I am applying for a job with Lowell

As part of our talent acquisition process, we will confirm the information you provide to us by contacting your former employers and your university or further education establishments. We will also ask for references for either the last two years or the last five years depending on the role you apply for. We may also ask for character references in some circumstances. We may collect publicly accessible information about you, for example through a Google search, to make sure that you are suitable for the role you are applying for.

We also use Experian to carry out the following checks on you if you accept an offer of employment with Lowell:

right to work checks
adverse financial checks
a basic or enhanced criminal record check depending on your role

Right to work checks

We need to confirm that you have a right to work in the UK.  We may do that in person by checking your documentation or remotely using Experian to perform these checks for us.

You can use Experian’s self-service app to provide your passport number (or you may be able to use your smartphone to scan the chip in your passport)  or birth certificate and National Insurance number which Experian will compare to their identity verification database or with the Home Office to confirm that you have a right to work in the UK. If you have a visa, they will also tell us the amount of time remaining before your visa expires. If you can’t use the app, we may send the information to Experian for you.

Adverse financial checks

These checks confirm whether there is any adverse data recorded on your credit file relating to defaults, CCJs (or similar judgments from other courts), voluntary arrangements or bankruptcy. This check is called a ‘soft search’ and may leave what is known as a “soft footprint”. This means that it is not visible to any other organisations and will not affect your credit score. It can only be seen by you, us and the credit reference agency and will show as account administration on your credit file.

Criminal record check

Experian will also use the services of the Disclosure and Barring Service to undertake on your behalf, a criminal record check which details unspent convictions under the Rehabilitation of Offenders Act 1974 to verify the information you provide us in your application form. If you have worked overseas in the last 5 years, Experian will also do an overseas criminal check on you.

For more details about Experian and how it uses and shares personal information please visit www.experian.co.uk/privacy-policies.html. More information about the Disclosure and Barring Service is available at www.gov.uk/government/organisations/disclosure-and-barring-service.

Depending on the type of role you accept with Lowell, we may also use Experian to carry out:
a check of the electoral roll
a director’s search at Companies House
a sanctions check
a Financial Conduct Authority check
a media check

The personal information we have collected from you will be shared with Cifas who will use it to prevent fraud, other unlawful or dishonest conduct, malpractice and other seriously improper conduct. If any of these are detected, you could be refused certain services or employment. Your personal information will also be used to verify your identity. For more details about how your information will be used by us and Cifas, please see the Cifas privacy notice at the bottom of this notice.

Before we carry out any checks (other than contacting your former employers and your university or further education establishments to confirm the information you have provided and your referees and character referees), we will send you our Background Check form for you to complete which will explain which checks we intend to carry out.

Depending on the type of role you accept with Lowell, we may update the employment screening checks on you from time to time.

Information that you give us

You give us information about yourself, your work experience and other relevant experience, your education, your qualifications and your circumstances:

by completing our online application form
in any telephone screenings and interviews and any assessment centres you may attend
in any communications with us by telephone, email, post, social media or otherwise
by visiting our website, setting up an online account through our website and filling in forms on our website.
Please see our Website User privacy notice and our Cookie notice for details of the information we collect through our website

Information that we collect about you

We may collect information about you that is publicly accessible, for example:

through a media search
news and social media reports
entries in online directories
information which is available at Companies House and
information which is available from the Financial Conduct Authority

Information that we receive from recruitment agents

If we receive your application through a recruitment agent, they will send us the following information:

your name
your contact details (including your address, email address and telephone numbers)
details of the role you are applying for with Lowell
details of your current salary and benefits package
the information contained in your CV
evidence of your right to work in the UK and
any other information provided to support your application

Information that we obtain from your previous employer(s)

We obtain information from your previous employers to confirm the information that you have provided us with. This includes:

the dates of your employment
your job title and role
details of your responsibilities
your reasons for leaving your previous role
whether your previous employer would employ you again
whether your previous employer is aware of anything about you that would mean that you are not suitable for the role that you are applying for with Lowell
any other information provided by your previous employer in the reference they provide for you and
any other information provided to support your application

Information that we obtain from the university and other further education establishments you have attended

