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Last updated: February 2022
The Solicitors Regulation Authority Limited (“SRA”, “we” or “us”) is the “data controller” of the personal information we hold for the purposes of the UK General Data Protection Regulation (the UK GDPR) and the Data Protection Act 2018 (the Data Protection Act).
The SRA is a wholly owned subsidiary of the Law Society of England and Wales (the Law Society), a body incorporated by Royal Charter.
The SRA have a contract for services in place with Kaplan SQE to operate the SQE, which includes suitable provisions to ensure Kaplan processes personal data in accordance with our requirements and those prescribed by the data protection laws. Kaplan is the sole assessment provider for the SQE.
Kaplan SQE Limited, a company registered in England with company number 11637771 and registered address at 179 – 191 Borough High Street, London SE1 1HR (“Kaplan SQE”) acts as a “data processor” of SQE candidate personal data for the purposes of the data protection laws (subject to the exceptions stated below).
The SRA’s grounds for processing personal data
Our lawful basis for processing this information is under GDPR is Article 6 Section 1(e) and Article 9 Section 2(g) as it is necessary for the exercise of our official authority in the public interest.
As the regulatory body for solicitors in England and Wales we are required to exercise our protective functions which are functions derived from the following legislation:
We collect, use and share data primarily in the exercise of these regulatory functions. Those functions, and our duties and powers, are chiefly found in primary legislation as set out above as well as in the rules and regulations made by our Board which sit beneath it.
From time to time, we may contact individuals in relation to research projects we are undertaking. We undertake research to gain more insight into the profession and emerging issues to inform policy development, achieve regulatory objectives, comply with equality duties and decision making (which, again, accords with our regulatory powers and duties). We also prepare and publish or share statistics obtained from data we collect but not in a form that identifies anyone
Certain limited personal data is processed by Kaplan SQE as a “data controller” in order to:
As a SQE candidate, Kaplan SQE collects and processes your personal data submitted in connection with the SQE so that they can process your application, payment and provide examination and assessment services on the behalf of the SRA.
When you request information or make enquiries about any of their services or programmes, Kaplan SQE will use the personal data you provide in order to fulfil your request or respond to your enquiry.
If you register with them, submit a booking request or make payment for, or attend, an SQE assessment, Kaplan SQE will collect the following categories of personal data about you through your Candidate Account:
You will also be asked (but not required to provide) information about education, work experience, age, disability, ethnicity, sex orientation, gender, religion or belief, caring responsibilities, socio-economic background and national identity. This information is treated with strict confidence.
Your special category data is processed either in the substantial public interest to achieve regulatory objectives or to comply with the SRA’s equality duties. The data will be used to monitor the equality impact of the assessment to ensure that it complies with the Equality Act 2010 and the Public Sector Equality Duty including evaluating different statistical approaches to detecting bias.
We may also prepare and publish or share statistics or research obtained from this data but not in a form that identifies anyone.
We will not use your personal data for marketing purposes.
Kaplan SQE will collect information about your progression through the SQE assessments together with your scripts including videos of performances.
If you make any academic appeals and/or complaints, Kaplan SQE will collect a statement of circumstance and supporting evidence if applicable.
If you request any reasonable adjustments on health grounds, Kaplan SQE may need to collect personal data about your health in order to make appropriate arrangements and reasonable adjustments for you regarding your welfare or attendance.
Data may also be used to improve the level of service. Where possible they will anonymise this information.
Kaplan SQE is collecting and holding your data. Relevant data will be shared with the SRA at the appropriate time to enable you to apply to be a solicitor.
Kaplan SQE has entered into contracts with third party suppliers whose services are required to support the provision of the SQE assessments. Kaplan SQE will share your personal data with such suppliers as is required under those contracts in order for the services to be performed.
These services may include processing booking requests and payments, verifying your identity, providing systems enabling you to schedule and manage assessment appointments and engaging in associated correspondence, providing customer service, performing business and sales analysis and supporting our website and IT functionality. These service providers may be supplied with or have access to your personal data solely for the purpose of providing these services to us or on our behalf.
Where you are an apprentice, Kaplan SQE has entered into a contract with your training provider or employer for the provision of assessment services, on behalf of the SRA. Kaplan SQE will share your personal data with the training provider or employer as is required under those contracts for the services to be performed. This could include sharing your results and progress in SQE assessments with them.
