Last updated: May 2022
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About this notice
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Eversheds Sutherland’s data protection responsibilities
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What types of personal data do we collect and where do we get it from?
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What do we do with your personal data, and why?
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Automated decision-making
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Anonymised and aggregated data
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Sensitive personal data (including criminal data)
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Who do we share your personal data with, and why?
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Where in the world is your personal data transferred to?
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How do we keep your personal data secure?
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How long do we keep your personal data for?
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What are your rights in relation to your personal data and how can you exercise them?
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Categories of personal data
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Purposes for processing personal data
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Purposes for processing sensitive personal data
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Individuals' rights
About this notice
This Privacy Notice applies to the Eversheds Sutherland network of law firms except for the ES entities in Austria, Czech Republic, Finland, Hungary, Italy, Slovakia, Sweden and Switzerland, which their own Privacy Notices that apply instead.
This notice explains how and why Eversheds Sutherland uses personal data about individuals who apply (or enquire about applying) to become our employees, partners, staff, contractors, trainees, officers, consultants, work experience students, vacation scheme students, apprentices and temporary or agency workers (referred to as “
applicants
” or “
you
”). You should read this notice, so you know what we are doing with your personal data. Please also read any other privacy notices that we give you, that might apply to our use of your personal data in specific circumstances in the future. For example, if you are successful in your application you should read our HR Privacy Notice when you join us.
For the purposes of this notice, the controller will be the Eversheds Sutherland entity that you are applying for a role with (the
controller
is also referred to in this notice as “
Eversheds Sutherland
”, “
ES
” “
we
”, “
our
” and “
us
”).
Click here for a list of the Eversheds Sutherland operating entities
and their contact details.
This notice does not form part of any contract between us and you (including any contract of employment that may be offered or any other services contract).
Eversheds Sutherland’s data protection responsibilities
“
Personal data
” is any information that relates to an identifiable natural person. Your name, address, contact details, salary details and CV are all examples of your personal data, if they identify you.
The term “
process
” means any activity relating to personal data, including, by way of example, collection, storage, use, consultation and transmission.
Eversheds Sutherland is a “
controller
” of your personal data. This is a legal term – it means that we make decisions about how and why we process your personal data and, because of this, we are responsible for making sure it is used in accordance with data protection laws.
What types of personal data do we collect and where do we get it from?
We collect many different types of personal data about you for lots of reasons. We cannot administer your application without your personal data. Where we don’t need your personal data, we will make this clear, for instance we will explain if any data fields in our application forms are optional and can be left blank.
Further details of the personal data we collect and where we get it from are set out at
Schedule 1.
As you can see from the table at
Schedule 1
, we collect your personal information from you directly and sometimes we obtain it from other people and organisations, including some public sources, such as publicly available directories and online resources, your emergency contacts, your use of Eversheds Sutherland provided assets, systems and platforms, your line manager and co-workers, your dependants and beneficiaries, third party benefits providers.
If any of the personal information you have given to us changes, such as your contact details, please inform us without delay by contacting recruitment@eversheds-sutherland.com.
What do we do with your personal data, and why?
We process your personal data for particular purposes in connection with your application or engagement with us, and in connection with the management and administration of recruitment activities and strategies.
We are required by law to always have a “lawful basis” (ie a reason or justification) for processing your personal data. There are six lawful bases for processing – they are set out in the law, and they are where:
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the individual has given his or her consent to the processing;
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the processing of the individual’s personal data is necessary to perform a contract with that individual or to take steps at the request of the individual before entering into a contract;
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the processing is necessary to comply with a legal obligation to which we are subject;
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the processing is necessary in order to protect the vital interests of an individual;
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the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us; and
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the processing is necessary for our legitimate interests, provided those interests are not overridden by the individual’s interests, rights or freedoms.
The table at
Schedule 2
sets out the different purposes for which we process your personal data and the relevant lawful basis on which we rely for that processing.
If you would like more information on any of the purposes for which we process your personal data, please contact the Risk team at datagovernance@eversheds-sutherland.com for more information.
Please note that:
where our processing is based on your consent,
you can withdraw your consent
at any time. If you do this, it won’t impact any processing we’ve done prior to that date.
where we process your personal data because it is necessary for our legitimate interests, you
can object
to our processing at any time. If you object, we will stop processing unless we can show you a compelling reason why the processing overrides your privacy rights or where the processing is for the establishment, exercise or defence of legal claims.
In addition, where we have indicated in
Schedule 2
that our processing of your personal data is either:
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necessary for us to comply with a legal obligation; or
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necessary for us to take steps, at your request, to potentially enter into an employment contract with you, or to perform it,
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and you choose not to provide the relevant personal data to us, we may not be able to enter into our contract of employment or engagement with you.
Automated decision-making
Sometimes, we may use your personal data for automated decision making (in other words, decision-making without any human involvement), for example when we set up automated alerts in our background checking processes.
If any of our automated decision-making has legal or other significant effects on you, we will only make those decisions if:
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it is necessary for us to enter into or perform a contract with you; or
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it is authorised by applicable law; or
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we have your explicit consent.
Anonymised and aggregated data
We may also convert your personal data into statistical or aggregated form to better protect your privacy, or so that you are not identified or identifiable from it. Anonymised data cannot be linked back to you. We may use it to conduct research and analysis, including to produce statistical research and reports. For example, to help us understand which of our practice groups attract the most applicants.
Sensitive personal data (including criminal data)
We are required by law to treat certain categories of personal data with even more care than usual. These are called special categories of personal data – and in this notice, we refer to them as “
sensitive personal data
”. For these categories of personal data, different lawful bases apply.
The table at
Schedule 3
sets out the different purposes for which we process your sensitive personal data and the relevant lawful basis on which we rely for that processing. For some processing activities, we consider that more than one legal basis may be relevant – depending on the circumstances.
Who do we share your personal data with, and why?
Sometimes we need to disclose your personal data to other people.
Inside the Eversheds Sutherland network
We are part of the Eversheds Sutherland network of law firms. Therefore, we may share your personal data with other entities in the Eversheds Sutherland network for our general recruitment analysis and workforce management purposes.
Access rights between members of the Eversheds Sutherland network are limited and granted only on a need to know basis, depending – for example – jurisdictions, departments, job functions and roles.
Where any Eversheds Sutherland entities process your personal data on our behalf (as our processor), we will make sure that they have appropriate security standards in place to make sure your personal data is protected and we will enter into a written contract imposing appropriate security standards on them.
Outside the Eversheds Sutherland network
From time to time we may ask third parties to carry out certain business functions for us, such as the administration of our payroll and our IT support. These third parties will process your personal data on our behalf (as our processor). We will disclose your personal data to these parties so that they can perform those functions. Before we disclose your personal data to other people, we will make sure that they have appropriate security standards in place to make sure your personal data is protected and we will enter into a written contract imposing appropriate security standards on them. Examples of these third party service providers include service providers and/or sub-contractors, include our outsourced payroll, HR and marketing service providers, and our IT systems software and maintenance, back up, and server hosting providers.