We obtain information from the university and other further education establishments you have attended to confirm the information that you have provided us with. This includes:

the dates of your enrolment
the courses you studied
any qualifications you obtained
whether they are aware of anything about you that would mean that you are not suitable for the role that you are applying for with Lowell and
any other information provided to support your application

Information that we obtain from your character referee

We collect information from your character referee so that we can confirm that you are suitable for the role with Lowell that you are applying for. This includes:

how you know each other
how long you have known each other
depending on the role, whether they are aware of anything about you that would mean that you are not suitable for the role that you are applying for with Lowell and
any other information provided to support your application

Information that you ask us to collect from third parties

If you specifically ask us to collect information from a third party, we will do so in accordance with your request, which we may ask you to put in writing.

Information that we obtain from Experian

We use Experian to carry out pre-employment checks about you.

Experian is a credit reference agency. Credit reference agencies (or CRAs) hold personal information about individuals. Most of the personal information they hold relates to how you have maintained your credit accounts. They also hold address details and information taken from public sources, such as the electoral roll, public records including CCJs and bankruptcy and insolvency information. If you are financially associated with another person (which means that you have a joint credit account or mortgage with them), we will receive financial information relating to that association.

Experian will provide us with details of any of the following which are recorded on your credit file:

financial defaults
CCJs (or similar judgments from other courts)
IVAs
any other undischarged bankruptcy proceedings

This check is called a ‘soft search’ and may leave what is known as a “soft footprint”. This means that it is not visible to any other organisations and will not affect your credit score. It can only be seen by you, us and the credit reference agency and will show as account administration on your credit file.

In some circumstances, Experian may also process some of the references we obtain, including:

education references where the education provider charges a fee for providing the reference
references which are not provided in English and need to be translated

Experian may also carry out right to work checks on our behalf

Information that we may obtain from Cifas

Information that we receive from other companies in the Lowell group

We may receive information about you from other members of the Lowell group of companies:

so that Lowell UK Shared Services Limited is able to provide talent acquisition and other HR related services to Lowell Financial Ltd, Lowell Group Shared Services Limited, Lowell Legal Limited and Overdales Legal Limited.
for our internal administrative purposes including creating and analysing management information and HR reports
to monitor our compliance with our legal, professional, regulatory and other corporate governance obligations

Call recording

We may monitor and/or record calls for the purposes of resolving issues with your application, training and improving our quality and service standards.

CCTV images and building access

We operate CCTV at all of our premises. If you visit any of our offices, you may be recorded by our CCTV system.

We may collect information about your visit to our premises if you attend any of our premises for interview.

We may combine the information that you give us with the information we collect about you from the other sources listed above.

We need your information in order to process and evaluate your application and to decide whether you are suitable for the role that you are applying for. This includes:

identifying and evaluating individuals who have applied for a role with us
assessing your skills, qualifications and experience
verifying the information that you have provided to us
carrying out our pre-employment checks
communicating with you about the talent acquisition process and your application

We do this to take steps which are necessary for us to enter into an employment contract with you.

We also use your information to comply with our legal, regulatory, professional and other corporate governance obligations, for example:

the Financial Conduct Authority requires us to carry out certain pre-employment checks on individuals applying for senior management and other roles
to comply with our obligations under the right to work legislation
to make sure that we treat everyone fairly and equally as required by the equal opportunities legislation
to comply with our obligations under the anti-money laundering and counter-terrorist financing legislation and for crime and fraud prevention

If you don’t provide us with relevant information, we will not be able to proceed with your application which means that we will not be able to consider you for the role you are applying for with us.

Special Categories of personal data

Under the data protection laws, information revealing the following are “special categories of personal data”:

racial or ethnic origin
political opinions
religious or philosophical beliefs
trade union membership
genetic information
biometric information
information concerning health (including mental and physical health) or
sex life or sexual orientation

We are committed to providing equal opportunities in all areas of talent acquisition, employment, training and progression to everyone applying for a role with Lowell.

We collect information relating to:

racial or ethnic origin
religious or philosophical beliefs
information relating to disability, neurodiversity and long term health conditions
information relating to sexual orientation,

to make sure that we are meeting our commitment and complying with our obligations under the equal opportunities legislation. We do this on the basis that this is in the substantial public interest.

