This Privacy Notice tells you what to expect when Apex Chambers collects personal information. It applies to information we collect about:
• Visitors to our websites;
• Complainants and other individuals in relation to a complaint;
• People who instruct us using our website; and
• Job applicants and our current and former employees.
Apex Chambers understands that your privacy is important to you and that you care about how your personal data is used and shared. We respect and value the privacy of everyone who visits our website, www.apexchambers.net (“Our Site”) or shares information with us directly and will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law.
Please read this Privacy Notice carefully and ensure that you understand it. Your acceptance of our Privacy Notice is deemed to occur upon your first use of our website or the first time we formally communicate with you.
Definitions and Interpretation
In this Notice the following terms shall have the following meanings:
“Cookie” Means a small text file placed on your computer or device by our Site when you visit certain parts of our Site and/or when you use certain features of our Site. Details of the Cookies used by our Site are set out in our Cookies Policy, located on our website.
“Personal data” Means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”)
“We/Us/Our” Means Apex Chambers of Harlech House, 20 Cathedral Road, CARDIFF CF11 9LJ.
“GDPR” EU General Data Protection Regulation
How we use your information
All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the GDPR at all times.
Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:
• Supplying our services to you;
• Replying to emails from you;
• Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by emailing email@example.com);
• Considering your application to work for Apex Chambers as a member of staff, Pupil or Mini Pupil; and
• Managing your current employment arrangements with Apex Chambers or your previous employment with Apex Chambers
We will not send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
You have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it.
We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained in line with minimum statutory timelines or, where no retention period is legislated, in line with Apex Chambers Retention Policy.
Visitors to our Website
When someone visits www.apexchambers.net we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
People who email us
We use Transport Layer Security (TLS) and Secure Socket Layer (SSL) to encrypt and protect email traffic. If your email service does not support TLS, you should be aware that any emails we send or receive may not be protected in transit.
We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.
People who make a complaint to us
When we receive a complaint from a person we formally record the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide.
We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the nature of a person’s conduct is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.
We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for two years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.
People who Instruct Us Using our Website
Apex Chambers has specially trained barristers able to work directly with individuals and companies under the ‘direct access’ rules. This means that in suitable cases you can come directly to a barrister without first needing to instruct a solicitor. If you wish to instruct a barrister directly and seek our help via our website, we will ask you to complete an on-line form, providing us with your contact details and a brief summary of your requirements. From this, we will be able to contact you and discuss your needs. If you decide not to proceed with our Direct Access services, once you have advised us of this, we will delete your contact details from our records.
Job applicants, current and former Apex Chambers employees
Apex Chambers is the data controller for the information you provide during the process unless otherwise stated. If you have any queries about the process or how we handle your information please contact us at firstname.lastname@example.org
What will we do with the information you provide to us?
All of the information you provide during the process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary.
We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format.
We will use the contact details you provide to us to contact you to progress your application. We will use the other information you provide to assess your suitability for the role you have applied for.
What information do we ask for, and why?
We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary.
The information we ask for is used to assess your suitability for employment. You don’t have to provide what we ask for but it might affect your application if you don’t.
If you apply for a role through a third party agency, your personal information will be collected by a data processor on our behalf (please see below).
We ask you for your personal details including name and contact details. We will also ask you about your previous experience, education, referees and for answers to questions relevant to the role you have applied for. Our recruitment staff will have access to all of this information.
You will also be asked to provide equal opportunities information. This is not mandatory information – if you don’t provide it, it will not affect your application. This information will not be made available to any staff outside of our recruitment team, including hiring managers, in a way which can identify you. Any information you do provide, will be used only to produce and monitor equal opportunities statistics.
The Clerk/individual person responsible for hiring into a particular position will shortlist applications for interview.
We might ask you to participate in assessment days; complete tests or occupational personality profile questionnaires; and/or to attend an interview – or a combination of these. Information will be generated by you and by us. For example, you might complete a written test or we might take interview notes. This information is held by Apex Chambers.
If we make a conditional offer of employment we will ask you for information so that we can carry out pre-employment checks. You must successfully complete pre-employment checks to progress to a final offer. We are required to confirm the identity of our staff, their right to work in the United Kingdom and seek assurance as to their trustworthiness, integrity and reliability.
You will therefore be required to provide:
• Proof of your identity – you will be asked to attend our office with original documents, we will take copies.
• Proof of your qualifications – you will be asked to attend our office with original documents, we will take copies.
• You will be asked to complete a criminal records declaration to declare any unspent convictions.
• We will contact your referees, using the details you provide in your application, directly to obtain references
• We will also ask you to complete a questionnaire about your health. This is to establish your fitness to work. This is done through a data processor (please see below).
If we make a final offer, we will also ask you for the following:
• Bank details – to process salary payments
• Emergency contact details – so we know who to contact in case you have an emergency at work
Use of Data Processors
Data processors are third parties who may provide elements of our recruitment and employment services for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us, unless to carry out the duty they are contracted to do, for example sharing specific details with HMRC in order for them to correctly calculate your tax codes. They will hold it securely and retain it for the period we instruct, or which is required by law.
Cant Y Cant
If you are employed by Apex Chambers, relevant details about you will be provided to Cant Y Cant who provide payroll services to Apex Chambers. This will include your name, bank details, address, date of birth, National Insurance Number and salary.
Medrus UK Limited
If you are employed by Apex Chambers or are a self-employed barrister with chambers, Medrus will provide you with payroll services, collection of chambers rent from barristers and staff contract management. This will include your name, bank details, address, date of birth, National Insurance Number and salary details.
