I am a Lowell or Overdales colleague

• your name (including any previous names and the dates when you were known by these names)
• your contact details (including your current and previous addresses for the last 7 years, telephone numbers and e-mail addresses)
• your gender
• your date of birth
• your National Insurance number
• evidence of your right to work in the UK including information about your immigration status (where relevant), such as copy of your passport (including biometric data if you use your smartphone to scan the chip in your passport when using the Experian, full birth certificate, visa, National Identity cards or biometric residence permit
• proof of your current address, such as a bank or credit card statement or utility bill
• your work history and other relevant experience
• evidence of your work history and other relevant experience, including documents evidencing payment of your salary or wages or payment of tax such as a P60 or HMRC tax report and where necessary, your employee number with your previous employers
  where you have been out of work for an extended period of time, we may also ask for evidence relating to income you received during that period, such as Universal Credit or a Carer’s Allowance
• your education including degrees awarded, transcripts and other information provided in support of your application for a role with us
• your qualifications
• details of any professional memberships
• information collected during telephone screenings and interviews and any assessment centres you may attend, including the results of any language or technical tests you take, or psychometric assessments carried out and CCTV images if you attend our offices
• details of your character referee, including their name, address and occupation
• details of your emergency contact, including their name, their relationship to you and their contact details
• any other information collected as part of the talent acquisition process, including as a result of the employment checks we carry out
• details of any accounts you have with any member of the Lowell group (including but not limited to, Lowell Portfolio I Ltd, Lowell Financial Ltd, Lowell Legal Limited and Overdales Legal Limited) 
  information about your current financial status, including details of any financial defaults, unsatisfied county court judgments (CCJs), individual voluntary arrangements (IVAs), or any other undischarged bankruptcy proceedings
• any other information contained in your CV
• employee reference number / ID numbers
• bank account details and payroll information including expenses information
• salary and benefits package
• pension and tax information
• performance reviews, appraisals,
• any disciplinary proceedings and their outcomes
• any grievances and their outcomes
• absence information
• employment history with Lowell
• the results of any training programmes, assessments or exams which you take in the course of your employment with Lowell
  your photo
• video and/or audio recordings which you participate in 
  information which you post on our intranet and colleague engagement platforms, such as Yammer or Bright 
  information you provide by participating in any colleague engagement initiatives, such as our Involve groups 
  your vehicle registration and its make and model
  details relating to your driving licence and car insurance if you drive as part of your role
• details of your travel for work including your passport details if you travel abroad
• correspondence which you send using our systems including emails you send Teams messages and Zoom messages (whether these are business or personal)
• recording of our calls with you and calls which you make or receive using Lowell’s telephone system
• CCTV images
• information gathered through Lowell's monitoring of its IT systems (including details of your internet browsing), building access records and CCTV recordings
• information relating to health and safety at work and accidents at work

We collect information about your mental and physical health where we need to do so to:

• make reasonable adjustments to your working environment
• manage your absence including paying you sick pay or maternity/paternity pay
• dealing with any accidents at work
• help you to return to work and assess whether you are still able to perform your role

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 employment checks. If you apply for an internal vacancy, we may carry out further checks depending on the nature of the role you apply for.  Before we carry out any checks, you will be asked to complete our Background Check form which will explain which checks we intend to carry out.

From time to time, we may need to update the employment checks we have for you, but we will let you know before we carry out any more checks on you.

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 or six 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

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:

• during the talent acquisition process
• by completing our onboarding forms
• by filling in our internal forms or submitting requests
  as part of the day-to-day management of your relationship with us as a Lowell colleague
• by visiting our intranet and using our IT systems
• by posting information on our colleague engagement platforms and participating in colleague engagement initiatives
• 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 collect information about you as part of the day-to-day management of your relationship with us as a Lowell colleague, for example from your team leader or your colleagues.

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

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

Where you use our systems to:

• send emails, Teams or Zoom messages (including personal emails), we reserve the right to inspect, examine or monitor those communications without further notice
• interact with other colleagues, we reserve the right to inspect, examine or monitor such interactions without further notice and monitor the extent and frequency of use
• browse the internet, we monitor the types of sites you access, the extent and frequency of use of the internet

We will also capture and review all card purchases and payments made over our internet (including card details) to prevent and detect fraud and potential breaches of our information security policy.

For more details, please see our Information Security Policy and our Acceptable Use Policy which are available on our intranet.

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. This may include:

• in certain circumstances, the previous provider of your private medical insurance if you are transfer your existing insurance when you become a Lowell colleague
• organisations who are providing you with support such as mental health support or occupational health support

Information that we obtain from Experian

We use Experian to carry out 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 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.

Information that we may obtain from Cifas

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.

Information that we obtain from regulatory bodies and professional associations

If you are a member of a regulated profession, such as a solicitor, we may obtain information from 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 obtain information from the Financial Conduct Authority.

