Mini-pupils and mini-pupillage candidate privacy notice

What is the purpose of this notice?

The chambers of Gavin Kealey Q.C. of 7 King’s Bench Walk (Chambers or 7KBW) is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you prior to, during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

It applies to all candidates for mini-pupillage and all other persons who spend time with us in Chambers on a similar basis, such as participants in the Inner Temple Pegasus Access and Support (PASS) scheme, Temple Bar Scholars and all other individuals who attend 7KBW for the purpose of shadowing its members. For the purposes of this document only, all such individuals are referred to as “mini-pupils” and all such placements are referred to as “mini-pupillages”.

We are a “data controller” with respect to your personal data. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as as soon as reasonably practical by posting it on our website located at https://7kbw.co.uk.

It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.

Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

  1. Used lawfully, fairly and in a transparent way.
  2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  3. Relevant to the purposes we have told you about and limited only to those purposes.
  4. Accurate and kept up to date.
  5. Kept only as long as necessary for the purposes we have told you about.
  6. Kept securely.

What is personal data?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are certain types of more sensitive personal data which require a higher level of protection, such as information about a person’s health or sexual orientation. Information about criminal convictions also warrants this higher level of protection. It is unlikely that we would collect sensitive personal data relating to mini-pupils.

The kind of information we hold about you

As part of your application for a mini-pupillage (or consequent upon your successful application under the PASS scheme or for a Temple Bar Scholarship), we may collect, store, and process some or all of the following categories of personal information about you:

  • The information you provided to us in any curriculum vitae, covering letter, or application form.
  • Any information you provide to us during your time in Chambers.
  • Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
  • Date of birth.
  • Gender.
  • Next of kin and emergency contact information.
  • Employment history (including job titles, work history, qualifications, working hours, holidays, training records and professional memberships).
  • Performance information. We may also collect, store and use the following more sensitive types of personal information about your health, including any medical condition, injury, or disability, relating to any reasonable adjustments we might take account of.

How is your personal information collected?

We collect personal information about you through the application and recruitment process.

How we will use the information about you

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

  1. To assess your skills, qualifications and suitability for the work or role with us.
  2. To communicate with you about the recruitment process.
  3. To keep records relating to our hiring processes.
  4. To comply with legal or regulatory requirements.
  5. To assign tasks and provide feedback to you as part of your mini-pupil work experience
  6. Where it is necessary for legitimate interests pursued by us or a third party, and your interests and fundamental rights do not override those interests.

Situations in which we will use your personal information

We will also process your personal data to decide whether or not to offer you a mini-pupillage.

If you are a mini-pupil, we will use your personal information and background to decide what types of work we will give to you during your mini-pupillage. At the end of such placement, we may provide you with feedback in relation to pieces of work you have undertaken.

If you fail to provide personal information

If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How we use particularly sensitive information

Situations in which we will use your sensitive personal information

In general, we will not process particularly sensitive personal information about you unless it is necessary for performing or exercising obligations or rights in connection with your engagement. On rare occasions, there may be other reasons for processing, such as it is in the public interest to do so.

In the event that we make you an offer, we will use information about your physical or mental health, or disability status, to help us make any reasonable adjustments for you.

Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your Confidentiality Agreement with us that you agree to any request for consent from us.

Information about criminal convictions

We do not envisage that we will hold information about criminal convictions.

Automated decision-making

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

Data sharing

We share your data with third parties, including third-party service providers and members of 7KBW (Members).

We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside the EU.

We do not currently share your personal information with third parties outside the EU.  However if we do, you can expect a similar degree of protection in respect of your personal information.  In such event, we will provide you with an updated copy of this notice as soon as as soon as reasonably practical by posting it on our website located at https://7kbw.co.uk.

Why might you share my personal information with third parties?

We will share your personal information with individual Members, 7 KBW Limited or other third parties where required by law, where it is necessary to administer their working relationship with you or where we have another legitimate interest in doing so.

Which third-party service providers process my personal information?

“Third parties” includes third-party service providers (including contractors and designated agents). The following activities are carried out by third-party service providers: payroll, pension administration, benefits provision and administration, IT services, obtaining legal advice, training, budgeting and other business administration services.

How secure is my information with third-party service providers and other related entities in Chambers?

All Members and our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

When might you share my personal information with Members?

We will share your personal information with Members as part of the process of allocating members of Chambers to mini-pupils for supervision purposes and as part of our regular reporting activities.

What about other third parties?

We may also need to share your personal information with a regulator or to otherwise comply with the law. This may include making disclosures to insurers, regulators and Members.

Data security

We have put in place measures to protect the security of your information.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those Members of Chambers, employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

How long will you use my information for?

Normally, we will retain your personal information for a period of 18 months after we have communicated to you our decision about whether to offer you a mini-pupillage in Chambers. Exceptionally, where it is considered that retention of your personal information for a longer period is necessary or desirable, it may be retained for such longer period (not to exceed 6 years).  After this period, we will securely destroy your personal information in accordance with applicable laws and regulations. In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

If you become a mini-pupil, we will not retain any further details about you after your mini-pupillage has taken place beyond the period set out above.

Rights of access, correction, erasure, and restriction

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact Chambers’ data protection manager via email at data.protection@7kbw.co.uk.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our data protection manager at Northwall Cyber LLP via email at data.protection@7kbw.co.uk. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact data protection manager at Northwall Cyber LLP via email at data.protection@7kbw.co.uk.