Select the headings below to find out how we use your personal information, who we may share it with and how we protect it, as well as your rights and how to exercise them or click the link to read our full colleague privacy notice.

    If you would like a copy of our full colleague privacy notice or if you have any questions about how Lowell use and share your personal information, please contact our Data Protection Officer by:

    • email at dpo@lowellgroup.co.uk or
    • letter at Data Protection Officer, Lowell Financial Ltd, PO BOX 1411, Northampton, NN2 1BQ.

    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.

    • Who are we?

      You are employed by one of the UK Lowell companies:

      Company

      Lowell Financial Ltd

      Lowell Solicitors Limited

      Fredrickson International Limited

      Company number

      Company number 04558936

      Company number 08647091

      Company number 02679522

      Country

       

      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

      Darwin House, 7 Savannah Way, Leeds Valley Park, Leeds LS10 1AB

      Ellington House, 9 Savannah Way, Leeds Valley Park, Leeds LS10 1AB

       

      Where we use “Lowell” “we”, “our” or “us” in this notice, we mean Lowell Financial Ltd, Lowell Solicitors Limited and Fredrickson International Limited unless we say otherwise.

      Lowell Financial Ltd deals with talent acquisition, onboarding of new employees and general HR matters for Lowell Solicitors Limited and Fredrickson International Limited, so if you speak to or receive an email or letter from a member of our talent acquisition, onboarding or other HR teams, it will usually be Lowell Financial Ltd that you are dealing with.

      If you are an employee of Lowell Financial Ltd, Lowell Financial Ltd will be the controller of your information.

      As Lowell Financial Ltd deals with talent acquisition, onboarding and other HR matters for all our UK companies, if you are employed by either Lowell Solicitors or Fredrickson International Limited, this means that Lowell Financial Ltd and the company you are employed by are joint controllers of your information which means that we are both responsible for looking after your information.

    • What information do we collect about you?

      We collect:

      • 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, 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
      • information collected as part of the talent acquisition process, including as a result of the pre-employment checks, tests and assessments we carry out. For more details about the information we collect and the pre-employment checks we carry out, please see the section What information do we collect about you? of our applicant privacy notice and the section What pre-employment checks do we carry out? below
      • bank account details and payroll information, including salary and benefits package and pension and tax information
      • performance reviews, appraisals and learning and development records
      • employment history with Lowell including absence information, any disciplinary proceedings and outcomes and any grievances
      • details of your emergency contact, including their name, their relationship to you and their contact details
      • details of any accounts you have with any member of the Lowell group (including Lowell Portfolio I Ltd, Lowell Financial Ltd, Lowell Solicitors Limited and Fredrickson International 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
      • 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 (whether these are business or personal)
      • information gathered through Lowell's monitoring of its IT systems, building access records and CCTV recordings
      • recording of our calls with you and calls which you make or receive using Lowell’s telephone system
      • information relating to health and safety at work and accidents at work

      We may 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.

      For more details about how we use this information, please see the section Special categories of personal data of our full colleague privacy notice.

      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. If you apply for an internal vacancy, we may carry out further pre-employment 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 pre-employment checks we have for you, but we will let you know before we carry out any more checks on you.

      For more details about how we use this information, please see the sections What pre-employment checks do we carry out? below and Information relating to criminal convictions of our applicant privacy notice.

      If you are also a customer of Lowell, please see our customer privacy notice for details of what information we collect about you as our customer and how we use, store and protect that information.

      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 use our external website, please see our Website User privacy notice and our Cookie notice for details about the information we collect about you through our website.

    • What pre-employment checks do we carry out?

      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:

      • adverse financial checks
      • a criminal record check.

      Adverse financial checks

      These checks confirm whether there is any adverse data recorded on your credit file relating to defaults, county court judgments (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 see the section Where do we get your information from? below and 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.

      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.

    • Where do we get your information from?

      We collect some information directly from you, for example the information you provide to us during the talent acquisition process and the information which you provide to HR or your line manager as part of the day-to-day management of your relationship with us as a Lowell colleague. 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.

      We also collect information about you when you use our IT, telephone and building access systems. 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 is available to colleagues on our intranet.

      We may collect information about you that is publicly accessible, for example through a Google search.

      We may also obtain information from any recruitment agency we receive your application from, your previous employers, the universities, schools or colleges you attended, your referees, or your regulatory body or professional association, such as The Law Society or the Financial Conduct Authority where relevant.