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 Group Shared Services Limited, Lowell Financial Ltd, 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 training, improving our quality and service standards and resolving issues with customer accounts or with colleagues.

CCTV images and building access

We operate CCTV at all of our premises. Whilst you are on site at any of our offices, you may be recorded by our CCTV system.

We also collect information about which areas of our premises you visit through our building access systems.

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

We need your information in order to manage your relationship with us as a Lowell colleague on a day-to-day basis for the purposes of performing your employment contract with us. This includes:

• processing your payroll information and paying your salary
• providing tax information and payments to HMRC
• providing you with a pension and other benefits you have chosen or you are entitled to receive
• monitoring your performance and providing you with feedback
• providing you with training and opportunities to improve your knowledge and skills
• communicating with you about your employment with Lowell
  dealing with any grievances you may have and carrying out any necessary disciplinary proceedings

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 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 provide you with a safe working environment as required by the Health & Safety at 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 employment rights and pensions legislation
• to comply with our obligations under the anti-money laundering and counter-terrorist financing legislation and for crime and fraud prevention.

We also use your information, to meet our legitimate interests, for example: 

• to manage our employees effectively, for workforce and headcount management, forecasting and planning purposes
• to provide and monitor access to relevant IT systems and buildings
• to prevent unauthorised access, intrusion, misuse of our IT systems and to protect us against theft or other crime
• to provide and facilitate colleague engagement initiatives
• to prepare for and activate business continuity plans
• to use other companies in the Lowell group to provide IT and support functions
• to share with Cifas for the purposes of preventing fraud and money laundering and to verify your identity 

You must make sure that the information we hold about you is up to date and you must notify us of any changes so that we can make sure that we keep your records accurate, complete and up to date.

If you don’t provide us with relevant information, we will not be able to manage your relationship with us as a colleague and meet our obligations to you.

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 promotion at 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 to your working environment for you.  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.

We will also need information about your physical or mental health in order to manage your absences, including paying you sick pay or maternity/paternity pay, managing your return to work when appropriate and assessing your ability to perform your role.  We use this information to comply with our obligations as an employer under the employment legislation. We will collect this information either from you directly or from someone you have authorised to share this information with us, such as a family member, an occupational therapist, our onsite counsellor, our external employee assistance provider or any other medical professional. We will only collect and share information with those people if you have agreed we can do so, and we may ask you to confirm this in writing.

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.

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 employment checks. If you apply for an internal vacancy, we may carry out further checks depending on the nature of the role you apply for.  Before we carry out any checks, you will be asked to complete our Background Check form which will explain which checks we intend to carry out.

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 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 7 years from the date your employment with us ends.

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.  

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

Your information is generally stored on servers and filing systems in the UK or the European Economic Area (EEA) but from time to time it may be stored in or accessed from countries outside the UK and EEA. Where this may happen, we always make sure that there are appropriate safeguards in place, such as standard contractual clauses or binding corporate rules, to guarantee that your information – and your rights – are protected to the same high standard as under UK law.

We only keep your information for as long as we need it.

We keep the information we collect about you during the talent acquisition process and the course of your employment with us as part of your employee file for:

• no more than 75 years from the date you cease to be a Lowell colleague in relation to pension information and
• no more than 7 years from the date you cease to be a Lowell colleague in relation to the rest of your employee file

However, we won’t keep all of your information for so long, and we will delete some information much sooner.

For more details about the specific retention periods that will be applied to your information, please refer to our retention policy which is available on our intranet. This policy has been written by considering all the different types of information that we hold about you, understanding how long we need to keep it for and agreeing not to keep it for any longer.

We may sometimes anonymise your information so that we can use the information for our legitimate business purposes such as equal opportunities monitoring to make sure that we are meeting our commitment to valuing and promoting equality in all areas of talent acquisition, employment, training and promotion.  If we do this, we will remove any information that can be used to identify you.

We don’t carry out any profiling of our colleagues who work for any of the UK Lowell group of companies.

We do not make any automated decisions about any of our colleagues or their employment with any of the UK Lowell group of companies.

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.

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:

• 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.

If you have any questions, concerns or complaints about the way Lowell UK Shared Services Limited, Lowell Group Shared Services Limited, Lowell Financial Ltd, Lowell Legal Limited or Overdales Legal Limited process your personal information, our Data Protection Officer will do their very best to help you.  You can contact our Data Protection Officer 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, concern or complaint relates to, please contact our Data Protection Officer using these contact details.

If you are not happy with the way we have handled your complaint or are still concerned about our handing of your personal information, you have a right to take your complaint to the Information Commissioner’s Office at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF and www.ico.org.uk.

This privacy notice was updated in August 2024.

We will regularly review this notice and keep it updated to make sure that the information we provide you with is accurate and up to date.