Privacy & Data Protection Policy

Last Updated: 13/03/2025

Introduction

• This Privacy Policy describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
• This Privacy Policy applies in respect of the personal data of the following categories of people: Candidates, Clients, and Website Users
• We are subject to applicable data protection legislation including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), and the UK GDPR.  Please note that when we refer to the GDPR throughout this Privacy Policy, we are referring to both the GDPR and UK GDPR.
• The company responsible for your personal data (“Evolve”, “we” or “us“) can be found here.
• It is important to point out that we may amend this Privacy Policy from time to time. We will inform you of any material changes to this Policy by email in advance of them coming into effect.
• If you are dissatisfied with any aspect of our Privacy Policy, you may have legal rights and, where relevant, we have described these in this document.

How to Use This Privacy Policy

• This Privacy Policy tells you a few things about how we use your personal data, and perhaps more importantly, what your rights are in relation to this (you have, for example, the right to ask us to delete or confirm the nature of information that we hold about you at any time, withdraw any consents that you may previously have given and/or lodge a complaint with our Data Protection Officer or a supervisory authority if you are not happy about something we have done).
• The Privacy Policy is broadly divided into two sections:
  • Context-specific privacy information that applies to the different categories of person covered by this Privacy Policy, as follows:
    • Candidates
    • Clients
    • Website Users
  • General privacy information that applies to all of the different categories of people covered by this Privacy Policy, including:
    • Who do we share your personal data with?
    • How do we safeguard your personal data?
    • How long do we keep your personal data for?
    • How can you access, amend or take back the personal data that you have given to us?
    • Who is responsible for processing your personal data when you access the Evolve website?
    • How do we store and transfer data internationally?
    • Use of third party services

Context-Specific Privacy Information

Candidates

Candidates include individuals with whom Evolve has not had prior contact, but whom Evolve reasonably considers would be interested in, or might benefit from, Evolve’s services and being considered for any roles advertised or promoted by Evolve including permanent, part-time and temporary positions and freelance roles with Evolve’s Clients. Candidates also include applicants for such roles as well as people who have supplied a speculative CV to Evolve not in relation to a specific job and/or who have engaged with Evolve about Evolve’s services and/or any roles advertised or promoted by Evolve.

What kind of personal information do we collect?

The information described below is in addition to any personal data we are required by law to process in any given situation.

Depending on the relevant circumstances and applicable local laws and requirements, we will collect some or all of the information listed below to enable us to assess how we can assist you if we reasonably believe you might be interested in, or might benefit from our services, and to offer you employment opportunities which are tailored to your circumstances and your interests.

• Key identification and contact information
  • Name;
  • Sex/gender;
  • Contact details, such as phone number, street address and email address;
• Education and employment information
  • Education details;
  • Employment history;
  • Current job title/specialism/industry sector;
  • Skills and languages spoken;
  • Immigration status (whether you need a work permit);
  • Start date or availability date;
  • Details about your previous and current remuneration, pensions and benefits arrangements;
  • Information on your interests and needs regarding future employment, both collected directly and inferred, for example from jobs viewed or articles read on our website or from links clicked on in emails from us;
• Automatically collected information
  • IP address;
  • Usage information including the dates, times and frequency with which you access our services;
  • User choices (e.g. marketing preferences);
  • Log and troubleshooting information;
  • Device information when you access or use our services;
  • Website browsing data e.g. pages viewed e.g. Evolve or Clients’ websites;
  • Email engagement history with Evolve;
  • Location information (inferred from jobs, IP address, application history or system stored data);
• Information that others provide about you
  • Extra information that our Clients may tell us about you, or that we find from other third party sources such as job sites (which you have uploaded information onto, or is otherwise made available to us);
  • Information about your interests and needs regarding future employment, both collected directly and inferred, for example from jobs viewed or articles read on our website or from links clicked on in emails from us; and
• Additional information that you choose to tell us
  • Any other information that you may provide to us when corresponding with us via email or otherwise.

Please note that the above list of categories of personal data we collect is not exhaustive.

