties to process personal data on its behalf, this is on the basis of appropriate instruction, and technical and organisational measures to ensure the security of data.
- 6. For how long does the Firm keep data?
6.1 If your application for employment is unsuccessful, the Firm will hold your data on file for six months after the end of the relevant recruitment process. At the end of that period, or if you raise a valid objection to the processing of any data in the interim, your data is deleted or destroyed.
6.2 If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained as appropriate during your employment. The periods for which your data will be held will be provided to you in a new privacy notice. Where the Firm collects equal opportunities and diversity personal data, such as information about ethnic origin, sexual orientation or religion or belief, this is done for the purposes of monitoring the diversity of candidates applying for positions with the Firm. This information is requested on a voluntary basis and is not transferred to a successful candidate’s employee record. The information received is retained and deleted in accordance with 6.1 above.
- 7. Your rights
7.1 Under certain circumstances, you have the right to:
·Request access and to obtain a copy of your personal data;
·Request the Firm to change incorrect or incomplete personal data;
·Request the Firm to delete or stop processing your personal data, for example where the data is no longer necessary for the purposes of processing;
·Object to the processing of your personal data;
·Request the suspension of the processing of your personal data; and
·Request the transfer of your personal data to another party.
7.2 If you believe that the Firm has not complied with your data protection rights, you can complain to the Information Commissioner.
7.3 In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact email@example.com. Once notification is received that you have withdrawn your consent, the Firm will no longer process your information for the purpose or purposes you originally agreed to unless it has another legitimate basis for doing so in law.
- 8. What if you do not provide personal data?
8.1 You are under no statutory or contractual obligation to provide data to the Firm during the recruitment process. However, if you do not provide the information, the Firm may not be able to process your application properly or at all.
8.2 You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information if the same is requested.
- 9. Automated decision-making
9.1 The Firm's recruitment processes are not based on automated decision-making.