Recruitment Privacy Notice

Data Protection

Details of how and why we process your personal data are contained in the Company’s Data Privacy Notice, enclosed in the attached Schedule. The parties expressly acknowledge and agree that the Data Privacy Notice does not form part of your terms and conditions of employment. However, you acknowledge receipt of the Data Privacy Notice and confirm that you have read and understood its contents.

The Company takes its data protection obligations seriously and, in this regard, has a Data Protection and Privacy Policy (the “Privacy Policy”) which is applicable to all employees. Any breach of the Privacy Policy by an employee may result in disciplinary action, up to and including dismissal. For further information on data protection procedures and processes please refer to the Privacy Policy. The Company reserves the right to change, replace or withdraw its Privacy Policy at any time and you are required to comply with the policies and procedures in force from time to time.



This Data Privacy Notice is intended to ensure that you are aware of what personal data Spence & Partners Limited (we, us, our) with a registered address at 27-37 Linen Loft, Adelaide Street, Belfast, Northern Ireland, BT2 8FE, holds in relation to you, and how we use that data as data controller.

Please read the following carefully to understand our use of your personal data.

Your Right to Object – Please note that you have a right to object to processing of your personal data where that processing is carried out for our legitimate interest.


This Data Privacy Notice applies to you, as a prospective employee (including those that may be unsuccessful in the application process), partner, worker, applicant, interview candidate, intern, agency worker, consultant, individual contractor and director. It also applies to third parties whose information you provide to us in connection with our relationship with you (for example, in respect of emergency contact information). Please ensure that you provide a copy of this Data Privacy Notice to any third parties whose personal data you provide to us.

Where we refer to ’employee personal data’ or ’employment’ in this Data Privacy Notice, we do so for convenience only, and this should in no way be interpreted as purporting to confer employment status on non-employees to whom this Data Privacy Notice also applies above. This Data Privacy Notice does not form part of any contract of employment and does not confer any contractual right on you, or place any contractual obligation on us.

It applies to all personal data relating to you collected, maintained, transmitted, stored, retained, or otherwise used (i.e. processed) by us regardless of the media on which that personal data is stored. We may update this Data Privacy Notice at any time and will notify you in writing of any changes.

What is Personal Data?

‘Personal Data’ is defined as any data relating to a living individual who can be identified directly from that data or indirectly in conjunction with other information. We hold some or all of the following types of personal data in relation to you:

  • Contact/identifying details including name, address, date of birth, photo, civil status, emergency contact details;
  • Monitoring forms which include details of your community background and gender;
  • Curriculum Vitae and/or application form, previous employment background, references from previous employers, educational details, professional and/or academic transcripts;
  • Salary and benefit details including bank details; PPS number, tax information;
  • Job description, history and details of current position;
  • Interview records and performance assessments (including probationary assessments), data relating to training and development needs or records of training and, where relevant, executive objective forms;

Purpose and Legal Basis for Processing

We will hold, process and may disclose personal data provided by you for the following purposes:

Purpose Legal basis for processing
  • Recruitment/appointment including assessing your job application;
  • Reimbursing expenses;
  • This use of your data is necessary to process job applications submitted by, or on your behalf, and for performance of your contract of employment.
  • Comply with our regulatory (for example disclosing tax data to the office of the HMRC) and professional requirements;
  • Monitoring community background and gender breakdown of your employees, applicants, appointees and, in some instances, promotes and leavers for the purpose of completing annual monitoring returns and Article 55 Reviews as required by the Equality Commission for Northern Ireland; and
  • Exercising our right to defend, respond or conduct legal proceedings.
  • This use of your data is necessary in order for us to comply with any legal or regulatory obligations

Special Categories of Personal Data

Certain categories of your personal data are regarded as ‘special’. Special data includes information relating to an individual’s:

  • Physical or mental health;
  • Religious and philosophical beliefs
  • Political opinions;
  • Trade union membership
  • Ethnic or racial origin;
  • Biometric or genetic data; and
  • Sex life and sexual orientation.

We only process such data where necessary for:

  • the purpose of carrying out the obligations, and exercising specific rights, of Spence & Partners Limited or of an employee under employment law;
  • the assessment of your working capacity; and/or
  • the establishment, exercise or defence of legal claims.