Experian may collect biometric information held within your passport if you use the Experian self-service app to complete the right to work checks remotely and you use your smart phone to scan the chip in your passport.

We may collect information about your physical or mental health in order to make reasonable adjustments for you during the talent acquisition process. We only collect the minimum amount of information we need to make such adjustments. We collect this information in order to comply with our obligations as an employer under the equal opportunities legislation.

If we believe you are in immediate danger, including due to a medical emergency, we may process information relating to your physical and mental health conditions (including sharing this information with the emergency services and your emergency contacts) on the basis that it may be a life and death situation.

We do not collect special categories of personal data for any other purpose during the talent acquisition process.

Information relating to criminal convictions

Given the nature of our business, we ask you to tell us about any criminal convictions you may have, and we carry out a criminal records check as part of our pre-employment checks.

Experian use the services of the Disclosure and Barring Service to undertake on your behalf, a criminal record check which details unspent convictions under the Rehabilitation of Offenders Act 1974 to verify the information you provide us in your application form. If you have worked overseas in the last 5 years, Experian will also do an overseas criminal check on you.

We may also use the information we collect about your criminal convictions for the purposes of crime and fraud prevention and for complying with our obligations under the anti-money laundering and counter-terrorist financing legislation.

We only collect the minimum amount of information about your criminal convictions that we need for the purposes of determining whether you are suitable for the role that you are applying for with Lowell.

We collect information about your criminal convictions on the basis that we are required to do so to comply with our legal, professional, regulatory and other corporate governance obligations as an employer and particularly as employers authorised by the Financial Conduct Authority and Solicitors Regulation Authority.

Where we use information about your criminal convictions and share it with third parties for the purposes of complying with our obligations under the anti-money laundering, counter-terrorist financing and other legislation, we do so on the basis that this is necessary for us to comply with our legal obligations.

We will retain information relating to your criminal convictions for no more than 6 months from the end of the talent acquisition process for the role which you are applying for with Lowell; although we will keep the outcome of the criminal records check we carry out for up to 12 months.

We sometimes need to share some of your information with other organisations.

Information that we share with other companies in the Lowell group

We may share your information with other members of the Lowell group of companies:

so that Lowell UK Shared Services Limited is able to provide talent acquisition and other HR related services to Lowell Financial Ltd, Lowell Group Shared Services Limited, Lowell Solicitors Legal Limited and Overdales Legal Limited. for our internal administrative purposes including creating and analysing management information and HR reports
to monitor our compliance with our legal, professional, regulatory and other corporate governance obligations

As Lowell is a multi-national group of companies which operates in a number of EU countries, this may involve your information being shared with Lowell companies which are outside of the UK, although these companies are all based in the European Economic Area.

Information that we share with Experian

We share the following information with Experian so that Experian can carry out pre-employment checks for us:

your name
your contact details (including your current and previous addresses, email addresses and telephone numbers)
the information you provide when completing our Background Check form that we will send to you if you accept an offer of employment with Lowell
information you provide to evidence that you have a right to work in the UK
copies of your references in circumstances where they process these for us

Information that we may share with Cifas

Information that we share with law enforcement and emergency services

If we identify evidence of fraud, money laundering or any other crime (whether financial or otherwise) in relation to your application, including where you have been the victim of identity theft, we will share those details with the police, the National Crime Agency and other law enforcement agencies. We may also share information with HM Revenue and Customs where appropriate.

Where relevant we may also share CCTV images and call recordings with the police, the National Crime Agency and other law enforcement agencies.

Information that we share with regulatory authorities

Lowell Financial Ltd and Overdales Legal Limited are authorised by the Financial Conduct Authority. This means that we are required to report certain things to the Financial Conduct Authority which may mean sharing information about you if your role means that you will be an approved person and that you will need to be approved by the Financial Conduct Authority.

Overdales Legal Limited are authorised by the Solicitors Regulation Authority. This means that we are required to report certain things to the Solicitors Regulation Authority which may mean sharing information about you in relation to your application.

Lowell Legal Limited is no longer authorised by the Solicitors Regulation Authority, however, may be required to share information regarding previous matters.

