Privacy PolicyAusten Lloyd Limited

Austen Lloyd Limited (“Austen Lloyd”, “we”, “us” or “our”) is committed to protecting your privacy and handling your personal information responsibly, lawfully and transparently.

We are a specialist legal recruitment consultancy. In providing our recruitment services, we work with legal professionals, prospective candidates, law firms, businesses, hiring managers and other professional contacts throughout the United Kingdom.

This Privacy Policy explains what personal information we collect, how and why we use it, who we may share it with, how long we retain it and the rights you have in relation to your information.

1. Who we are

Austen Lloyd Limited is the data controller responsible for the personal information described in this Privacy Policy.

• Company name: Austen Lloyd Limited
• Company number: 07097366
• Registered office: 96 Church Lane, Backwell, Bristol, BS48 3JW
• Operational headquarters: 45 Oakfield Road, Clifton, Bristol, BS8 2AX
• Telephone: 01275 463111
• Email: info@austenlloyd.co.uk
• Website: www.austenlloyd.co.uk

For privacy or data protection enquiries, including requests relating to your personal information, please contact us using the details above and mark your communication Data Protection Enquiry.

2. Who this Privacy Policy applies to

This Privacy Policy applies to personal information we process about people including:

• candidates who register with Austen Lloyd;
• people applying for an advertised vacancy;
• prospective candidates whom we identify or approach regarding career opportunities;
• former candidates;
• people whose details appear in candidate CVs, such as referees;
• employees and representatives of clients and prospective clients;
• hiring managers and other business contacts;
• users of our website;
• people who subscribe to job alerts, newsletters or other communications;
• people who contact us by email, telephone, social media, contact form or other channels; and
• other individuals whose information we legitimately process in connection with our recruitment services.

Separate privacy information may be provided to Austen Lloyd employees and people applying to work directly for Austen Lloyd.

3. Personal information we collect

The information we collect depends on your relationship with Austen Lloyd.

Candidate and prospective candidate information

This may include:

• name;
• postal address;
• email address;
• telephone number;
• CV and employment history;
• qualifications, professional memberships and admissions;
• current and previous employers;
• practice areas and professional specialisms;
• seniority and position;
• salary, remuneration and benefit information;
• salary expectations;
• preferred locations and working arrangements;
• notice period and availability;
• career objectives and job preferences;
• interview availability;
• application and interview history;
• information about recruitment processes in which you participate;
• references and referee details;
• right-to-work information where appropriate;
• information provided during telephone calls, meetings, correspondence or interviews;
• information obtained from professional networking platforms and other publicly available professional sources;
• notes made by our consultants in connection with our professional relationship with you;
• communications between you and Austen Lloyd;
• information concerning job offers, negotiations and placements; and
• other information you choose to provide to us.

We do not need information that is irrelevant to providing recruitment services and ask candidates not to provide unnecessary sensitive personal information.

Client and business contact information

This may include:

• name;
• job title;
• employer or organisation;
• professional contact details;
• details of vacancies and recruitment requirements;
• records of communications;
• meetings and discussions;
• commercial relationship information;
• recruitment history;
• information about hiring preferences and requirements; and
• publicly available professional information.

Website information

When you use our website, we may collect information such as:

• IP address;
• browser and device information;
• pages visited;
• website interactions;
• referral source;
• cookie identifiers; and
• information submitted through website forms.

Our use of cookies and similar technologies is explained separately in our Cookie Policy.

4. Where we obtain personal information

We may obtain information directly from you when you:

• register your CV;
• apply for a role;
• contact one of our consultants;
• complete a website form;
• speak with us by telephone or video call;
• communicate with us by email;
• meet us;
• subscribe to communications; or
• otherwise engage with Austen Lloyd.

Because recruitment also involves identifying potentially suitable professionals, we may lawfully obtain professional information from other sources, including:

• LinkedIn and similar professional networking services;
• law firm and company websites;
• professional directories;
• publicly accessible professional profiles;
• job boards and recruitment platforms;
• professional recommendations and referrals;
• clients;
• former professional contacts; and
• other legitimate business sources.