If we wish to process your special personal data for any further purpose, we will seek your explicit consent to do so. You have the right to withdraw your consent to that processing at any time.

Data Relating to Crimes

 We will only process data relating to your criminal convictions or involvement in criminal proceedings when permitted or required by law, or where provided voluntarily by you.

Where you do not provide your Personal Data

If you do not provide us with your personal data we may not be able to process your job application, suitability for a particular role,  and comply with our legal obligations . We will tell you when we ask for information which is a contractual requirement or needed to comply with our legal obligations.

Recipients of Your Personal Data

We may disclose your personal data to members of our corporate group including, without limitation, for the following reasons: in order to, run global processes, carry out group wide reporting, or take decisions about hiring or promotion.

It may be necessary from time to time for us to disclose your personal data to third parties or agents, including without limitation to the following:

  • Third parties or agents of clients to assist in the administration, processing and management of certain activities pertaining to past, current and prospective employees;
  • Relatives or legal representatives of current and prospective employees;
  • Regulatory bodies to whom we are obliged or required to disclose information including the Office of the Industrial Tribunals and Fair Employment Tribunal, the Equality Commission for Northern Ireland other relevant regulatory / governing bodies, courts and court-appointed persons;

We will inform you in advance if we intend to further process or disclose your personal data for a purpose other than the purposes set out in this Data Privacy Notice. We take all reasonable steps, as required by law, to ensure the safety, privacy and integrity of such data and information and, where appropriate, enter into contracts with such third parties to protect the privacy and integrity of such data and any information supplied.

Transfer of Personal Data outside the EEA

The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA“), for the purposes described above. Those countries may not provide an adequate level of protection in relation to processing your personal data. Due to the global nature of our business, your personal data may be disclosed to members of our group outside the EEA, including in particular in the USA. It may also be processed by personnel operating outside the EEA who work for us or for one of our suppliers who act on our behalf. We will ensure appropriate safeguards are in place to protect the privacy and integrity of such personal data. You can obtain information concerning such safeguards from the HR Department, where applicable.

Security and Storage of Personal Data

We securely store your personal data in a centralised database, with controlled access to such database. Access to personal data (including special data) in both electronic and paper form is restricted to members of the HR Department and employees who have a legitimate and justifiable reason to view such data.

Data Retention

An employee’s data will be stored for the duration of their employment and retained to the extent necessary to enable us to comply with any legal obligations or for the exercise or defence of legal claims following termination of employment. Unsuccessful applicants’ personal data maybe be stored for up to six years then destroyed in accordance with our legal obligations.

Your Data Rights

You have several rights in relation to your personal data.  You have a right to:

  • access a copy of your personal data held by Spence & Partners Limited;
  • request rectification of your personal data if it is inaccurate or incomplete;
  • request erasure of your personal data in certain circumstances;
  • restrict our use of your personal data in certain circumstances;
  • move (or port) personal data which you have given us to process on the basis of your consent or for automated processing;
  • object to the processing of your data where our legal basis for processing your data is our legitimate interests; and
  • not to be subject to a decision based on automated processing, including profiling which has legal or similar significant affects.

However, these rights may not be exercised in certain circumstances, such as when the processing of an employee’s data is necessary to comply with a legal obligation or for the exercise or defence of legal claims.  If you wish to exercise any of your rights in this regard please contact the HR Department. We will respond to your request in writing, or orally if requested, as soon as practicable and in any event not more than within one month after of receipt of your request. We may request proof of identification to verify your request.


You have the right to lodge a complaint with the Information Commissioner’s Office if you are unhappy with how your personal data is being handled.

Further Information

If you require any further clarification regarding this Data Privacy Notice, please contact:

Please note by accepting you are acknowledgment of receipt of Spence & Partner Limited’s recruitement data privacy notice

I acknowledge that I have received a copy of the Spence & Partners Limited Recruitment Data Privacy Notice.

I acknowledge that the Spence & Partners Limited Recruitment Data Privacy Notice is not a contract, express or implied and that it does not set terms or conditions of employment.

I understand that the Spence & Partners Limited Recruitment Data Privacy Notice may be updated at any time and that Spence & Partners Limited will notify me in writing of any such changes.

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