We are registered with the Information Commissioner’s Office and if you make a complaint to them, we may have to share information about you.

Where appropriate, we may share CCTV images and call recordings with these organisations.

Information that we share with regulatory bodies and professional associations

If you are a member of a regulated profession, such as a solicitor, we may share information with your regulatory body or professional association such as The Law Society.

If you have previously held a role as an approved person or you are applying for such a role with Lowell, we may also share information with the Financial Conduct Authority.

Information that we share with your previous employer(s) and the university and other further education establishments you have attended

We may share some limited information with your previous employer(s) and the university and other further education establishments you have attended in order to verify the information which you have provided to us about your work history, education and qualifications.

Information that you ask us to share with third parties

If you specifically ask us to share information with a third party, we will do so in accordance with your request, which we may ask you to put in writing.

Information that we share with our clients

We may share information about you with our clients, including details of the pre-employment checks we have carried out with our clients for the purposes of quality assurance and evidence of our compliance with our contractual obligations to our clients.

Information that we share with our third party suppliers

We use a number of carefully selected third parties to supply us with products and services, such as our HR systems and IT services.

The information that we share with our suppliers will depend on the nature of the products and services that they provide to us but we will only share the minimum amount of your information which is necessary for them to provide us with the products and services we need.

This may sometimes involve your information being shared or stored outside of the UK and outside the European Economic Area.

Information that we share with other third parties

If we or any member of the Lowell group of companies merges, transfers or sells part or all of its business or assets or any of the share capital of Lowell Portfolio I Ltd or Lowell Financial Ltd to a third party, your personal information may be disclosed to that third party and its advisers for the purposes of negotiating and completing the merger, transfer or sale. If the merger, transfer or sale does complete, that third party may use or disclose your information as set out in this privacy notice.

Under the data protection laws, you have a number of rights in respect of your information and the way we use it. Some of these rights only apply in certain situations. We explain below what rights you have, what these mean and how they apply to the way we use your information.

You have the right to

Access your information

You can ask for

confirmation that we process your personal information
a copy of your personal information that we hold and
other information about how we process your information

We will provide you with a copy of your personal information which we hold unless the data protection rules provide an exception that decide to rely on, for example where there are ongoing court proceedings. We may also edit out the names of any other individuals to protect their privacy.

Wherever possible, we will provide you with a copy of your personal information in the same manner you make your request unless we agree otherwise with you.

This privacy notice also includes the other information you can ask for about how we process your information.

Have your information rectified

You can ask us to rectify your information if it is not accurate, complete or up to date.

We will update or correct your information, although sometimes we may need to ask you to provide evidence to confirm the changes, for example a copy of your marriage certificate if you are changing your name because you have got married.

Have your information erased

This is also known as the right to be forgotten.

You can ask us to delete your information where:

we no longer need it
we rely on your consent to use your information and you withdraw it
you object to our processing it and we have no overriding legitimate grounds to continue processing it or
we are legally required to delete it

This right does not apply where:

we are legally required to keep your information, for example under the laws which require us to check you have a right to work in the UK
we have a compelling legitimate ground for using your personal information or
we need your information to establish, exercise or defend legal claims, for example where there are ongoing court proceedings.

As we rely on the fact that we need your information to (a) take steps at your request prior to entering into an employment contract with you (b) comply with our legal obligations or (c) protect you where it is a matter of life and death for most processing of your personal information, we will only be able to delete your personal information:

if you have the right to object to our processing your personal information and to carry out your request we have to erase your information and
where we no longer need your information. Although our retention policy means that we will delete your information once we no longer need it. Please see the section How long do we keep your information? above for more details.

Restrict our processing of your information

You may ask us to restrict our processing of your personal information where:

you believe the information we hold about you is inaccurate while we check whether it is accurate
we no longer need your information but you need it to establish, exercise or defend a legal claim or
you object to our processing your personal information while we reconsider our legitimate interests assessment

We will not process your personal information whilst we consider your request. However, we will still be able to process your personal information for the purposes of any ongoing court or other legal proceedings.

We will inform you if we begin processing your personal information again and explain why.

Have your information transferred to you and/or a third party

This is also known as the right to data portability.