In certain circumstances, we will also disclose your personal data to third parties who will receive it as controllers of your personal data in their own right for the purposes set out above, in particular:
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if we transfer, purchase, reorganise, merge or sell any part of our business or the business of a third party, and we disclose or transfer your personal data to the prospective seller, buyer or other third party involved in a business transfer, reorganisation or merger arrangement (and their advisors); and
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if we need to disclose your personal data in order to comply with a legal obligation, to enforce a contract or to protect the rights, property or safety of our employees, clients or others.
We have set out below a list of the categories of recipients with whom we are likely to share your personal data:
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consultants and professional advisors including legal advisors and accountants;
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recruitment agencies appointed by us or you;
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courts, court-appointed persons/entities, receivers and liquidators;
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business partners and joint ventures;
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trade associations and professional bodies;
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insurers; and
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governmental departments, statutory and regulatory bodies.
Where in the world is your personal data transferred to?
As we are an international network of law firms operating under a single brand, we may transfer your personal data to recipients that are established in jurisdictions other than your own. The data protection laws in these jurisdictions may not provide the same level of protection to your personal data as provided to it in your jurisdiction.
If you are employed or engaged by an Eversheds Sutherland entity in the United Kingdom or European Union and any disclosures of personal data referred to above require us to transfer your personal data from within the European Union to outside the European Economic Area, or from within the United Kingdom to outside the United Kingdom, we will only make that transfer if:
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the country to which the personal data is to be transferred ensures an adequate level of protection for personal data;
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we have put in place appropriate safeguards to protect your personal data, such as an appropriate contract with the recipient. Please contact our Data Protection Office at datagovernance@eversheds-sutherland.com if you wish to obtain a copy of these;
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the transfer is necessary for one of the reasons specified in data protection legislation, such as the performance of a contract between us and you; or
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you explicitly consent to the transfer.
How do we keep your personal data secure?
We will take specific steps (as required by applicable data protection laws) to protect your personal data from unlawful or unauthorised processing and accidental loss, destruction or damage.
How long do we keep your personal data for?
If you are our employee we will keep your personal data during the period of your employment and then, after your employment with us ends, for as long as is necessary in connection with both our and your legal rights and obligations. This may mean that we keep some types of personal data for longer than others.
We will only retain your personal data for a limited period of time. This will depend on a number of factors, including:
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any laws or regulations that we are required to follow;
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whether we are in a legal or other type of dispute with each other or any third party;
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the type of information that we hold about you; and
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whether we are asked by you or a regulatory authority to keep your personal data for a valid reason.
Please contact our Data Protection Office at datagovernance@eversheds-sutherland.com to request a copy of our Data Retention Policy.
What are your rights in relation to your personal data and how can you exercise them?
You may have certain legal rights in relation to your personal data, particularly where the Eversheds Sutherland entity you are applying to is based in the United Kingdom or European Union which are summarised at Schedule 4, in relation to any personal data about you which we hold.
Where our processing of your personal data is based on your consent (see Schedule 2), you have the right to withdraw your consent at any time. If you do decide to withdraw your consent we will stop processing your personal data for that purpose, unless there is another lawful basis we can rely on – in which case, we will let you know. Your withdrawal of your consent won’t impact any of our processing up to that point.
Where our processing of your personal data is necessary for our legitimate interests (see Schedule 2), you can object to this processing at any time. If you do this, we will need to show either a compelling reason why our processing should continue, which overrides your interests, rights and freedoms or that the processing is necessary for us to establish, exercise or defend a legal claim.
If you wish to exercise any of these rights please contact dataprotectionoffice@everhseds-sutherland.com in the first instance.
If you are based in the European Union or United Kingdom or you are applying for a position with an ES entity based in the European Union or United Kingdom, you also have the right to lodge a complaint with the relevant data protection supervisory authority – for contact details see here.
Updates to this notice
We may update this notice from time to time to reflect changes to the type of personal data that we process and/or the way in which it is processed. We will update you on material changes to this notice by email and we will publish revised versions of this notice on www.eversheds-sutherland.com.
Where can you find out more?
If you have any queries about how Eversheds Sutherland process your personal data, please contact the Risk team at datagovernance@eversheds-sutherland.com.
SCHEDULE 1
Categories of personal data
The table below sets out the different categories of personal data we collect and where we get it from (we’ve sorted them into groups, to make it more clear for you). As you can see, we collect your personal information from you directly and sometimes we obtain it from other people and organisations, including some public sources, such as publicly available directories and online resources, your emergency contacts, your use of Eversheds Sutherland provided assets, systems and platforms, your line manager and co-workers, your dependants and beneficiaries, third party benefits providers.
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Types of personal data
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Collected from
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a) Contact Information
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Name(s)
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Address(es)
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Email address(es)
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Contact details including mobile telephone number(s)
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b) Personal Information
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Date of birth
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Gender
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Next of kin or other dependants
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Marital or relationship status
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Lifestyle and social circumstances
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Emergency contact information
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If successful: Previous and offered salary, compensation and other benefits National insurance number and tax codes Bank account details
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You
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Recruitment consultants and agencies
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Your previous employers
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c) Identity and Background Information
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LinkedIn profile and other available professional background information about you online
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Career history, experience and skills
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Passport information
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Driving licence information
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Psychometric test results
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Right to work, residency and/or other visa information (where unrelated to your race or ethnicity)
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Curriculum Vitae (CV) or resume
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Details of education, qualifications, results and certificates and other evidence of the same
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Image or photographs
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Application form
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Evaluative notes and decisions from job interviews
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Preferences relating to job location and salary
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Conflicts of interests (including where related to family networks)
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Background checks relating to credit history and criminal records (see also Sensitive Personal Data below)
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You
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Recruitment consultants and agencies
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Your previous employers
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Publicly available information from online resources
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d) Sensitive Personal Data (see section 5 for further information)
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Racial or ethnic origin (including your nationality and visa information)
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Political opinions
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Religious or philosophical beliefs
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Trade union membership
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Data concerning physical and/or mental health (including occupational health requirements, accident reports, day-to-day health concerns such as diabetes or epilepsy conditions which we should be aware of, dietary requirements, allergies, drug and alcohol test results and reasons for any short term or long term absence)
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Sexual orientation
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Information relating to actual or suspected criminal convictions and offences
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You
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Your emergency contact(s)
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Your use of Eversheds Sutherland security control systems
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e)Recruitment Administration, Performance and Grievance Information
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Offered terms and conditions of employment
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Working preferences and feedback in relation to Eversheds Sutherland and our staff
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Preference in relation to our use of your personal data
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Interview notes and associated feedback
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Complaints, grievance and employment tribunal information
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f)Asset, Systems and Platform Usage and Communications Information
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User IDs and password information
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IP addresses and device identifiers
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Relevant records of calls, telephone/video interviews, messages and/or internet or other data traffic and communications
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Access logs and usage records from application systems and other Eversheds Sutherland provided applications and technologies
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You
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Your use of Eversheds Sutherland assets, systems and platforms
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g)Security, Location and Access Information
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Information captured or recorded by electronic card access systems, CCTV and other security control systems
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You
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Your use of Eversheds Sutherland security control systems
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SCHEDULE 2
Purposes for processing personal data
The table below sets out the different purposes for which we process your personal data and the relevant lawful basis on which we rely for that processing.
