Diversity Data Policy

Diversity Data Policy V1.0

Introduction

1. This is the Diversity Data Policy of Drystone Chambers, effective as of 01/02/2023.

2. This is one of a number of specific policies aimed at achieving the objective of Chambers’ Equality and Diversity Policy, available here, which sets out Chambers’ overarching rules, principles and procedures for preventing discrimination, ensuring equality of opportunity, and promoting diversity, and which should be read together with this policy.  Any queries, concerns, complaints or grievances in respect of this policy should be raised with the Diversity Data Officer (DDO).

3. The name of the registered Data Controller for Drystone Chambers is the Head of Chambers, Allison Summers KC and the data controller’s registration number on the Data Protection register is Z6759214.

4. The Diversity Data Officer as appointed and notified to the Bar Standards Board (BSB), is the Chambers Administrator, Russell Burton-Lawrence.

Purpose and scope

5. This policy sets out Chambers procedure for gathering and publishing diversity data in accordance with rules rC110.p to .t of the Bar Standards Board’s Handbook.

6. This policy applies to all members of Chambers, pupils and employees.

Collection of Diversity Data

7. Members of Chambers’ workforce (e.g. members of Chambers, pupils and employees) are given the opportunity to provide their Diversity Data for collection in accordance with the BSB requirements and for the purposes set out below.  The Diversity Data Officer is responsible for arranging and supervising the collection of Diversity Data.  Diversity Data is collected every three years.  As at the date of this policy, the data is due to be collected next in October 2023.

Why Diversity Data is collected

8. Individuals have the opportunity to provide their Diversity Data in order for Chambers 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.

9. You are not obliged to provide your Diversity Data and if you submit diversity data you do so voluntarily. You are free to provide all, some or none of your Diversity Data.  A ‘prefer not to say’ option is provided in all our diversity surveys.  Individuals may withdraw their consent to the use of their data at any time.

How Diversity Data is collected

10. Diversity Data will be collected through the completion of an online form, on an anonymous basis.  The online form shall be based on the model questionnaire provided by the BSB.  The Diversity Data Officer shall be responsible for the setting-up and operation of the online form system and the collection/compilation of data from the online survey.

11. You will be provided with a link to the online form by email.  The online form shall ask for your consent to the provision and processing of your personal data in accordance with the BSB’s rules and this policy.

Keeping Diversity Data secure

12. All Diversity Data that is collected from individuals will be kept securely.  Chambers shall ensure the following security measures are in place to protect Diversity Data.

1. The collection of data complies with Chambers’ Privacy Policy available here.
2. The online survey IP address tracking facility will be turned off making this survey anonymously secure.
3. The data stored by the online third-party provider is stored in the UK and is GDPR compliant.
4. The Diversity Data Officer is the only person who will have access to the online form system.

13. Chambers will not share Diversity Data with any third parties, save as set out in paragraph 12 above.

Anonymising Diversity Data

14. Diversity Data shall be collected on an anonymous basis.  The diversity data shall therefore always be processed and held in anonymous form.

Publication of the anonymised summary of Diversity Data

15. Chambers shall publish on its website a summary of the anonymised diversity data, in accordance with the BSB rules.  This shall provide a breakdown of diversity characteristics (in particular sex, gender identity, ethnic group, disability, age, religion or belief, sexual orientation, socio-economic background and caring responsibilities) split between KC tenants, Non-KC tenants, pupils and employees of Chambers.

16. 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 shall not publish that part of the information unless it has the consent from the individuals affected.

Destruction of Diversity Data

17. Anonymised data will be kept for 12 months after collection in accordance with BSB rules.  The Diversity Data Officer will be responsible for securely destroying the Diversity Data collected within three months thereafter.  Secure destruction means that as far as possible Chambers shall not hold the Diversity Data in any way where it is possible to identify an individual.

Questions or complaints

18. You have a right to withdraw your consent or object to the use of your Diversity Data at any time.

19. Where your data has been already provided and you wish to withdraw your consent to its use, please notify the Diversity Data Officer by email to russell.burton-lawrence@drystone.com.  He will promptly delete or destroy any Diversity Data which includes your personal data and will confirm to you that this step has been taken within 21 days of receiving notification from you.

21. 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 it is likely that continued publication could 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 date you notify him of your belief to let you know whether he 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.
22. Should you have any questions or complaints about this Diversity Data Policy, please contact the Diversity Data Officer.