Your details will be provided to Nest who are the administrators of Chambers’ Stakeholder Pension Scheme. You will be auto-enrolled into the pension scheme and details provided to Nest will be your name, address, date of birth, National Insurance number and salary. Your bank details will not be passed to Nest at this time.
We sometimes advertise administrative positions through the local Press. On an individual basis, chambers will agree terms and conditions for this service, with the advertiser. The advertiser will only act as a method of promoting the vacancy and will not receive or distribute your personal information. Applicants will be requested to submit their CV and covering letter directly to Apex Chambers and this information shall be used by chambers to assess your suitability for the role you have applied for.
How long is the information retained for?
If you are successful, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment plus 6 years following the end of your employment. This includes your criminal records declaration, fitness to work and references.
If you are unsuccessful at any stage of the process, the information you have provided until that point will be retained for 6 months from the closure of the campaign.
Information generated throughout the assessment process, for example interview notes, is retained by us for 6 months following the closure of the campaign.
Equal opportunities information is retained for 6 months following the closure of the campaign whether you are successful or not.
How we make decisions about recruitment?
Final recruitment decisions are made by hiring managers and members of our Management Committee, where appropriate. All of the information gathered during the application process is taken into account.
You are able to ask about decisions made about your application by speaking to our Senior Clerk or by emailing email@example.com
Pupillage / Mini-Pupillage
We also offer opportunities for people to join us under our Pupillage and Mini-Pupillage schemes. We advertise Pupillage positions on both our website as well as www.pupillagegateway.com Applicants should email their CV and covering letter to firstname.lastname@example.org. Further information can be found on the recruitment page of our website.
Mini-Pupillages are advertised on our website during the periods they are being offered. Applicants should email their CV and covering letter to email@example.com. Further information can be found on the recruitment page of our website.
Once we have considered your application, we’ll contact you using the details you provided.
We might ask you to provide more information about your skills and experience or invite you to an interview.
If you join chambers either as a Pupil or Mini Pupil we will ask you to sign a confidentiality agreement.
Your application to join chambers along with any other personal information provided during your time at chambers will be retained for the duration of your attachment plus 6 years following your departure from chambers.
How and Where Do We Store Your Data?
We only keep your personal data for as long as we need to in order to use it for its original purpose and/or for as long as we have your permission to keep it.
Your data will only be stored in the UK.
How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by us (where such data is held). Under the GDPR, no fee is payable and we will provide any and all information in response to your request free of charge. Please contact us for more details at firstname.lastname@example.org or using the contact details below.
As a data subject, you have the following rights under the GDPR, which this Policy and our use of personal data have been designed to uphold:
• The right to be informed about our collection and use of personal data;
• The right of access to the personal data we hold about you;
• The right to rectification if any personal data we hold about you is inaccurate or incomplete (please contact us using the details at the end of this Policy);
• The right to be forgotten – i.e. the right to ask us to delete any personal data we hold about you (We only hold your personal data for a limited time, as explained in in this Policy but if you would like us to delete it sooner, please contact us using the details at the end of this Policy);
• The right to restrict (i.e. prevent) the processing of your personal data;
• The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
• The right to object to us using your personal data for particular purposes; and
• Rights with respect to automated decision making and profiling.
If you have any cause for complaint about our use of your personal data, please contact us using the details provided at the end of this Policy and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
Complaints or queries
Apex Chambers tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.
This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of chambers’ collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.
If you want to make a complaint about the way we have processed your personal information, you can contact us at email@example.com
Access to personal information
Apex Chambers tries to be as open as it can be in terms of giving people access to their personal information. Individuals can find out if we hold any personal information by making a Subject Access Request. If we do hold information about you we will:
• give you a description of it;
• tell you why we are holding it;
• tell you who it could be disclosed to; and
• let you have a copy of the information in an intelligible form.
In most cases you will not charge for complying with a request. We will provide this information within one month of receiving your request. We reserve the right to refuse or charge for requests that we consider to be manifestly unfounded or excessive. However, if we refuse a request, we will tell you why and advise you of your right to complain to the supervisory authority and to a judicial remedy. We will do this without undue delay and at the latest, within one month of receiving your request.
To make a request to Apex Chambers for any personal information we may hold you need to put the request in writing addressing it to the Senior Clerk at the address provided below.
If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
If we do hold information about you, you can ask us to correct any mistakes by, once again, contacting the Senior Clerk.
Do We Share Your Data?
In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal obligations, a court order, or a governmental authority. Subject to the above circumstances, we will not share any of your data with any third parties for any purpose.
Disclosure of personal information
In many circumstances we will not disclose personal data without consent. However when we investigate a complaint, for example, we will need to share personal information with the organisation concerned and with other relevant bodies.
Please contact firstname.lastname@example.org for further information on:
• agreements we have with other organisations for sharing information;
• circumstances where we can pass on personal data without consent for example, to prevent and detect crime and to produce anonymised statistics;
• our instructions to staff on how to collect, use and delete personal data; and
• how we check that the information we hold is accurate and up to date.
Links to other websites
This privacy notice does not cover the links within this Policy or our website linking to other websites. We encourage you to read the privacy statements on the other websites you visit.
Changes to this privacy notice
We keep our privacy notice under regular review. This privacy notice was last updated on 15th May 2018
How to contact us
20 Cathedral Road
CARDIFF CF11 9LJ
If you wish to report a concern about how you believe we are handling your personal data or feel that we have not responded to your Subject Access Request in line with our procedure laid out in this Policy, please contact The Information Commissioner at www.ico.org.uk or write to;
Information Commissioner's Office