For some processing activities, we consider that more than one lawful basis may be relevant – depending on the circumstances.
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Lawful basis
We are permitted to process your personal data because...
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Purposes of processing
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You have given your consent to the processing
(Please also see section 10.2)
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It is necessary to perform your employment contract
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It is necessary for us to comply with a legal obligation
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It is necessary for our legitimate interests or those of third parties
(Please also see section 10.3)
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It is necessary to protect your vital interests (or those of someone else)
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New joiner activities
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Developing, operating and collecting feedback on recruitment activities and employee selection processes
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Administering your application for a job with us and considering your suitability for the relevant role
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Obtaining, considering and verifying your employment references and employment history
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Reviewing and confirming your right to work
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Conducting verification and vetting, including criminal background checks and credit checks where required by law (Note: Sensitive Personal Data, please also see Schedule 3)
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Conducting background checks, credit checks, verification and vetting which are not required by law but needed by us to assess your suitability for your role
(Note: May involve Sensitive Personal Data, please also see Schedule 3)
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Making a job offer to you and entering into a contract of employment with you
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Identifying and assessing our strategic business direction, resourcing needs and areas for development
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Analysing recruitment and retention objectives, processes and employee turnover rates
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Communicating with you and providing you with information in connection with your application or engagement with us from time to time
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General staff administration, including workforce management and facilities operations
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Managing our health and safety compliance obligations (Note: Sensitive Personal Data, please also see Schedule 3)
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Determining whether any adjustments are necessary to enable you to carry out a role (Note: Sensitive Personal Data, please also see Schedule 3)
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Considering your suitability for existing and future vacancies
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Handling grievances and complaints, including investigating issues, considering appropriate resolution and mitigating actions and reviewing outcomes
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Responding to feedback from you or your recruitment agent
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Security and governance
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Monitoring the security of Eversheds Sutherland’s physical premises and systems, networks and applications
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Identifying and authenticating applicants and other individuals (Note: Sensitive Personal Data, please also see Schedule 3)
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Identifying, investigating and mitigating suspected misuse of Eversheds Sutherland’s assets, systems and platforms (Note: Sensitive Personal Data, please also see Schedule 3)
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Ensuring compliance with Eversheds Sutherland policies and procedures (Note: Sensitive Personal Data, please also see Schedule 3)
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Legal and regulatory compliance and responsibilities
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Managing and administering our equal opportunities reporting (Note: Sensitive Personal Data, please also see Schedule 3)
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Responding to binding requests or search warrants or orders from courts, governmental, regulatory and/or enforcement bodies and authorities (Note: Sensitive Personal Data, please also see Schedule 3)
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Responding to non-binding requests or search warrants or orders from courts, governmental, regulatory and/or enforcement bodies and authorities
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Complying with disclosure orders arising in civil proceedings (Note: Sensitive Personal Data, please also see Schedule 3)
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Investigating, evaluating, demonstrating, monitoring, improving, reporting on and meeting Eversheds Sutherland’s compliance with relevant legal and regulatory requirements (Note: Sensitive Personal Data, please also see Schedule 3)
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Investigating, evaluating, demonstrating, monitoring, improving, reporting on and meeting Eversheds Sutherland’s compliance with best practice and good governance responsibilities
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Eversheds Sutherland business operations
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Implementing, adapting and enhancing systems and processes to develop or improve our business and/or our recruitment process
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Managing, planning and delivering events, projects and initiatives in connection with our global business, Finance, Sales, HR, IT, Marketing and other strategies (for example arranging partner and practice group conferences)
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Supporting our diversity programmes and targets (Note: Sensitive Personal Data, please also see Schedule 3)
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Supporting, updating and maintaining our technology infrastructure
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Supporting the sale, transfer or merging of part or all of our business or assets, or in connection with the acquisition of another business
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Analysing recruitment-related objectives and results
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Collecting feedback in relation to our recruitment and HR activities and processes for continuous improvement purposes
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SCHEDULE 3
Purposes for processing sensitive personal data
The table below sets out the different purposes for which we process your sensitive personal data and the relevant lawful basis on which we rely for that processing. For some processing activities, we consider that more than one legal basis may be relevant – depending on the circumstances.
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Sensitive Information - lawful basis
We are permitted to process your personal data because...
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Purposes of processing
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You have given your explicit consent to the processing
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It is necessary for your/our obligations and rights in the field of employment and social security and social protection law
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It is necessary to protect the vital interests of the data subject or another person you or they are physically or legally incapable of giving consent
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It is necessary for our establishment, exercise or defence of legal claims
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It is necessary for reasons of substantial public interest
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It is necessary for preventive or occupational medicine, for the assessment of the working capacity of the employee
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Recruitment and workforce planning
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Conducting verification and vetting, including criminal background checks and credit checks where required by law
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Conducting background checks, verification and vetting which are not required by law but needed by us to assess your suitability for your role
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General application management and administration
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Managing our health and safety compliance obligations
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Determining whether any adjustments are necessary to enable you to carry out a role
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Security and governance
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Identifying and authenticating Applicants and other individuals
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Identifying, investigating and mitigating suspected misuse of our assets, systems and platform
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Legal and regulatory compliance and responsibilities
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Managing and administering our equal opportunities reporting
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Responding to binding requests or search warrants or orders from courts, governmental, regulatory and/or enforcement bodies and authorities or sharing information (on a voluntary basis) with the same
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Responding to non-binding requests or search warrants or orders from courts, governmental, regulatory and/or enforcement bodies and authorities
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Complying with disclosure orders arising in civil proceedings
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Investigating, evaluating, demonstrating, monitoring, improving and reporting on our compliance with relevant legal and regulatory requirements
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Investigating, evaluating, demonstrating, monitoring, improving, reporting on and meeting our compliance with best practice and good governance responsibilities
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Day-to-day business operations
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Supporting the sale, transfer or merging of part or all of our business or assets, or in connection with the acquisition of or by another business
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SCHEDULE 4
Individuals' rights
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Your right
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What does it mean?
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Limitations and conditions of your right
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Right of access
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Subject to certain conditions, you are entitled to have access to your personal data (this is more commonly known as submitting a “data subject access request”).
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If possible, you should specify the type of information you would like to see to ensure that our disclosure is meeting your expectations.
We must be able to verify your identity. Your request may not impact the rights and freedoms of other people, eg privacy and confidentiality rights of other staff.
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Right to data portability
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Subject to certain conditions, you are entitled to receive the personal data which you have provided to us and which is processed by us by automated means, in a structured, commonly-used machine readable format.
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If you exercise this right, you should specify the type of information you would like to receive (and where we should send it) where possible to ensure that our disclosure is meeting your expectations.
This right only applies if the processing is based on your consent or on our contract with you and when the processing is carried out by automated means (ie not for paper records). It covers only the personal data that has been provided to us by you.
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Rights in relation to inaccurate personal or incomplete data
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You may challenge the accuracy or completeness of your personal data and have it corrected or completed, as applicable. You have a responsibility to help us to keep your personal information accurate and up to date.
We encourage you to notify us of any changes regarding your personal data as soon as they occur, including changes to your contact details, telephone number, immigration status.
