Julius and Clark Ltd Recruitment Privacy Notice
1. What is the purpose of this document
This is the Julius & Clark privacy notice which applies to our recruitment activities. Julius & Clark respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we collect, use, transfer and look after personal data which we may have collected directly from you or from third parties who have supplied such personal data to us in the context of recruitment, including any careers or marketing event we may hold. It also tells you about your privacy rights and how, in certain circumstances, the law protects you. Please note that as stated in this notice, certain sections of this privacy notice only apply to the personal data of data subjects who are protected under the General Data Protection Regulation ((EU) 2016/679)(GDPR) which, for our recruitment purposes, mainly consist of persons within the European Union. It applies regardless of the media on which your information is stored.
At the end of this document you will find a glossary of definitions which will assist you with reading this notice.
2. Important information and who we are
In our recruitment activity Julius & Clark Ltd is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. This privacy notice is being provided to you because you are applying for a position with us whether as an employee, worker, contractor or otherwise (a “position”) or registering for a recruiting event. It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided to data subjects protected under the GDPR.
We do not knowingly collect data relating to children under the age of 16 so if you become aware that we hold personal data on any person under 16 years of age please inform us immediately; our contact details are set out below.
We have appointed a data privacy manager (the “DPM”) who will oversee questions in relation to this privacy notice by those data subject protected by the GDPR. If your personal data is protected by the GDPR and you have any questions about this privacy notice, including any requests to exercise your rights, please contact the data privacy manager using the details set out below.
Should you have any questions relating to your data for recruitment purposes the data privacy manager can be contacted by email at firstname.lastname@example.org
If you are a data subject protected by the GDPR, in the EU you have the right to make a complaint at any time to the relevant supervisory authority which for Julius & Clark’s Group EU entities is the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version of the privacy notice was last updated in August 2019. Julius & Clark reserves the right to modify this privacy notice at any time. If you are concerned about how your information is used, you should check back at our recruitment page periodically. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. You always have the opportunity to review your personal data and other details for accuracy and can request changes that you are unable to edit yourself by contacting the data privacy manager by email at email@example.com
3. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). In connection with your application for a position with us, we will collect, store, use and transfer the following categories of personal information about you:
The information you have provided to us in your curriculum vitae and covering letter.
The information you have provided on the application form, including name, title, address, telephone number, personal email address, date of birth, gender, educational history and qualifications.
Your academic results and related information.
Your language capabilities.
Your requirements for visa sponsorship.
Any information you provide to us during an interview or any information we obtain from other people involved in the recruitment process including any references.
If you contact us for any reason, a record of that correspondence.
Details of your use of our recruitment tools and services whether through our website or otherwise.
Your feedback on the recruitment process.
Information required to process a contract and any benefits that may be offered.
On-boarding information such as bank details, next of kin, etc.
Information collected by Julius & Clark’s personnel about their evaluation of your education, professional and past-employment history in order to consider your suitability for the relevant position.
Information collected by Julius & Clark’s personnel about their evaluation of your performance in interviews.
Information relating to your performance in tests or assessments of your aptitudes or ability (whether performed by Julius & Clark or a third party).
Information regarding the status of your application in the recruitment process including your acceptance or rejection of employment by Julius & Clark.
In certain jurisdictions we may also collect, store, use and transfer the following "special categories" of more sensitive personal information:
Optional information you provide to us about your medical needs, dietary requirements, disability, dyslexia, etc.
Information about your race or ethnicity, religious beliefs, sexual orientation and political opinion as appropriate in the region in which you are applying for a position.
Information about your health, including any medical condition, health and sickness records.
In limited circumstances, information about criminal convictions and offences.
In applications for positions in the EU we do not generally collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). In the rare occasion where we are required to collect this type of personal sensitive data we will put in place safeguards to protect that information. Where a third party is collecting this information from you we will ask that they have the required consent, where applicable, or other legitimate basis to process the information but we are not responsible for their obligations to you.
Where the information we ask you to provide is optional we do so to help us deliver a better recruitment process. If you provide this we will either rely on your consent (where sought), our need to be able to perform or enter into a contract between us or when the performance is in the public interest such as equal employment opportunities reporting. Where you provide us with details of special categories of data we take your application directly to us as your consent to our use of this information. There are instances where we will rely on our legal obligations in the relevant jurisdiction in terms of employment, social security or social protection laws.
We also collect, use, store and transfer aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.
4. How is your personal information collected?
We collect personal information about candidates from the following sources:
You, the candidate.
Any Julius & Clark person or recruitment agency engaged by us in recruitment activities.
Background check providers where these are required for particular positions.
Where we have a legitimate interest any credit reference agency.
Your named referees in CVs and applications or as you may otherwise provide to us.
From third parties from a publicly accessible source.
5. How we will use information about you
We will use the personal information we collect about you to:
Assess your skills, qualifications, and suitability for the relevant position.
