Recruitment Privacy Notice
1. IntroductioN
1.1 At Slaughter and May, we take the protection of your personal information seriously and we are committed to safeguarding the privacy of the personal information that you share with us or is collected by us during the course of our interactions with you. This Recruitment Privacy Notice (“RP Notice”) supplements and should be read together with the firm’s Privacy Notice.
1.2 This RP Notice sets out the basis upon which Slaughter and May, as a data controller, processes the personal information we collect from you when you register and apply for a permanent or fixed term role, a work experience opportunity or an insight event, as well as the subsequent selection process. We have prepared a China Addendum for individuals whose data is collected in mainland China. It supplements and constitutes an integral part of this RP Notice.
1.3 Under relevant data protection law, we are obliged to share detailed information about how we process your personal information. This invariably results in long, formal notices using technical and legal jargon, so in summary:
(A) we commit to only asking you for information that we consider relevant to the recruitment process;
(B) we endeavour to share only relevant information with colleagues internally and trusted external third parties to enable us to administer the recruitment process and, for successful candidates, the subsequent onboarding process;
(C) we constantly review our processes to keep the information you provide secure and we commit to deleting it in line with agreed retention periods; and
(D) we are always available to answer any concerns you may have around how your personal information is used, shared, stored or deleted during this process. You can either contact us via your recruitment contact, through the recruitment portal or by using our [email protected] email address. For more information about your rights, please see the firm’s Privacy Notice.
2. Scope of this RP Notice
2.1 Like most businesses, we hold and process a wide range of information, some of which relates to individuals who are interested in exploring opportunities with us. This RP Notice explains the type of information we process, our reasons for doing so and how that processing may affect you. For the purposes of this RP Notice, Slaughter and May means Slaughter and May, the partnership, Slaughter and May Services Company and the various other Slaughter and May entities operating in London, Brussels, Hong Kong and Beijing (also referred to in this RP Notice as the “firm” or “we”).
2.2 The RP Notice focuses on individuals who are applying to work for us as an employee, partner, contingent worker, contractor, consultant, work experience student or as part of our insight programme of events, and the data that we process as part of the application, recruitment and onboarding process only.
2.3 References in this RP Notice to employment, work (and similar expressions) include any arrangement we may have under which an individual provides us with work or services, or applies for such work or services, including but not limited to partners of any Slaughter and May entity.
2.4 We use the word “you” to refer to anyone within the scope of this RP Notice.
2.5 In brief, this RP Notice explains:
i. what personal information we hold and why we process it;
ii. the legal grounds allowing us to process your personal information;
iii. where the data comes from, who gets to see the data and how long we keep it;
iv. how to access your personal information and other rights; and
v. how to contact us concerning your data.
3. WHAT WE PROCESS AND WHY
3.1 The types of personal information we process will vary depending on the opportunity you are applying for, your location and the terms and conditions of employment or engagement (if any) relevant to you.
3.2 Slaughter and May generally processes data for the purposes of our business, including providing services to our clients, management, administrative, employment and for legal and regulatory purposes.
4. how we collect your information
4.1 When you apply to work for us, the initial data about you that we process are likely to come from you: for example, your contact details, educational information, diversity data and information on your immigration status.
4.2 Where necessary, and in accordance with this Notice, we will require references and information to carry out pre-engagement screening (PES) or background checks. If you have concerns about this in a particular context, you should speak to your contact within our Recruitment team.
4.3 We may also receive data from third party recruiters, agents or other intermediaries as part of the recruitment process, or as a referral from one of our employees or clients.
5. HOW WE SHARE YOUR INFORMATION
5.1 Internally
(i) Your personal information will be seen internally by members of the Recruitment team, and other HR team members, hiring managers, associates and partners involved in recruitment and, in some circumstances (if you are interviewing or you join us), other prospective colleagues on a need-to-know basis only.
(ii) We may also disclose your data to other employees of the firm where it is necessary for decision-making regarding your application. This will depend on the type of role you are applying for.
5.2 Externally
(i) We share your personal information with third party providers to carry out reference checks, credit checks and other PES checks and on-boarding activities in the event you accept an offer of employment or engagement from us, for example to our third-party PES providers.