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Please always check first whether there are any available self-help tools to correct the personal data we process about you.
This right only applies to your own personal data. When exercising this right, please be as specific as possible.
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Right to object to or restrict our data processing
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Subject to certain conditions, you have the right to object to or ask us to restrict the processing of your personal data.
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As stated above, this right applies where our processing of your personal data is necessary for our legitimate interests.
You can also object to our processing of your personal data for direct marketing purposes.
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Right to erasure
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Subject to certain conditions, you are entitled to have your personal data erased (also known as the “right to be forgotten”), eg where your personal data is no longer needed for the purposes it was collected for, or where the relevant processing is unlawful.
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We may not be in a position to erase your personal data, if for example, we need it to (i) comply with a legal obligation, or (ii) exercise or defend legal claims.
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Right to withdrawal of consent
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As stated above, where our processing of your personal data is based on your consent you have the right to withdraw your consent at any time.
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If you withdraw your consent, this will only take effect for future processing.
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someone else (such as a customer of an Eversheds Sutherland client, supplier or press contact etc)
Last updated: July 2023
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About this notice
This Privacy Notice applies to the Eversheds Sutherland network of law firms except for the ES entities in Austria, Finland, Hungary, Ireland, Italy, Sweden and Switzerland, which have their own Privacy Notices that apply instead.
This notice explains how and why Eversheds Sutherland use your personal data in connection with our legal advice and related services and our general business operations. You should read this notice if you are not an Eversheds Sutherland client but you are dealing with us in relation to any service that we provide, where you are providing us with a service or where you are a different type of third party whether or not in communication with us.
For the purposes of this notice, the
controller
will be the relevant ES entity providing the services which are relevant to your matter with us, or if you are a supplier, the relevant ES entity that you are contracting with (or looking to contract with) or for some other types of third party the ES entity which is providing advice to its client.
Click here for a list of the Eversheds Sutherland operating entities
and their contact details. (In limited circumstances, where we work with a consultant to provide legal advice, we and the consultant may be joint controllers of your personal data in relation to the consultant’s processing to provide legal advice. Where this is the case, it will be notified to you by the consultant, to the extent that you have contact with the consultant. If you have any questions about our joint controllership with a consultant, or to exercise your rights in relation to personal data which is jointly controlled, please contact us as set out in this notice.)
In this notice, when we talk about
personal data
we mean any information that relates to an identifiable natural person – in this case, you.
You should read this notice, so you know what personal data we collect about you, what we do with it and how you can exercise your rights in connection with it. You should also read any other privacy notices that we give you, that might apply to our use of your personal data in specific circumstances from time to time. If you have any questions about this notice, please contact
datagovernance@eversheds-sutherland.com
.
What types of personal data do we collect and where do we get it from?
The personal information we process about you broadly falls into four main categories: (i) Contact Information; (ii) Identity and Other Regulatory Information; (iii) Matter Information; (iv) Browsing and Device Usage Information; and in some limited cases (v) other publicly available information.
Where necessary and lawful for the purposes set out below, we collect your personal information from various sources. The table below sets out the different types of personal information that we collect and the sources we collect it from.
|
Category
|
Types of personal data
|
Collected from
|
|
Contact Information
|
-
Name
-
Address
-
Telephone number
-
Organisation details (e.g. your place of work, job title and organisation contact information)
|
-
Our clients
-
You
-
Publicly available resources such as LinkedIn and Google
|
|
Identity and Other Regulatory Information
|
-
Date of birth
-
Identification information (e.g. passport, utility bill and/or bank statement)
|
-
You
-
Third party systems used for our regulatory checks
|
|
Matter Information
|
-
Details relating to client matters, enquiries and other dealings with us or our clients (including matter related communications with you and other information about you in connection with such matters)
|
-
Our clients
-
You
-
Third parties also working on your matter
|
|
Browsing and Device Usage Information
|
-
Information automatically generated through your use of our websites and other digital platforms
-
IP address
-
Information revealing the location of your electronic device
|
-
You and your use of our digital platforms
|
|
Other publicly available information
|
-
Names
-
Addresses
-
Dates of birth
-
other personal special category and criminal convictions data which is lawfully available to us
|
-
Official government department lists (e.g. sanctions list) which are publicly available
|
Please note
that if you do not provide us with your Contact Information we may not be able to provide you with any information you request, and if you are a supplier or prospective supplier and you do not provide us with your Contact Information, Identity and Other Regulatory Information or Matter Information, we may not be able to enter into a contract with you.
What do we do with your personal data, and why?
We use your personal data for a number of different purposes. We must always have a “lawful basis” (i.e. a reason, prescribed by law) for processing your personal data. The
Personal data table
below sets out the purposes for which we process the different categories of your personal data and the corresponding lawful basis for that processing. The purposes applicable to you will vary according to the relevant Eversheds Sutherland controller of your personal data (as explained in the introductory paragraph above). For some processing activities, we consider that more than one lawful basis may be relevant – depending on the circumstances.
We also process certain
special categories of personal data
, which require a higher standard of protection under applicable laws. For these
special categories of personal data
, different lawful bases apply. We only process this type of information about you where it is necessary for the establishment, exercise or defence of a legal claim or where it is necessary for reasons of substantial public interest, for example we process racial or ethnic origin, political opinions, religious, cultural or philosophical beliefs, health, sex life or orientation and criminal convictions data in relation to individuals on official government department lists (e.g. sanctions lists) which are publicly available on the basis that this is necessary for reasons of substantial public interest for preventing or detecting unlawful acts.
We may also process certain information relating to criminal convictions and offences where applicable, which require a higher standard of protection under applicable laws. We also have policies in place explaining our procedures for ensuring compliance with applicable laws in connection with the processing of special categories of personal data.
Cookies and similar technologies
For more information regarding how we use cookies and similar technologies in connection with your use of our platforms, please read our
Cookies Policy
.
Who do we share your personal data with, and why?
Sometimes we share your personal data with third parties where permitted by law, including the following:
-
other companies in or branches or offices of the Eversheds Sutherland network of firms where necessary in connection with the legal matters we are instructed on or with our business operations. You can find a list of the countries in which we operate on our
Contact Us page
;
-
our clients, barristers, other law firms and courts, service providers and the courts as applicable in the context of the legal services we provide to our clients;
-
courts and other judicial or official bodies, where we are asked to respond to an order or other binding requests;
-
regulatory bodies and law enforcement agencies, where necessary for any investigations or to respond to enquiries in relation to our compliance with applicable law or regulations or in connection with criminal investigations, or where otherwise permitted or required by applicable law; and
-
professional advisors (such as third party law firms and accountants) and third parties in connection with our legitimate business activities.
These organisations will also use your personal data as a “controller” – they will have their own privacy notices which you should read, and they have their own responsibilities to comply with applicable data protection laws.
We also ask third party service providers to carry out certain business functions for us. These include IT support, cloud platform and data hosting providers who help us with the operation of our websites, mobile applications, data rooms, document and workflow management systems and other systems and applications. We will have in place an agreement with our service providers which will restrict how they are able to process your personal data and impose appropriate security standards on them.
Where is your personal data transferred to?
