Transport for London advised to review processing of criminal records data

Earlier this year Alex registered with Transport for London’s National Apprenticeship Fair, hoping for the chance to meet with 15 employers offering vacancies across London. She was surprised to be asked about unspent convictions for a recruitment fair, but ticked the box and looked for the privacy policy to understand how it would be used. […]

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More employers remove questions about criminal records from application forms

In 2018 research by Unlock found that 70% of well-known national employers asked about criminal records on application. Three years on, with increased understanding of data protection, the GDPR and inclusive recruitment, we reviewed those employers to see what, if anything had changed. Key findings in 2018 The 2018 findings were disappointing, though perhaps not […]

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HMPPS confirms prison and probation roles are covered by filtering rules

Samantha contacted Unlock’s helpline for advice on applying for a ‘Through the Gate’ role with Sodexo. The job involved helping women prepare for leaving prison and would be subject to prison vetting. Sodexo has banned the box, so Samantha was surprised to see the application form ask: Have you ever been convicted of any offences […]

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Do you collect criminal records information?

If you process this information for any reason, the Information Commissioner’s Office would like to hear from you. Employers, universities, insurers, membership organisations and others process criminal records information otherwise known as Article 10 data – for a variety of reasons. The sensitive nature of this data means there are particular safeguards in place to […]

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PriceWaterhouseCoopers fined under GDPR for inappropriate use of consent

The Greek arm of PriceWaterhouseCoopers have been fined €150,000 after an investigation found they were unlawfully relying on employees’ consent to process personal data. PWC claimed to be relying on consent but data was in fact processed to comply with contract obligations. By allowing employees to believe that their data was being processed with their […]

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Unlock collaboration with The Key on guidance for schools recruitment

The Key provides tools and services to education leaders. Unlock worked with The Key on their new guidance on asking about criminal records. Following the introduction of the GDPR, The Key took legal advice on how schools should collect criminal records information. As most roles in schools are exempt from the Rehabilitation of Offenders Act […]

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Midlands university risks carrying out ineligible checks

Lawrence contacted us about a post advertised at a university in the Midlands. The job, Head of Business Programmes, involved working with departments within the university and developing relationships with external partners. Lawrence was surprised then to see that the job description said the post would involve an enhanced DBS check. It wasn’t clear why […]

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A question of fairness: John Lewis Partnership

The John Lewis Partnership (JLP) includes Waitrose and John Lewis. Their online application form asks applicants to indicate whether they have an unspent conviction. The question is compulsory. Selecting ‘Yes’ from the drop-down menu leads to the request for details. The application doesn’t explain why this information is necessary, or what will happen to it. […]

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A question of fairness: Greggs

Greggs’ Fresh Start programme has been running since 2012. In that time they say they have employed one hundred people with previous convictions and that 32% are now in some form of management role. The Fresh Start programme recruits people in prison who are eligible to work outside on ROTL, and is also open to […]

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A question of fairness: Spar

Some applications for retail positions in Spar stores ask about criminal records. We contacted Spar to understand why and the Head of HR confirmed:  …we do not ask applicants questions regarding Criminal Records and we do not need to (given the nature of our work) undertake DBS checks. It’s refreshing to see a retailer assess […]

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