You can ask us to provide you with a copy of the information which you have provided to us and which we hold electronically.

This right only applies to the information which you have provided to us which we hold electronically. It does not apply to information that we collect to comply with our legal obligations such as evidence of your right to work in the UK.

We will provide this information to you in a commonly-used and machine readable format.

Object to our processing of your information, including profiling

You can object to our use of your information, including profiling unless:

we have compelling legitimate grounds for using your information or
we need to use your information to establish, exercise or defend a legal claim, for example where there are ongoing court proceedings

You can also object to us using your information for marketing purposes.

We don’t carry out any profiling of people who apply to work with the UK Lowell group of companies.

This right only applies to the information that we process on the basis that it is in our legitimate interests.

We don’t use your information for direct marketing.

Not to be subject to an automated decision

You can ask us to review any automated decision which has a legal or significant effect for you. You can provide us with your point of view and any additional information that you think we need and ask for a human to reconsider our decision.

You can ask us to reconsider any automated decision we have made about whether or not to proceed with your application.

We will always do our best to respond to your request within one month of receiving it and any additional information we need to confirm your identity and understand your request.

However, sometimes we may need some more time to deal with your request, particularly if it is complicated. Where this happens, we will write to you within one month and let you know why we need some more time and when we will provide you with our response.

If we are unable to carry out your request, we will send you a response explaining why.

If you would like to exercise any of your rights, please contact our Data Protection Officer by:

by email at dpo@lowellgroup.co.uk or
letter at Data Protection Officer, Lowell Financial Ltd, PO Box 13079, Harlow, CM20 9TE

Our Data Protection Officer deals with data protection for all our UK companies, so whichever Lowell company your question, query or request relates to, please contact our Data Protection Officer using these contact details.

Company	Lowell UK Shared Services Limited	Lowell Group Shared Services Ltd	Lowell Financial Ltd	Lowell Legal Ltd	Overdales Legal Ltd
Company number	08336897	08647094	04558936	08647091	07407310
Country	Incorporated in the UK	Incorporated in the UK	Incorporated in the UK	Incorporated in the UK	Incorporated in the UK
Registered office	Ellington House, 9 Savannah Way, Leeds Valley Park, Leeds, LS10 1AB	Ellington House, 9 Savannah Way, Leeds Valley Park, Leeds, LS10 1AB	Ellington House, 9 Savannah Way, Leeds Valley Park, Leeds, LS10 1AB	Ellington House, 9 Savannah Way, Leeds Valley Park, Leeds, LS10 1AB	Ellington House, 9 Savannah Way, Leeds Valley Park, Leeds, LS10 1AB

Lowell Portfolio I Ltd	Company number 04857418
Lowell Financial Ltd	Company number 04558936
Lowell Legal Limited	Company number 08647091
Overdales Legal Limited	Company number 07407310
Lowell UK Shared Services Limited	Company number 08336897
Lowell Group Shared Services Limited	Company number 08647094
Lowell Receivables Financing 1 Limited	Company number 11344999
Lowell Receivables Financing 2 Limited	Company number 13403235
Lowell Receivables Financing 3 Limited	Company number 13849615
Lowell Portfolio IV Limited	Company number 08654105
Simon Bidco Limited	Company number 09709443
Metis Bidco Limited	Company number 07652466
Wolf Receivables Financing plc	Company number 13949210
Wolf Receivables Financing 3 plc	Company number 15073494

I am applying for a job with Lowell

I am an applicant

Who are we?

What information do we collect about you?

What pre-employment checks do we carry out?

Where do we get your information from?

Why do we need your information?

Who do we share your information with?

Where is your information stored?

How long do we keep your information?

Do we carry out profiling and automated decision-making?

What rights do you have?

You have the right to

What if you have a complaint?

Who are the Lowell group?

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I am applying for a job with Lowell

I am an applicant

Who are we?

What information do we collect about you?

What pre-employment checks do we carry out?

Where do we get your information from?

Why do we need your information?

Who do we share your information with?

Where is your information stored?

How long do we keep your information?

Do we carry out profiling and automated decision-making?

What rights do you have?

You have the right to

What if you have a complaint?

Who are the Lowell group?

Changes to this notice