Since Eversheds Sutherland is a network of different law firms operating globally, we will sometimes need to transfer your personal data to recipients in jurisdictions other than your own. Some of these jurisdictions may not provide the same level of protection to your personal data as provided in your jurisdiction. If we transfer your personal data outside the European Union or the United Kingdom, we will only make that transfer if:
-
the recipient country ensures an adequate level of protection for your personal data; or
-
the recipient or recipient country is subject to an approved certification mechanism or code of conduct with binding and enforceable commitments which amount to appropriate safeguards for your personal data; or we have put in place appropriate safeguards to protect your personal data, such as a contract with the person or entity receiving your personal data which incorporates specific provisions as directed by the European Commission; or
-
the transfer is permitted by applicable laws; or
-
you explicitly consent to the transfer.
If you would like to see a copy of any relevant safeguards used by us to protect the transfer of your personal data, please contact
datagovernance@eversheds-sutherland.com
.
How do we keep your personal data secure?
We will put in place appropriate security measures to protect your personal data from unlawful or unauthorised processing and accidental loss, destruction or damage.
However please note that, in relation to any personal data you submit to us online, we cannot guarantee the security of data sent to us in this way. Transmission of data over the internet is at your own risk. You are responsible for keeping any passwords you use to access Eversheds Sutherland platforms safe.
How long do we keep your personal data for?
We will only retain your personal data for a limited period of time, and for no longer than is necessary for the purposes for which we are processing it for. This will depend on a number of factors, including:
-
any laws or regulations that we are required to follow;
-
whether we are in a legal or other type of dispute with each other or any third party;
-
the type of information that we hold about you; and
-
whether we are asked by you or a regulatory authority to keep your personal data for a valid reason.
What are your privacy rights and how can you exercise them?
Where our processing of your personal data is based on your
consent
, you have the right to withdraw your consent at any time. If you do decide to withdraw your consent we will stop processing your personal data for that purpose, unless there is another lawful basis we can rely on – in which case, we will let you know.
Where
our processing of your personal data is based on the
legitimate interests
lawful basis, you can object to this processing at any time. If you do this, we will need to show either a compelling reason why our processing should continue, which overrides your interests, rights and freedoms or that the processing is necessary for us to establish, exercise or defend a legal claim.
Depending on the circumstances, you may have the right to:
-
access your personal data and to be provided with certain information in relation to it, such as the purpose for which it is processed, the recipients or categories of recipient to whom it is disclosed and the period for which it will be stored;
-
require us to correct any inaccuracies in your personal data without undue delay;
-
require us to erase your personal data;
-
require us to restrict processing of your personal data;
-
receive the personal data which you have provided to us, in a machine readable format, where we are processing it on the basis of your consent or because it is necessary for your contract with us and where the processing is automated; and
-
object to a decision that we make which is based solely on automated processing of your personal data.
Please contact us at
datagovernance@eversheds-sutherland.com
if you would like to exercise any of your privacy rights.
We also encourage you to let us know if you have any concern about how we are processing your personal data so we can try to resolve your concerns. However, if you consider that we are in breach of our obligations under data protection laws, you are always entitled to submit a complaint with your data protection supervisory authority – for contact details
see here
.
Purposes for processing personal data
|
|
Lawful basis
|
|
Purposes of processing
|
Your consent
|
To perform a contract with you
|
To comply with a legal obligation
|
For our legitimate interests
|
|
Matter Related Purposes
|
|
|
|
|
|
Responding to your enquiries
|
|
|
|
(It is important that we can respond to your enquiries)
|
|
Resolving any complaints from or disputes with you
|
|
|
|
(We need to be able to try and resolve any complaint or dispute you might raise with us)
|
|
Performing identity checks (including those against third party sources) for identity verification purposes
|
|
|
|
(We need to verify the identities of people we deal with)
|
|
Carrying out various tasks and services in connection with our clients’ matters which may involve you (eg arranging for monies due to you to be paid, sending you documents in relation to a court case or consulting and further processing documents which relate to you, or providing information about you which is on official government department lists (e.g. sanctions lists) which are publicly available to our clients)
|
|
|
|
(We need to be able to carry out the tasks required in connection the provision of legal advice to our clients and other related services)
|
|
Legal and Regulatory Compliance and Reporting
|
|
|
|
|
|
Monitoring our systems and processes to identify, record, and prevent fraudulent, criminal and/or otherwise illegal activity
|
|
|
|
(We need to be able to monitor our systems in this way to help protect them, us and you from illegal activity)
|
|
Complying with instructions, orders and requests from law enforcement agencies, any court or otherwise as required by law
|
|
|
|
|
|
Complying with our general regulatory and statutory obligations (including our responsibilities under codes of conduct and anti-bribery laws)
|
|
|
|
|
|
Purchasing, maintaining and claiming against our insurance policies
|
|
|
|
(It' ss in our interests to protect our business against specified losses)
|
|
Training our staff
|
|
|
|
(Sometimes, it is appropriate for us to use your personal information so that we can provide our staff with training to manage risk and improve the quality of our services)
|
|
Continuously reviewing and improving our products and services (including by seeking and obtaining your feedback) and developing new ones
|
|
|
|
(We have a legitimate interest in making sure that we are continuously improving our service offering)
|
|
Complying with instructions from our clients in relation to their regulatory obligations (including recording our telephone communications with you)
|
|
|
|
(Sometimes, we need to record calls to our teams to assist with our clients’ regulatory obligations, and for training and quality purposes)
|
|
General Business Requirements
|
|
|
|
|
|
Obtaining legal advice, and establishing, defending and enforcing our legal rights and obligations in connection with, any legal proceedings (including prospective legal proceedings)
|
|
|
|
(We must be able to establish and defend our legal rights and understand our obligations, and seek legal advice in connection with them)
|
|
Monitoring and producing statistical information regarding the use of our platforms, and analysing and improving their functionality
|
|
|
|
(We need to perform this limited routine monitoring to make sure our platforms work properly)
|
|
Managing the proposed sale, restructuring, transfer or merging of any or all part(s) of our business, including to respond to queries from the prospective buyer or merging organisation
|
|
|
|
(We have a legitimate interest in being able to sell any part of our business)
|
|
Maintaining the security and integrity of our systems, platforms, premises and communications (and detecting and preventing actual or potential threats to the same)
|
|
|
|
(We need to make sure our that our business processes are secure)
|
applying for or considering applying for a training contract, vacation scheme, apprenticeship or other work experience at Eversheds Sutherland
Ths Privacy Notice applies to the Eversheds Sutherland (International) LLP only.
Last updated: May 2022
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What is this document and why should you read it?
This notice explains how and why Eversheds Sutherland uses personal data about individuals who apply (or enquire about applying) to become our trainees, vacation scheme students, apprentices and/or other work experience students (referred to as “
applicants
” or “
you
”). For the purposes of this notice, the
controller
will be the Eversheds Sutherland entity that you are applying for a role with (the controller is also referred to in this notice as “
Eversheds Sutherland
”, “
ES
” “
we
”, “
our
” and “
us
”).
You should read this notice, so you know what we are doing with your personal data. Please also read any other privacy notices that we give you, that might apply to our use of your personal data in specific circumstances in the future. For example, if you are successful in your application you should read our HR Privacy Notice when you join us.