(ii) We also share it with organisations that process data on our behalf, such as our payroll service, insurers and other benefits providers, our bank and organisations that host our IT systems and data. This would normally occur if you accepted an offer from us and would be carried out as part of the onboarding process.
(iii) We are also obliged to share your personal information with regulators, for example in order to conduct a s.43 check we need to share certain information with the Solicitors Regulation Authority.
(iv) In the UK we also use a third-party applicant tracking system (ATS), which securely stores your personal information for us once you have made an application in order to enable the relevant hiring managers and recruiters to consider your application.
6. THE LEGAL PART - OUR GROUNDS FOR PROCESSING
6.1 Under data protection law, there are various legitimate and lawful grounds we can rely on when processing your personal information. In some contexts, more than one of the stated grounds will apply to the processing we carry out.
6.2 We have summarised these grounds under four headings:
(i) contractual;
(ii) legal obligation;
(iii) legitimate interests; and
(iv) explicit consent.
6.3 Each of the grounds is defined in the following table:
Applicable term |
Ground for processing |
Explanation / definition |
|
i. Contractual |
Processing the data is necessary for the performance of contractual obligations with you or is necessary as a precursor to enter into a contract at the request of an individual. |
This covers carrying out our contractual obligations and exercising our contractual rights. |
|
ii. Legal obligation |
Processing the data is necessary in order to ensure compliance with our legal obligations. |
Ensuring we perform our legal and regulatory obligations. For example, in the avoidance of unlawful discrimination as part of the recruitment process or complying with our SRA regulations. |
|
iii. Legitimate interests |
Processing the data is necessary for our interests or for the legitimate interests of a third party. |
The firm or a third party have legitimate interests in carrying out, managing and administering our respective businesses effectively, and it is necessary to process your data in the course of doing so. Your data will not be processed on this basis if the firm’s interests or those of a third party are overridden by your own interests, rights and freedoms. |
|
iv. Explicit Consent |
You have given specific consent to our processing of your data. |
In general, processing of your data in connection with employment is not conditional on your consent, however there may be occasions where we rely on your consent to do so, for example when we request a reference from a former employer or consent is required in your jurisdiction to enable us to transfer your personal data overseas. |
7. Special categories of personal information
7.1 If we process special category personal information, as well as ensuring that one of the grounds for processing mentioned in section 6 applies, we will also make sure that one or more of the additional grounds for processing this type of personal information applies. The grounds include:
(i) processing being necessary for the purposes of your or our obligations and rights in relation to employment insofar as it is authorised by law or collective agreement;
(ii) processing relating to data about you that you have manifestly made public;
(iii) processing being necessary for the purpose of establishing, making or defending legal claims;
(iv) processing being necessary for provision of health care or treatment, medical diagnosis, and assessment of your working capacity;
(v) processing for equality and diversity purposes, to the extent permitted by local law; and
(vi) processing for which you have given us your explicit consent.