If we obtain your personal information from another source rather than directly from you, we will provide appropriate privacy information where required by law.

5. How we use personal information

We may use personal information to:

Provide recruitment services

This includes:

• registering and maintaining candidate profiles;
• understanding your experience, qualifications and career objectives;
• assessing potential suitability for opportunities;
• discussing vacancies with you;
• matching candidates with potential employers;
• introducing candidates to clients where authorised;
• arranging interviews;
• supporting recruitment processes;
• managing offers and negotiations;
• obtaining appropriate references where required;
• supporting placements;
• maintaining appropriate records of our relationship with candidates and clients; and
• contacting candidates about relevant future opportunities.

Identify prospective candidates

Recruitment frequently involves identifying professionals who may be suitable for a role even where they have not actively applied.

We may therefore use limited professional information obtained from publicly available or legitimate professional sources to identify individuals who could reasonably be expected to have an interest in relevant professional opportunities.

Where appropriate, we will explain who we are, why we have contacted you and how we obtained or use your information.

Provide services to clients

We may use information to:

• understand a client’s recruitment requirements;
• identify potentially suitable candidates;
• manage recruitment assignments;
• communicate with hiring managers;
• maintain client relationships;
• administer agreements;
• invoice for our services;
• deal with queries and disputes; and
• develop our recruitment services.

Protect our business and comply with legal obligations

We may process information to:

• maintain appropriate business records;
• prevent fraud and misuse;
• protect confidential information;
• establish, exercise or defend legal claims;
• comply with legal and regulatory requirements;
• respond to lawful requests from authorities;
• manage data protection requests; and
• maintain the security of our systems.

Improve our services

We may analyse information in an appropriately controlled way to:

• understand recruitment trends;
• improve candidate and client services;
• assess the effectiveness of our recruitment activities;
• improve our website;
• improve internal processes; and
• develop our business.

Where reasonably possible, information used for analytics or reporting will be aggregated or anonymised.

6. Our lawful bases for using personal information

UK data protection law requires us to have a lawful basis for processing personal information.

Depending on the circumstances, Austen Lloyd may rely on the following bases.

Taking steps before entering into a contract or performing a contract

Where you ask Austen Lloyd to assist you in finding employment, or where processing is necessary in connection with services we provide under an agreement, we may process information because it is necessary to take steps at your request before entering into a contract or to perform a contract.

Legitimate interests

We may process personal information where this is necessary for our legitimate interests or those of a third party and those interests are not overridden by your rights and interests.

These legitimate interests may include:

• operating a professional recruitment consultancy;
• identifying candidates who may be suited to professional vacancies;
• helping candidates identify suitable career opportunities;
• helping employers find suitable candidates;
• maintaining candidate and client relationships;
• maintaining an appropriate professional candidate database;
• responding to professional enquiries;
• maintaining records of recruitment activity;
• establishing and defending legal claims;
• preventing fraud;
• maintaining information and system security; and
• improving our services.

Where we rely on legitimate interests, we consider the necessity and proportionality of the processing and the reasonable expectations and privacy rights of the individual concerned.

You have the right to object to processing based on legitimate interests. Further information appears below.

Legal obligation

We may process information where necessary to comply with legal obligations applying to Austen Lloyd.

Consent

We may ask for your consent where consent is the appropriate lawful basis, particularly for certain optional marketing communications or where another specific legal requirement makes consent appropriate.

Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect processing lawfully undertaken before consent was withdrawn.

We do not rely on consent where another lawful basis more appropriately reflects the nature of the processing.

7. Candidate confidentiality and sending CVs to clients

Candidate confidentiality is fundamental to our service.

We will not ordinarily send your CV or disclose your identity to a prospective employer in connection with a specific recruitment opportunity without discussing the opportunity with you and obtaining your authority to represent you.