This notice does not form part of any contract between us and you (including any contract of employment that may be offered or any other services contract).
Eversheds Sutherland’s data protection responsibilities
“
Personal data
” is any information that relates to an identifiable natural person. Your name, address, contact details, salary details and CV are all examples of your personal data, if they identify you.
The term “
process
” means any activity relating to personal data, including, by way of example, collection, storage, use, consultation and transmission.
Eversheds Sutherland is a "
controller
" of your personal data. This is a legal term – it means that we make decisions about how and why we process your personal data and, because of this, we are responsible for making sure it is used in accordance with data protection laws.
What types of personal data do we collect and where do we get it from?
We collect many different types of personal data about you for lots of reasons. We cannot administer your application without your personal data. Where we don’t need your personal data, we will make this clear, for instance we will explain if any data fields in our application forms are optional and can be left blank.
Further details of the personal data we collect and where we get it from are set out at
Schedule 1
.
As you can see from the table at
Schedule 1
, we collect your personal information from you directly and sometimes we obtain it from other people and organisations, including some public sources, such as publicly available directories and online resources, your emergency contacts, your use of Eversheds Sutherland provided assets, systems and platforms, your line manager and co-workers, your dependants and beneficiaries, third party benefits providers.
If any of the personal information you have given to us changes, such as your contact details, please inform us without delay by contacting gradrec@eversheds-sutherland.com.
What do we do with your personal data, and why?
We process your personal data for particular purposes in connection with your application or engagement with us, and in connection with the management and administration of recruitment activities and strategies.
We are required by law to always have a “lawful basis” (i.e. a reason or justification) for processing your personal data. There are six lawful bases for processing – they are set out in the law, and they are where:
-
the individual has given his or her consent to the processing;
-
the processing of the individual’s personal data is necessary to perform a contract with that individual or to take steps at the request of the individual before entering into a contract;
-
the processing is necessary to comply with a legal obligation to which we are subject;
-
the processing is necessary in order to protect the vital interests of an individual;
-
the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us; and
-
the processing is necessary for our legitimate interests, provided those interests are not overridden by the individual’s interests, rights or freedoms.
The table at
Schedule 2
sets out the different purposes for which we process your personal data and the relevant lawful basis on which we rely for that processing.
If you would like more information on any of the purposes for which we process your personal data, please contact the Risk team at datagovernance@eversheds-sutherland.com for more information.
Please note that:
-
where our processing is based on your consent,
you can withdraw your consent
at any time. If you do this, it won’t impact any processing we’ve done prior to that date.
-
where we process your personal data because it is necessary for our legitimate interests,
you can object
to our processing at any time. If you object, we will stop processing unless we can show you a compelling reason why the processing overrides your privacy rights or where the processing is for the establishment, exercise or defence of legal claims.
In addition, where we have indicated in
Schedule 2
that our processing of your personal data is either:
-
necessary for us to comply with a legal obligation; or
-
necessary for us to take steps, at your request, to potentially enter into an employment contract with you, or to perform it, and you choose not to provide the relevant personal data to us, we may not be able to enter into our contract of employment or engagement with you.
Anonymised and aggregated data
We may also convert your personal data into statistical or aggregated form to better protect your privacy, or so that you are not identified or identifiable from it. Anonymised data cannot be linked back to you. We may use it to conduct research and analysis, including to produce statistical research and reports, and to support our contextual recruitment and diversity initiatives.
Sensitive personal data (including criminal data)
We are required by law to treat certain categories of personal data with even more care than usual. These are called special categories of personal data – and in this notice, we refer to them as “
sensitive personal data
”. For these categories of personal data, different lawful bases apply.
The table at
Schedule 3
sets out the different purposes for which we process your sensitive personal data and the relevant lawful basis on which we rely for that processing. For some processing activities, we consider that more than one legal basis may be relevant – depending on the circumstances.
Who do we share your personal data with, and why?
Sometimes we need to disclose your personal data to other people.
Inside the Eversheds Sutherland network
We are part of the Eversheds Sutherland network of law firms. Therefore, we may share your personal data with other entities in the Eversheds Sutherland network for our general recruitment analysis and workforce management purposes.
Access rights between members of the Eversheds Sutherland network are limited and granted only on a need to know basis, depending – for example – jurisdictions, departments, job functions and roles.
Where any Eversheds Sutherland entities process your personal data on our behalf (as our processor), we will make sure that they have appropriate security standards in place to make sure your personal data is protected and we will enter into a written contract imposing appropriate security standards on them.
Outside the Eversheds Sutherland network
From time to time we may ask third parties to carry out certain business functions for us, such as the administration of our payroll and our IT support. These third parties will process your personal data on our behalf (as our processor). We will disclose your personal data to these parties so that they can perform those functions. Before we disclose your personal data to other people, we will make sure that they have appropriate security standards in place to make sure your personal data is protected and we will enter into a written contract imposing appropriate security standards on them. Examples of these third party service providers include service providers and/or sub-contractors, include our outsourced payroll, HR and marketing service providers, and our IT systems software and maintenance, back up, and server hosting providers.
In certain circumstances, we will also disclose your personal data to third parties who will receive it as controllers of your personal data in their own right for the purposes set out above, in particular:
-
if we transfer, purchase, reorganise, merge or sell any part of our business or the business of a third party, and we disclose or transfer your personal data to the prospective seller, buyer or other third party involved in a business transfer, reorganisation or merger arrangement (and their advisors); and
-
if we need to disclose your personal data in order to comply with a legal obligation, to enforce a contract or to protect the rights, property or safety of our employees, clients or others.
We have set out below a list of the categories of recipients with whom we are likely to share your personal data:
-
consultants and professional advisors including legal advisors and accountants;
-
recruitment agencies appointed by us or you;
-
courts, court-appointed persons/entities, receivers and liquidators;
-
business partners and joint ventures;
-
trade associations and professional bodies;
-
insurers; and
-
governmental departments, statutory and regulatory bodies.
Where in the world is your personal data transferred to?
As we are an international network of law firms operating under a single brand, we may transfer your personal data to recipients that are established in jurisdictions other than your own. The data protection laws in these jurisdictions may not provide the same level of protection to your personal data as provided to it in your jurisdiction.
If you are employed or engaged by an Eversheds Sutherland entity in the European Union or United Kingdom and any disclosures of personal data referred to above require us to transfer your personal data from within to outside the European Economic Area or United Kingdom, we will only make that transfer if:
-
the country to which the personal data is to be transferred ensures an adequate level of protection for personal data;
-
we have put in place appropriate safeguards to protect your personal data, such as an appropriate contract with the recipient. Please contact our Data Protection Office at datagovernance@eversheds-sutherland.com if you wish to obtain a copy of these;
-
the transfer is necessary for one of the reasons specified in data protection legislation, such as the performance of a contract between us and you; or
-
you explicitly consent to the transfer.
How do we keep your personal data secure?
We will take specific steps (as required by applicable data protection laws) to protect your personal data from unlawful or unauthorised processing and accidental loss, destruction or damage.
How long do we keep your personal data for?