Carry out background and reference checks, where applicable.
Communicate with you about the recruitment process.
Keep records related to our hiring processes.
Provide you with information about services that you may request from us.
Respond to queries you make of us.
Allow you to participate in interactive features of our recruitment process.
Notify you about any changes to the recruitment process.
Comply with legal or regulatory requirements.
It is in our legitimate interests to decide whether to appoint you to a vacancy, position, provide you with employment or otherwise seek to engage your services since it would be beneficial to our business to do so and you have expressed an interest in being considered for that position. We also need to process your personal information to decide whether to enter into a contract of employment or for the provision of services with you.
Having received your CV and covering letter or your application form (as the case may be) and having regard to the results from the tests which you may have taken, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the relevant position. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the position. If we decide to offer you the position, we may then take up references and, in certain instances and, in some jurisdictions, carry out a criminal record or other security checks before confirming your appointment. We will carry out such checks where we are required to do so by law or, if we need your consent for such processing, we will request it from you.
If you fail to provide personal information
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications, work history or other information), we will not be able to process your application successfully. For example, if we require references for this role and you fail to provide us with relevant details, we will not be able to take your application further. Where we need to collect personal data by law, or under the terms of a contract we may have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.
How we use particularly sensitive personal information
We will use your sensitive personal information in the following ways:
We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.
Where we collect it, we will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting or for a purpose as otherwise required by the law of the relevant jurisdiction in which you are applying for a position.
Information about criminal convictions
If you are a person protected by the GDPR we do not envisage that we will process information about criminal convictions and if we do, we would only do so where have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.
In other jurisdictions we may collect information about your criminal convictions history because we would like to offer you a position conditional on checks and any other conditions, such as references, being satisfactory. We are required or are entitled to 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 the position in question.
Automated decision making takes place when an electronic system uses personal information to make a decision without human intervention. In our recruitment processes we may use automated decision making. We do so because, given the high volume of applicants, it is necessary for the performance of a contract or to take steps to enter that contract with you.
For applicants for consulting and certain core services positions in our London offices the automated decision making is based on a minimum academic criteria where it will be necessary to achieve a minimum 2:1 result in your undergraduate degree, and AAB at A level, with an A in Maths if taken (and fluent English) or other equivalent. Where these criteria have not been met you will automatically receive an email from us letting you know that your application has not been successful. You have a right to obtain human intervention and express your point of view and contest the decision. If you would like to do so please contact us on firstname.lastname@example.org
If you are a data subject protected by GDPR, we do not envisage making any other automatic decisions but if we need to use automated decisions on the basis of sensitive personal information we will only do so in the rare occasions where we obtained your explicit consent or it is justified in the public interest.
6. Data sharing
Why might you share my personal information with third parties?
We may share your contact details with an online assessment provider, if you are a candidate for certain London vacancies. We will also share it with ad-hoc recruitment agencies when there is a vacancy we are recruiting for. All our third-party service providers and other entities in the Julius & Clark Group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
We will also share the personal data where it is necessary for the establishment, exercise or defence of legal claims or threatened legal claims or wherever courts of competent jurisdiction are acting in their judicial capacity.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
7. Data security
Taking into account the state of the art, the cost of implementation and the nature, scope, contexts and purpose of the processing as described, as well as the risks of varying likelihood and severity for your rights, we have put in place appropriate security measures aimed at preventing your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed commensurate to that risk. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. However, as with any information transmitted via the internet or even in protected environments this is always susceptible of unauthorised access. Most of our communications with you are through email which involves well publicised risks including data corruption, hacking, interception, unauthorised amendment and other tampering and, in some cases, use of email may compromise confidentiality. We cannot therefore be responsible for the confidentiality of your data in these instances.
We have put in place procedures to deal with personal data breaches and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my information for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We will retain your personal information for a period of 2 years after we have communicated to you our decision about whether to appoint you to a position. If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.
However, by law we may have to keep certain information about you for up to 10 years after we no longer communicate with you or you ceasing to be an active contact with us. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way.
Where any statute of limitation requires longer periods we shall retain the personal data for such longer periods.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
In connection with the processing of data of data subjects to which the GDPR applies, under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are also processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact email@example.com
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Right to withdraw consent
If when you applied for a position, you provided consent to us processing your personal information for the purposes of the recruitment exercise, you have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact the data manager by email at firstname.lastname@example.org. Once we have received notification that you have withdrawn your consent, we will no longer process your application subject to the data retention period mentioned.
“data controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
“data subject” means a living, identified, or identifiable individual about whom personal data is processed;
“data processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
“EEA” means the countries within the European Union and also Iceland, Lichtenstein and Norway;
“personal data breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed;
“privacy notice” means the separate notices setting out information that may be provided to data subjects when personal data about them is collected;
“processing” or “process” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.