8. Data processing examples and grounds
8.1 The firm’s Privacy Notice outlines the purposes for which we process your personal information. More specific, recruitment-related information on these, examples of the data and the grounds upon which we process data are in the table below (these examples are not exhaustive):
|
Purpose |
Examples of personal information that may be processed |
Grounds for processing |
|
(i) Recruitment in relation to any job for which you apply and/or any job we think you might be suitable for in the future. |
Standard data related to your identity (e.g. your name, address and email address), ID information and documents, telephone numbers, place of birth, nationality, contact details, salary information, professional experience and education (including university degrees, academic records, professional licenses, memberships and certifications, awards and achievements, and current and previous employment details), financial information (including current salary information), language skills, and any other personal information that you present us with as part of your application related to the fulfilment of the role. Information concerning your application and our assessment of it, your references, any checks we may make to verify information provided or background checks and any information connected with your right to work. |
Contractual Legal Obligations (for example any information proving your right to work here, information provided to payroll to fulfil our obligations to HMRC, for health and safety purposes in CCTV, or diversity data collected for diversity monitoring and reporting) Legitimate Interests |
|
(ii) Entering into a contract with you (if you are made an offer by us). |
Information on your terms of employment from time to time including your hours and working patterns, your pay and benefits, such as your participation in pension arrangements, life and medical insurance and any bonus or share schemes. |
Contractual |
|
(iii) Contacting you or others on your behalf. |
Your address and phone number, emergency contact information and information on your next of kin. |
Contractual |
|
(iv) Payroll administration. |
Information on your bank account, pension contributions and on tax and national insurance. Your national insurance number or other government issued identifier. |
Contractual Legal Obligations Legitimate Interests |
|
(v) Physical and system security. |
CCTV images upon attendance for interview at our premises. |
Legal Obligations |
| (vi) Monitoring of diversity and equal opportunities (where permitted under local law) |
Information on your nationality, racial and ethnic origin, gender, sexual orientation, religion, disability and age as part of diversity monitoring initiatives. Such data will usually be aggregated and used for equality of opportunity monitoring purposes. |
Legal Obligations Legitimate Interests Explicit consent (only where necessary) |
|
(vii) Disputes and legal proceedings |
Any information relevant or potentially relevant to a dispute or legal proceeding affecting us. |
Legitimate interests Legal Obligation (necessary for the purpose of establishing, making or defending legal claims).
|
8.2 If you accept an offer from us we will process further information as part of the employment relationship. You will then be signposted to our internal Privacy Policy as part of the onboarding process.
9. HOW LONG WE RETAIN YOUR INFORMATION
9.1 Our general approach is to retain your personal information only for as long as is required to satisfy the purpose for which it was collected by us or provided by you. If you become employed by us we will keep your personal information for the duration of your employment and for a period afterwards.
9.2 The length of time for which we keep data collected during the recruitment process will depend on the type of role or opportunity you are applying for. If you would like more information about the firm’s retention periods for recruitment activity, please contact us at [email protected]
10. Cross border transfers
10.1 The global nature of our business means that your personal information may be disclosed to other Slaughter and May entities, or to third party suppliers or partners, located outside the United Kingdom, including (but not limited to) our offices in Brussels, Hong Kong and Beijing. These jurisdictions may not offer a level of protection of privacy equivalent to the level within the United Kingdom.
10.2 Where we transfer your personal information outside the United Kingdom, the firm will ensure that adequate safeguards have been provided by the entity receiving the information.
10.3 In respect of internal transfers between Slaughter and May offices, we undertake to ensure your data receives a level of protection which is at least in line with the requirements of data privacy legislation applicable in the United Kingdom.
10.4 In respect of transfers of your personal information to third party suppliers outside the United Kingdom, we will take steps to ensure that your personal information receives an adequate level of protection, including by, for example, entering into appropriate data transfer agreements.
11. your Rights
You have a variety of rights that enable you to exercise control over your personal information, including rights of access, erasure and objection. These rights are subject to certain exemptions which we may apply and certain rights (such as erasure) only apply in limited circumstances. For more detailed information about your rights, please refer to the ‘Your Rights’ section of our Privacy Notice.
12. Automated decision making
We do not currently use any automatic decision making as part of our recruitment processes, although we may use filtering questions in order to assist us with the administration and progression of your application throughout some stages of the application process.
13. Recruitment queries
If you have any general questions about your application or the recruitment process, please go to our Contact Us page.
14. Data privacy contact details and complaints
14.1 If you have any questions or concerns about this RP Notice or how the firm is processing your personal information, please contact the firm’s Privacy Partner at [email protected].
14.2 We hope that the firm’s Privacy Partner can resolve any query or concern you raise. If you feel we have not handled your query or concern to your satisfaction you can contact the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. They can be contacted by telephone on 0303 123 1113, or via the ICO’s live chat facility, which you can access via your browser by clicking here.
14.3 If you are based outside the UK, you may also have the right to submit a complaint to the relevant supervisory authority in your jurisdiction.
16. Status of this Notice
This RP Notice does not form part of any contract of employment you might enter into and does not create contractual rights or obligations. It may be amended by us at any time. Nothing in this RP Notice is intended to create an employment relationship between Slaughter and May and any non-employee.
Last updated: April 2024