If you are our employee we will keep your personal data during the period of your employment and then, after your employment with us ends, for as long as is necessary in connection with both our and your legal rights and obligations. This may mean that we keep some types of personal data for longer than others.
We will only retain your personal data for a limited period of time. This will depend on a number of factors, including:
-
any laws or regulations that we are required to follow;
-
whether we are in a legal or other type of dispute with each other or any third party;
-
the type of information that we hold about you; and
-
whether we are asked by you or a regulatory authority to keep your personal data for a valid reason.
Please contact our Data Protection Office at
datagovernance@eversheds-sutherland.com
to request a copy of our Data Retention Policy.
What are your rights in relation to your personal data and how can you exercise them?
You may have certain legal rights in relation to your personal data, particularly where the Eversheds Sutherland entity you are applying to is based in the United Kingdom or European Union which are summarised at
Schedule 4
, in relation to any personal data about you which we hold.
Where our processing of your personal data is based on your
consent
(see
Schedule 2
), you have the right to withdraw your consent at any time. If you do decide to withdraw your consent we will stop processing your personal data for that purpose, unless there is another lawful basis we can rely on – in which case, we will let you know. Your withdrawal of your consent won’t impact any of our processing up to that point.
Where our processing of your personal data is necessary for our
legitimate interests
(see
Schedule 2
), you can object to this processing at any time. If you do this, we will need to show either a compelling reason why our processing should continue, which overrides your interests, rights and freedoms or that the processing is necessary for us to establish, exercise or defend a legal claim.
If you wish to exercise any of these rights please contact
dataprotectionoffice@everhseds-sutherland.com
in the first instance.
If you are based in the United Kingdom or European Union or you are applying for a position with an ES entity based in the European Union or United Kingdom, you also have the right to lodge a complaint with the relevant data protection supervisory authority – for contact details see
here
.
Updates to this notice
We may update this notice from time to time to reflect changes to the type of personal data that we process and/or the way in which it is processed. We will update you on material changes to this notice by email and we will publish revised versions of this notice on
www.eversheds-sutherland.com
.
Where can you find out more?
If you have any queries about how Eversheds Sutherland process your personal data, please contact the Risk team at
datagovernance@eversheds-sutherland.com
.
Schedule 1 – Categories of personal data
The table below sets out the different categories of personal data we collect and where we get it from (we’ve sorted them into groups, to make it more clear for you). As you can see, we collect your personal information from you directly and sometimes we obtain it from other people and organisations, including some public sources, such as publicly available directories and online resources, your emergency contacts, your use of Eversheds Sutherland provided assets, systems and platforms, your line manager and co-workers, your dependants and beneficiaries, third party benefits providers.
|
Type of personal data
|
Collected from
|
|
a) Contact Information
|
Name(s)
Address(es)
Email address(es)
Contact details including mobile telephone number(s)
|
You
|
|
b) Personal Information
|
Date of birth
Gender
Next of kin or other dependants
Marital or relationship status
Lifestyle and social circumstances
Stage in education, further education and/or employment
Emergency contact information
If successful: previous and offered salary, compensation and other benefits, national insurance number and tax codes and bank account details
|
You
Recruitment consultants and agencies
Your previous employers
|
|
c) Identity and Background Information
|
LinkedIn profile and other available professional background information about you online
Career history, experience and skills
Passport information
Driving licence information
Psychometric test results
Right to work, residency and/or other visa information (where unrelated to your race or ethnicity)
Curriculum Vitae (CV) or resume
Details of education, qualifications, results and certificates and other evidence of the same
Images and/or video footage
Application form
Evaluative notes and decisions from job interviews
Preferences relating to job location and salary
Conflicts of interests (including where related to family networks)
Background checks relating to credit history and criminal records (see also Sensitive Personal Data below)
|
You
Recruitment consultants and agencies
Your previous employers
Publicly available information from online resources
|
|
d) Sensitive Personal Data (see section 5 for further information)
|
Racial or ethnic origin (including your nationality and visa information)
Religious or philosophical beliefs
Data concerning physical and/or mental health (including occupational health requirements, accident reports, day-to-day health concerns such as diabetes or epilepsy conditions which we should be aware of, dietary requirements, allergies, drug and alcohol test results and reasons for any short term or long term absence)
Sexual orientation
Information relating to actual or suspected criminal convictions and offences
|
You
Your emergency contact(s)
Your use of Eversheds Sutherland security control systems
|
|
e) Recruitment Administration, Performance and Grievance Information
|
Offered terms and conditions of employment
Working preferences and feedback in relation to Eversheds Sutherland and our staff
Preference in relation to our use of your personal data
Interview notes and associated feedback
Complaints, grievance and employment tribunal information
|
You
|
|
f) Asset, Systems and Platform Usage and Communications Information
|
User IDs and password information
IP addresses and device identifiers
Relevant records of calls, telephone and/or video interviews, messages and/or internet or other data traffic and communications
Access logs and usage records from application systems and other Eversheds Sutherland provided applications and technologies
|
You
Your use of Eversheds Sutherland assets, systems and platforms
|
|
g) Security, Location and Access Information
|
|
Information captured or recorded by electronic card access systems, CCTV and other security control systems
|
You
Your use of Eversheds Sutherland security control systems
|
Schedule 2 – Purposes for processing personal data
The table below sets out the different purposes for which we process your personal data and the relevant lawful basis on which we rely for that processing.
For some processing activities, we consider that more than one lawful basis may be relevant – depending on the circumstances.
Where our processing is necessary for our legitimate interests, those interests are the purposes listed below.