Authorising Austen Lloyd to put you forward for a particular opportunity is separate from consenting to general marketing communications.

We ask candidates to tell us if another recruiter is already representing them for a particular position so that duplicate applications can be avoided.

There may be exceptional circumstances in which information must be disclosed because of a legal obligation, regulatory requirement or legal claim.

8. Special category information

Certain personal information is given additional protection under data protection law. This includes information concerning:

• racial or ethnic origin;
• political opinions;
• religious or philosophical beliefs;
• trade union membership;
• genetic information;
• biometric information used for identification;
• health; and
• sex life or sexual orientation.

We do not seek to collect this information routinely as part of our recruitment service.

Where special category information is genuinely necessary, we will only process it where an appropriate Article 9 UK GDPR condition and any applicable Data Protection Act 2018 condition is satisfied.

For example, limited health information may occasionally be processed where necessary to support reasonable adjustments during a recruitment process.

Candidates should avoid including unnecessary special category information in CVs submitted to Austen Lloyd.

9. Criminal conviction and offence information

We do not routinely collect criminal conviction or offence information.

If such information is required for a particular regulated position or recruitment process, we will only process it where permitted by law and with appropriate safeguards.

Where a criminal records check is required, this will normally be undertaken at the appropriate stage of recruitment and in accordance with applicable legal requirements.

10. References

If you provide details of referees, you should ensure that they reasonably expect their details to be provided for recruitment purposes.

We use referee information only where it is reasonably necessary in connection with recruitment and will treat it confidentially.

11. Who we share information with

Depending on the circumstances, personal information may be shared with:

• clients or prospective employers;
• organisations involved in a recruitment process;
• service providers supporting our IT, CRM, communications, website, hosting and business systems;
• professional advisers such as lawyers and accountants;
• insurers;
• regulators and public authorities where required;
• law enforcement agencies where legally required; and
• other organisations where disclosure is necessary to establish, exercise or defend a legal claim.

Service providers processing personal information on our behalf are required to protect it appropriately and may only use it in accordance with our instructions and applicable law.

We do not sell candidate personal information.

12. International transfers

Some technology and service providers may process or make personal information accessible outside the United Kingdom.

Where a restricted transfer occurs, Austen Lloyd will ensure an appropriate transfer mechanism is in place in accordance with UK data protection law.

Depending on the destination and circumstances, this may include:

• UK adequacy regulations;
• the UK International Data Transfer Agreement;
• the UK International Data Transfer Addendum to EU Standard Contractual Clauses; or
• another lawful transfer mechanism.

Where required, we will also undertake an appropriate transfer risk assessment and implement supplementary safeguards.

13. How long we keep information

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, together with any period necessary to meet legal, regulatory, contractual or legitimate business requirements.

Candidate records

Our normal candidate relationship review period is two years from the most recent meaningful interaction with the candidate.

A meaningful interaction may include:

• applying for a vacancy;
• registering or updating a CV;
• discussing a role with a consultant;
• participating in a recruitment process;
• responding to Austen Lloyd regarding career requirements;
• updating employment details;
• requesting continued recruitment support; or
• being placed by Austen Lloyd.

At or around the end of this period we may:

• contact you to establish whether you want Austen Lloyd to continue providing recruitment services;
• update your information;
• delete or anonymise information that is no longer required; or
• retain limited information where there is another lawful reason to do so.

Information connected with completed placements, contracts, invoices, disputes or legal claims may need to be retained for longer.

We do not interpret a two-year retention period as permission to retain every item of information indiscriminately. Records should remain relevant, proportionate and reasonably current.

Client records

Client and business contact information may be retained while there is an active or reasonably foreseeable professional relationship and afterwards where required for legitimate business, contractual, accounting or legal purposes.

Suppression records

If you ask us not to contact you, we may retain limited information such as your email address on a suppression list. This allows us to respect your request rather than accidentally contacting you again.

