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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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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Asking for self-disclosure during recruitment – is it necessary?

Asking applicants to self-disclose criminal records information is seen by most employers as part and parcel of the standard recruitment process. Whether it’s a tick box on the application form or part of pre-employment checks, asking has been the norm. The advent of the GDPR means employers need be clear about the purpose of self-disclosure […]

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Asking applicants to self-disclose can be deemed excessive, says ICO

Last month we published research that showed almost three-quarters of employers ask about criminal records at application stage. Being asked to self-disclose puts off applicants. Unlock encourages employers to consider whether they need to ask about criminal records at all. If you need to ask, questions should be targeted – for example, only asking at […]

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New guidance published to support employers with GDPR, data protection and processing criminal records in recruitment

Today we have published new guidance to support employers to ensure that their policies and practices on collecting criminal records data during recruitment is compliant with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018. The guidance makes it clear that collecting criminal records at the initial application stage is unlikely to be […]

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