Recruitment Privacy Notice (RP Notice)
1.1 At Rickard Luckin, 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 our interactions with you.
1.2 This RP Notice sets out the basis upon which Rickard Luckin, 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.
1.3 Under relevant Data Protection law, we are obliged to share detailed information about how we process your personal information. To summarise:
(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 or by using our firstname.lastname@example.org email address.
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, Rickard Luckin means Rickard Luckin (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, trainee, 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) includes 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 Rickard Luckin 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:
(a) what personal information we hold and why we process it;
(b) the legal grounds allowing us to process your personal information;
(c) where the data comes from, who gets to see the data and how long we keep it;
(d) how to access your personal information and other rights; and
(e) 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 Rickard Luckin 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 HR 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
(a) Your personal information will be seen internally by members of the HR team, 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.
(b) 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.
(a) 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.
(b) 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.
(c) We are also obliged to share your personal information with regulators, for example to conduct a s.43 check we need to share certain information with the Solicitors Regulation Authority.
6. 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:
(ii) legal obligation;
(iii) legitimate interests; and
(iv) explicit consent.
6.3 Each of the grounds is defined in the following table:
|Applicable term||Grounds for processing||Explanation / Definition|
|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.|
|Legal obligation||Processing the data is necessary 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.|
|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.|
|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.|
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:
(a) 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;
(b) processing relating to data about you that you have manifestly made public;
(c) processing being necessary for the purpose of establishing, making or defending legal claims;
(d) processing being necessary for provision of health care or treatment, medical diagnosis, and assessment of your working capacity;
(e) processing for equality and diversity purposes, to the extent permitted by local law; and
(f) processing for which you have given us your explicit consent.
8. Data processing examples and grounds
8.1 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|
|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.
|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.||
|Contacting you or others on your behalf||Your address and phone number, emergency contact information and information on your next of kin.||
|Payroll administration||Information on your bank account, pension contributions and on tax and national insurance. Your national insurance number or other government issued identifier.||
|Physical and system security||CCTV images upon attendance for interview at our premises.||
|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.||
|Disputes and legal proceedings||Any information relevant or potentially relevant to a dispute or legal proceeding affecting us.||
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 HR Policies 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@example.com
10. 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.
11. Automated decision making
We do not currently use any automatic decision making as part of our recruitment processes, although we may use filtering questions to assist us with the administration and progression of your application throughout some stages of the application process.
12. Recruitment queries
If you have any general questions about your application or the recruitment process, please go to our Contact Us page.
13. Data privacy contact details and complaints
13.1 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 HR team at firstname.lastname@example.org
13.2 We hope that the firm’s HR team 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. 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 Rickard Luckin and any non-employee.