      We use Experian to carry out pre-employment checks about you. Experian will check your credit file for information about any financial defaults, unsatisfied CCJs, IVAs, or 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.

      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 see the section Where do we get your information from? below and 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.

      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.

      We may also receive information from other members of the Lowell group of companies so that:

      • Lowell Financial Ltd is able to provide talent acquisition and other HR related services to Lowell Solicitors Limited and Fredrickson International Limited
      • for our internal administrative purposes including creating and analysing management information and HR reports
      • to monitor our compliance with our professional, legal, regulatory and other corporate governance obligations.

      We may monitor and/or record calls for the purposes of resolving issues with customer accounts or with colleagues, for training purposes and to improve our quality and service standards. We also operate CCTV at all of our premises. Whilst you are on site at any of our offices, you may be recorded by our CCTV systems.

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

    • Why do we need your information?

      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
      • managing any absences including your return to work and assessing your ability to do your role
      • dealing with any grievances you may have and carrying out any necessary disciplinary proceedings
      • making reasonable adjustments to your working environment if you have a health condition.

      We also use your information to comply with our legal, profession, regulatory 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 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.

      Where we need information relating to your health for any of the above purposes, 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, which we may ask you to confirm in writing.  Please see the sections Special categories of personal data in our full colleague privacy notice for more details.

      Please also see the section Information relating to criminal convictions in our full colleague privacy notice for more details about how we use information relating to criminal convictions.

      If you use our external website, please see our Website User privacy notice and our Cookie notice, for details about the information we collect about you through our website.

      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.

    • Who do we share your information with?

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

      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.

      We will share information with HMRC and the provider of our pension scheme to comply with our legal obligations as your employer. We will also share information with the providers of any benefits which you choose to receive as part of our benefits package.

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

       

      • Lowell Financial Ltd is able to provide talent acquisition and other HR related services to Lowell Solicitors Limited and Fredrickson International Limited
      • for our internal administrative purposes including creating and analysing management information and HR reports
      • to monitor our compliance with our professional, legal and 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.

      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.

      We share information with Experian so that Experian can carry out pre-employment checks for us. Experian has put together an information notice which explains in more detail, how Experian uses and shares personal information about you which is available at www.experian.co.uk/privacy-policies.html.  For more details, please see the section What pre-employment checks do we carry out? above.

      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.

      If we identify evidence of fraud, money laundering or any other crime (whether financial or otherwise) in relation to your application, we will share information with the police and other law enforcement agencies.

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

      We use a number of carefully selected third parties to supply us with products and services, such as payroll, occupational therapy services, HR systems and IT services. This may sometimes involve your information being shared or stored outside of the UK and outside the European Economic Area.  For more details about how we make sure your information is protected if it is shared or stored outside the UK and the European Economic Area, please see the section Where is your information stored? below.

      We may also share your information with our investors insurers, lenders, legal and other professional advisers where necessary.

      For more details, please see the Who do we share your information with? section of our full colleague privacy notice.

    • Where is your information stored?

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

      For more details, please see the Where is your information stored? section of our full colleague privacy notice.

    • How long do we keep your information?

      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.

      For more details, please see the How long do we keep your information? section of our full colleague privacy notice.

    • What rights do you have?

      Under the data protection laws, you have a number of rights in respect of your information, which include the right to:

      • access your information
      • ask us to make changes to the information we hold about you to make sure that it is accurate and up to date
      • delete or erase your information (sometimes called the right to be forgotten)
      • stop or restrict our processing of your information
      • object to our processing your information
      • not be subject to automated decision-making and
      • request the transfer of some of the information we hold about you (known as data portability).

      Some of these rights only apply in certain situations. For more details about how these rights apply to the way we use your information, please see the What rights do you have? section of our full colleague privacy notice.

      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 1411, Northampton, NN2 1BQ.

      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.

    • What if you have a complaint?

      If you have any questions, concerns or complaints about the way either Lowell Financial Ltd, Lowell Solicitors Limited or Fredrickson International 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 1411, Northampton, NN2 1BQ.

      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.

    • Changes to this notice

      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.

      We won’t tell you about every little change. If there are any really important changes, we will highlight these.

    © Lowell Financial Ltd, Lowell Solicitors Limited and Fredrickson International Limited 2018- 2019