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Lawful basis
We are permitted to process your personal data because…
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Purposes of processing
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1. You have given your consent to the processing (Please also see section 10.2)
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2. It is necessary to perform a contract with you or because you have asked us to before entering into a contract
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3. It is necessary for us to comply with a legal obligation
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4. It is necessary for our legitimate interests or those of third parties (Please also see section 10.3)
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5. It is necessary to protect your vital interests (or those of someone else)
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Recruitment activities
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Sending you communications regarding our recruitment events, application deadlines and other recruitment related activities and processes
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Communicating with you and providing you with information in connection with our vacancies, our recruitment events and processes and/or your applications or engagement with us from time to time
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Administering your application for a job with us and considering your suitability for the relevant role
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Considering your suitability for existing and future vacancies
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Organising and conducting interviews by telephone, video and/or face-to-face
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Communicating with or providing feedback to you and/or your recruitment agent
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Obtaining, considering and verifying your employment references and employment history
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Reviewing and confirming your right to work
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Conducting verification and vetting, including criminal background checks and credit checks where required by law (
Note
: Sensitive Personal Data, please also see
Schedule 3
)
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Conducting background and credit checks, verification and vetting which are not required by law but needed by us to assess your suitability for your role (
Note
: May involve Sensitive Personal Data, please also see
Schedule 3
)
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New joiner activities
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Making a job offer to you and entering into a contract of employment with you
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Managing, administering and carrying out the systems, processes and tasks needed to facilitate the commencement and duration of your role with us
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Determining whether any adjustments are necessary to enable you to carry out a role (
Note
: Sensitive Personal Data, please also see
Schedule 3
)
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Security and governance
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Monitoring, maintaining and improving the security of Eversheds Sutherland’s physical premises and systems, networks and applications
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Identifying and authenticating applicants and other individuals (
Note
: Sensitive Personal Data, please also see
Schedule 3
)
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Identifying, investigating and mitigating suspected misuse of Eversheds Sutherland’s assets, systems and platforms (
Note
: Sensitive Personal Data, please also see
Schedule 3
)
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Ensuring compliance with Eversheds Sutherland policies and procedures (
Note
: Sensitive Personal Data, please also see
Schedule 3
)
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Legal and regulatory compliance and responsibilities
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Looking after the welfare of our staff (
Note
: Sensitive Personal Data, please also see
Schedule 3
)
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Managing our health and safety compliance obligations (Note: Sensitive Personal Data, please also see
Schedule 3
)
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Managing and administering our equal opportunities reporting (
Note
: Sensitive Personal Data, please also see
Schedule 3
)
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Responding to binding requests or search warrants or orders from courts, governmental, regulatory and/or enforcement bodies and authorities (
Note
: Sensitive Personal Data, please also see
Schedule 3
)
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Responding to non-binding requests or search warrants or orders from courts, governmental, regulatory and/or enforcement bodies and authorities
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Complying with disclosure orders arising in civil proceedings (
Note
: Sensitive Personal Data, please also see
Schedule 3
)
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Investigating, evaluating, demonstrating, monitoring, improving, reporting on and meeting Eversheds Sutherland’s compliance with relevant legal and regulatory requirements (
Note
: Sensitive Personal Data, please also see
Schedule 3
)
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Investigating, evaluating, demonstrating, monitoring, improving, reporting on and meeting Eversheds Sutherland’s compliance with relevant legal and regulatory requirements (
Note
: Sensitive Personal Data, please also see
Schedule 3
)
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Eversheds Sutherland business operations
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Decision-making in relation to the long term prospects of our vacation scheme students, work experience students, trainees and apprentices and more general promotion and succession planning
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Developing, operating and collecting feedback on recruitment activities and employee selection processes
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Analysing recruitment and retention objectives, processes and staff turnover rates
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Handling grievances and complaints, including investigating issues, considering appropriate resolution and mitigating actions and reviewing outcomes
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General staff administration, including workforce management and facilities operations
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Identifying and assessing our strategic business direction, resourcing needs and areas for development
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Implementing, adapting and enhancing systems and processes to develop or improve our business and/or our recruitment process
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Managing, planning and delivering events, projects and initiatives in connection with our global business, Finance, Sales, HR, IT, Marketing and other strategies (for example arranging partner and practice group conferences)
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Supporting our diversity programmes and targets (
Note
: Sensitive Personal Data, please also see
Schedule 3
)
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Supporting, updating and maintaining our technology infrastructure
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Supporting the sale, transfer or merging of part or all of our business or assets, or in connection with the acquisition of another business
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Analysing recruitment-related objectives and results
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Collecting feedback in relation to our recruitment and HR activities and processes for continuous improvement purposes
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Schedule 3 – Purposes for processing sensitive personal data
The table below sets out the different purposes for which we process your sensitive personal data and the relevant lawful basis on which we rely for that processing. For some processing activities, we consider that more than one legal basis may be relevant – depending on the circumstances.
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Sensitive Information - lawful basis
We are permitted to process your personal data because…
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Purposes of processing
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You have given your explicit consent to the processing
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It is necessary for your/our obligations and rights in the field of employment and social security and social protection law
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It is necessary to protect the vital interests of the data subject or another person you or they are physically or legally incapable of giving consent
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It is necessary for our establishment, exercise or defence of legal claims
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It is necessary for reasons of substantial public interest
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It is necessary for preventive or occupational medicine, for the assessment of the working capacity of the employee
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Recruitment and workforce planning
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Conducting verification and vetting, including criminal background checks and credit checks where required by law
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Conducting background checks, verification and vetting which are not required by law but needed by us to assess your suitability for your role
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General application management and administration
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Managing our health and safety compliance obligations
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Determining whether any adjustments are necessary to enable you to carry out a role
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Security and governance
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Identifying and authenticating Applicants and other individuals
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Identifying, investigating and mitigating suspected misuse of our assets, systems and platform
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Legal and regulatory compliance and responsibilities
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Managing and administering our equal opportunities reporting
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Reviewing and confirming your right to work Responding to binding requests or search warrants or orders from courts, governmental, regulatory and/or enforcement bodies and authorities or sharing information (on a voluntary basis) with the same
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Responding to non-binding requests or search warrants or orders from courts, governmental, regulatory and/or enforcement bodies and authorities
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Complying with disclosure orders arising in civil proceedings
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Investigating, evaluating, demonstrating, monitoring, improving and reporting on our compliance with relevant legal and regulatory requirements
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Investigating, evaluating, demonstrating, monitoring, improving, reporting on and meeting our compliance with best practice and good governance responsibilities
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Day-to-day business operations
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Supporting the sale, transfer or merging of part or all of our business or assets, or in connection with the acquisition of or by another business
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Schedule 4 – Individuals’ rights
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Your right
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What does it mean?
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Limitations and conditions of your right
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Right of access
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Subject to certain conditions, you are entitled to have access to your personal data (this is more commonly known as submitting a “
data subject access request
”).
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If possible, you should specify the type of information you would like to see to ensure that our disclosure is meeting your expectations.
We must be able to verify your identity. Your request may not impact the rights and freedoms of other people, eg privacy and confidentiality rights of other staff.
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Right to data portability
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Subject to certain conditions, you are entitled to receive the personal data which you have provided to us and which is processed by us by automated means, in a structured, commonly-used machine readable format.
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If you exercise this right, you should specify the type of information you would like to receive (and where we should send it) where possible to ensure that our disclosure is meeting your expectations.
This right only applies if the processing is based on your consent or on our contract with you and when the processing is carried out by automated means (ie not for paper records). It covers only the personal data that has been provided to us by you.
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Rights in relation to inaccurate personal or incomplete data
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You may challenge the accuracy or completeness of your personal data and have it corrected or completed, as applicable. You have a responsibility to help us to keep your personal information accurate and up to date.
We encourage you to notify us of any changes regarding your personal data as soon as they occur, including changes to your contact details, telephone number, immigration status.
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Please always check first whether there are any available self-help tools to correct the personal data we process about you.
This right only applies to your own personal data. When exercising this right, please be as specific as possible.
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Right to object to or restrict our data processing
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Subject to certain conditions, you have the right to object to or ask us to restrict the processing of your personal data.
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As stated above, this right applies where our processing of your personal data is necessary for our legitimate interests.
You can also object to our processing of your personal data for direct marketing purposes.
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Right to erasure
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Subject to certain conditions, you are entitled to have your personal data erased (also known as the “
right to be forgotten
”), e.g. where your personal data is no longer needed for the purposes it was collected for, or where the relevant processing is unlawful.
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We may not be in a position to erase your personal data, if for example, we need it to (i) comply with a legal obligation, or (ii) exercise or defend legal claims.
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Right to withdrawal of consent
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As stated above, where our processing of your personal data is based on your consent you have the right to withdraw your consent at any time.
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If you withdraw your consent, this will only take effect for future processing.
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