14. Keeping your information accurate

Recruitment information can become outdated quickly.

We take reasonable steps to keep information accurate and encourage you to tell us if:

• your contact details change;
• you change employer or position;
• your professional qualifications change;
• your job-search requirements change; or
• information held by Austen Lloyd is incorrect.

15. Security

We implement appropriate technical and organisational measures designed to protect personal information against:

• unauthorised access;
• accidental loss;
• unauthorised disclosure;
• alteration;
• destruction; and
• misuse.

Access to candidate and client information is restricted according to legitimate business need.

Employees and contractors handling personal information are required to maintain confidentiality and follow Austen Lloyd’s data protection and information security requirements.

No internet-based system can be guaranteed to be completely secure, but we maintain proportionate safeguards having regard to the nature of the information we process.

16. Artificial intelligence and automated tools

Austen Lloyd may use technology to assist with administrative, research, search, matching, analysis or drafting activities.

Where AI or automated tools process personal information, they must be used in accordance with our data protection obligations, confidentiality requirements and internal controls.

Austen Lloyd does not make recruitment decisions about candidates solely by automated means where those decisions produce legal or similarly significant effects unless the processing is lawful and all required safeguards are in place.

Our recruitment service remains consultant-led.

Where technology helps us identify or assess potentially relevant candidates or opportunities, the output may be reviewed by an Austen Lloyd consultant rather than being treated automatically as determinative.

17. Direct marketing and job communications

There is an important distinction between:

• communications necessary to provide recruitment services you have requested;
• individual communications about a role that we reasonably believe may be professionally relevant to you; and
• general marketing communications such as newsletters and promotional updates.

We comply with applicable data protection and electronic marketing requirements when sending these communications.

You may opt out of marketing communications at any time by using an unsubscribe mechanism where provided or by contacting us.

Opting out of general marketing does not necessarily prevent Austen Lloyd from contacting you about an existing application, recruitment process, contractual matter or other communication that is not marketing.

18. Your data protection rights

Depending on the circumstances and the lawful basis on which we process your information, you may have rights including:

Right of access

You may request confirmation that we process your personal information and obtain a copy of it.

Right to rectification

You may ask us to correct inaccurate or incomplete information.

Right to erasure

In certain circumstances you may ask us to delete personal information.

This right is not absolute, and we may retain information where there is a lawful reason to do so.

Right to restrict processing

In certain circumstances you may ask us to restrict how information is used.

Right to object

You have the right to object to processing based on legitimate interests.

Where you object, we will consider your request and stop the processing unless there are compelling legitimate grounds for continuing or processing is required for the establishment, exercise or defence of legal claims.

You have an absolute right to object to the use of your personal information for direct marketing.

Right to data portability

Where applicable, you may have the right to receive certain information in a structured, commonly used and machine-readable form.

Rights relating to automated decisions

You may have rights in relation to qualifying decisions made solely by automated processing where those decisions have legal or similarly significant effects.

Right to withdraw consent

Where processing is based on consent, you can withdraw your consent at any time.

To exercise a right, contact us at:

info@austenlloyd.co.uk

We may need to verify your identity before responding.

19. Complaints

If you have concerns about how Austen Lloyd uses your personal information, please contact us first so that we can investigate.

You also have the right to complain to the UK supervisory authority:

Information Commissioner’s Office (ICO)
www.ico.org.uk (opens in a new tab)

The ICO’s website contains current contact details and information about making a complaint.

20. Links to other websites

Our website may contain links to third-party websites.

Austen Lloyd is not responsible for the privacy practices of third-party websites and we recommend reviewing their privacy information separately.

21. Changes to this Privacy Policy

We may update this Privacy Policy periodically to reflect:

• changes to our services;
• changes to technology;
• changes to our processing activities; or
• changes in data protection law or regulatory guidance.

The current version will be published on our website together with the date it was last updated.

Where we intend to make a material new use of existing personal information, we will provide additional information where required before beginning that processing.