Diversity Data Policy
This is the Data Diversity Policy for Gainsborough Law which is established in accordance with rC110 of the Bar Standards Handbook.
The name of the registered data controller for chambers is Gainsborough Law and the data controller’s registration number on the OCR Data Protection register is ZA014132.
Chambers’ Diversity Data Officer is Camilla Whitehouse.
Collection of Diversity Data
Members of chambers’ workforce are given the opportunity to provide their Diversity Data for collection in accordance with the Bar Standards Board’s requirements. The Diversity Data Officer is responsible for arranging and supervising the collection of Diversity Data.
Why Diversity Data is collected
Individuals have the opportunity to provide their Diversity Data in order for the Diversity Data Officer to publish an anonymous summary of such data. This provides transparency concerning recruiting and employment activities across chambers and analysis of diversity data encourages a strong, diverse and effective legal profession.
Please note: You are not obliged to provide your Diversity Data. You are free to provide all, some or none of your Diversity Data.
How Diversity Data is collected
Diversity Data will be collected through completing an online survey which we ask you to return to the Diversity Data Officer.
You will be provided with a copy of the online form by email, together with a copy of the content form which you must complete if you wish to provide your Diversity Data.
You will be notified of the deadline for completing the forms, which will be no less that 7 days from the data of notification.
Keeping Diversity Data secure
All Diversity Data that is collected from individuals will be kept securely. Gainsborough Law shall put the following security measures in place to protect Diversity Data:
- All Diversity Data will be collected in soft form only and stored within Gainsborough Law’s bank secure, cloud-based, online management system.
- All Diversity Data will be processed in accordance with the General Data Protection Regulations and other applicable data protection laws and regulations.
- Restricted access to Diversity Data will apply ensuring against unlawful and unauthorised disclosure or access.
- Access and analysis of Diversity Data will be done by the Diversity Data Officer only.
- Gainsborough Law will not share Diversity Data with any third parties, save as equality rules which came into force in September 2012 requesting chambers to publish anonymised summary data every three years.
- If there is a real risk that the publication of the summary of anonymous data would result in the identification of an individual in respect of one or more of their diversity characteristics, chambers are not required to publish that part of the information unless it has consent from the individuals affected.
- Should you access or disclose Diversity Data accidentally or intentionally when you are not authorised to do so, you must notify the Diversity Data Officer immediately.
Anonymising Diversity Data
Gainsborough Law is required to anonymise Diversity Data before publishing it in summary form. The Diversity Data Officer will securely anonymise Diversity Data under the following categories: age, gender, ethnic group, religion or belief, sexual orientation, socio-economic background and caring responsibilities.
Publication of the anonymised summary of Diversity Data
The Diversity Data Officer is required to publish diversity data in an anonymised summary format within the three-month period following the date for collection specified by the Bar Standards Board. The summary will break down the information in a way which categorises each diversity characteristic against job status and role, in a manner which reflects seniority within Gainsborough Law. The summary will be published online via the Gainsborough Law website.
Where there are fewer than ten individuals within each published category who identify through the questionnaire with the same diversity characteristic (for example, two individuals with a job role at the same level of seniority identify themselves as disabled), the Diversity Data Officer shall not publish the anonymous data relating to those individuals and that diversity characteristic unless the individuals concerned have each consented to such publication, in the knowledge that they may be identified against that characteristic.
If Gainsborough Law cannot publish an anonymised summary of its diversity data, it will publish a summary of the data in headline terms, to give a general picture of its diversity.
Destruction of Diversity Data
Gainsborough aw will securely destroy the Diversity Data collected promptly after the Data has been anonymised and in any event within 3 months following the date of collection. Secure destruction means that as far as possible we shall not hold the Diversity Data in any way where it is possible to identify an individual. In practice relevant documents will be deleted from our online system.
Anonymised data will be kept for 12 months before being destroyed as above.
Questions or complaints
Individuals have a right to withdraw their consent or object to the use of their diversity data at any time.
Where your data has already been provided and you wish to withdraw your consent to its use. Please notify the Diversity Data Officer in writing at email@example.com Your data will promptly be deleted or destroyed and you will receive written confirmation that this step has been taken within 21 days of receiving notification from you.
Where the anonymised data has been published in summary form, the Diversity Data Officer will not extract your personal data from the published summary unless you have reason to believe that continued publication of the anonymised data is causing, or is likely to cause you or someone else, substantial damage or distress. In such circumstances, the Diversity Data Officer will consider the reasons you have put forward and shall respond within 21 days from the data you notify her of your belief to let you know whether she has determined that the continued publication of the data is justified and, if not, to confirm the action taken to extract your data from the published summary and to delete or destroy any copies.
Any questions or complaints about Gainsborough Law’s Diversity Data Policy can be sent to the Diversity Data Officer at firstname.lastname@example.org