Kaplan SQE may also need to share your personal data with other professional or regulatory bodies, including the Education and Skills Funding Agency if you are an apprentice, or if required to otherwise comply with law.
In the event that the SRA replaces Kaplan SQE with another approved assessment provider, it may share your data with such provider in order that assessments can continue to be provided to you.
Kaplan SQE is an international business with employees, entities and service providers all over the world, and so it may need to transfer the personal data you provide to other countries which may be outside the UK and the European Economic Area (EEA).
The data protection laws in such countries may not be as comprehensive and provide the same level of protection for your personal data as those within the UK or the EEA. In these circumstances, they will take appropriate steps to ensure that your personal data is handled as described in this Privacy Notice. These steps will include appropriate contractual mechanisms.
Your personal data will only be retained for as long as necessary to fulfil the purposes for which it was collected, to ensure the SRA can fulfil its regulatory role in the public interest, and for Kaplan SQE and/or the SRA to satisfy any legal, accounting or reporting requirements.
To determine the appropriate retention period for personal data, the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which your personal data is being processed, and whether those purposes can be achieved through other means, and the applicable legal requirements are considered.
It is important that the personal information held about you is accurate and current, therefore please keep your information up to date.
In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Please contact us using the details in this Privacy notice if you would like further information about how long your personal data is retained.
We are under a general duty to keep personal data and information confidential. Where we share information, we take all reasonable steps to keep it secure, use it fairly and ensure that data protection safeguards are in place. We use secure portals and encryption tools when necessary to ensure data in transit is protected.
We apply best practice in terms of information security, in line with the ISO:27001 standard and adopt a privacy by design approach in developing new systems and processes involving personal data, considering the rights of individuals and the risks involved at the start of projects to make sure we build in suitable controls. Kaplan SQE is ISO:27001 certified.
Depending on the information we hold about you, and the reason it is being held, you have certain rights which are set out below. In some cases, exemptions disapply your rights and the obligations the data controller/data processor have towards you.
You have the right to obtain a copy of personal data held about you for the purpose of the SQE, including the reasons why it is held, who the data will be shared with as well as details of the period for which the data will be retained.
You are entitled to have your records amended if the personal data held is inaccurate or incomplete. The right to rectification does not always apply. For example, it does not include amending data which was accurate about you at one time even though the current position is different.
You have a right to request your data is deleted in certain circumstances, i.e. where it is no longer needed for the purposes it was collected; you object to the processing (see below) and there are no overriding legitimate grounds to continue; where the data has been unlawfully processed; or where it has to be erased for compliance with a legal obligation.
This right does not apply where the information is needed for the performance of the SRA’s regulatory functions or for example there is a need to comply with a legal obligation or it is necessary to process the data in connection with legal proceedings or legal advice.
You have the right to object to processing your information in certain circumstances, i.e. where it is being processed in connection with the exercise of the SRA’s regulatory function or where it is being processed under the grounds of legitimate interest of any party. In such a case, we will stop processing unless we can demonstrate compelling legitimate grounds for continuing the processing which override your interests.
If you would like to submit a request please email Kaplan SQE using the details below or complete this form.
If you have any concerns about the matters in this statement or the way we process your data, then you can you can email us:
SRA email address: SRAinformationcompliance@sra.org.uk
For more detailed information on how personal data is processed please see the SRA’s full privacy notice at www.sra.org.uk/privacy
If you would like to contact Kaplan SQE regarding how they handle your data you can email them:
Kaplan SQE email address: firstname.lastname@example.org
Postal address: Kaplan SQE, Spring House, 40-44 Holloway Road, London N7 8JL.
If you are an EU national or resident in an EU country, and wish to contact our EU Representative:
Kaplan Ireland Education Limited, 13/14 Aungier Street, Dublin 2, D02 WC04 Ireland
If you are a citizen or resident in China, and wish to contact our China Representative:
Shanghai Kaibo Management & Consulting Co., Ltd, 29D, Building B, No. 1188, Kai Xuan North Road, Putuo District, Shanghai, People’s Republic of China. To find out more about how Kaplan handles the data of Chinese citizens please see our privacy notice: https://www.kic.org.cn/privacy
You also have the right to lodge a complaint with the Information Commissioner’s Office, the UK supervisory authority for data protection issues (www.ico.org.uk).
We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
We keep this notice under regular review.
Last updated on 1 February 2022
Please contact us using the details in this Privacy notice if you would like further information.
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