To the extent that you access our website or click through any links in an email from us, we will also collect certain data from you. If you would like more information about this, please refer to the context-specific section of this Privacy Policy that applies to Website Users.

How do we collect your personal data?

We collect Candidate personal data in the following ways:

• Personal data that you, the Candidate, give to us;
• Personal data that we receive from other sources; and
• Personal data that we collect automatically.

Personal data you give to us

• Evolve needs to know certain information about you in order to provide you with its services. This will enable us, amongst other things, to provide you with the best opportunities, and should save you time in not having to trawl through information about jobs and services that are not relevant to you.
• There are numerous ways you can share your information with us. These may include:
  • Entering your details on the Evolve website or via an application form, as part of the registration process;
  • Emailing your CV or other information to a Evolve consultant or being interviewed by them;
  • Applying for jobs through a job aggregator, which then redirects you to the Evolve website;
  • Entering your personal details into a Evolve microsite; or
• The types of information that receive from you in this way include:
  • Key identification and contact information;
  • Education and employment information;
  • Additional information that you choose to tell us,

as described in the section entitled “What Kind of Personal Information Do We Collect?” above.

Personal data we receive from other sources

• We also receive personal data about Candidates from other sources. Depending on the relevant circumstances and applicable local laws and requirements, this will involve personal data received in the following situations:
  • When we search for Candidates via third party sources, such as LinkedIn and other job sites, from which we obtain your personal information and/or when we carry out other pre-recruitment activities (please refer to the section entitled “Pre-recruitment activities” below);
  • Our Clients, Suppliers, other Candidates and our colleagues within Evolve (e.g. in the context of them making a referral) may share personal information about you with us;
  • If we receive your personal information from Facebook or X, if you ‘like’ our Facebook page or ‘follow’ us on X (or perform a similar interaction with us on any social media platform on which we have a presence)
• The types of information that we receive about you in this way include the information that others provide about you described in the section entitled “What Kind of Personal Information Do We Collect?” above.

Personal data we collect automatically

• To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we will also collect your data automatically (e.g. via website tracking scripts such as cookies or pixels) or through you providing it to us. For more information, please refer to the context-specific section of this Privacy Policy that applies to Website Users.
• The types of information that we collect about you in this way includes the “Automatically collected information” described in the section entitled “What Kind of Personal Information Do We Collect?” above.

How do we use your personal data?

We generally use Candidate data in five ways:

• Pre-recruitment Activities;
• Recruitment Activities;
• Marketing Activities;
• Equal Opportunities Monitoring; and
• To help us to establish, exercise or defend legal claims.
• In appropriate circumstances, we also use Candidate data for Profiling.

Pre-recruitment Activities

• When conducting pre-recruitment activities, we use your data to work out whether you might be interested in, or might benefit from, our services, and to assess whether and how we might be able to assist you. If we think we can help, we will use your contact details to get in touch with you and find out if you are interested in our services, subject to any applicable laws and requirements.
• In order for us to do this, we may:
  • Collect your personal data;
  • Store your details (and update them when necessary) on our database so that we can contact you about our services;
  • Send you an email to inform you about our processing of your personal data and to direct you towards this Privacy Policy;
  • Review your information to work out whether and how our services might help you; and
  • Contact you about our services.
• We've set out in more detail below various ways in which we will use and process your personal data for the purposes of determining whether our services would be beneficial to you. Please note that this list is not exhaustive.
• In most cases, we will use your personal data for the purposes below if we deem it necessary to do so for our legitimate interests. Article 6(1)(f) of the GDPR says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of you which require protection of personal data.”
• We don't think that any of the activities in relation to which we rely on the legitimate interests condition prejudice Candidates in any way. However, you do have the right to object to us processing your personal data on this basis. If you would like to know more about how to do so, please refer to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.

Recruitment Activities

• Our main area of work is recruitment – connecting the right Candidates with the right jobs. We've listed below various ways in which we will use and process your personal data for this purpose. Please note that this list is not exhaustive.
• In most cases, we will use your personal data for the purposes below if we deem it necessary to do so for our legitimate interests. Article 6(1)(f) of the GDPR says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of you which require protection of personal data.”
• We don't think that any of the activities in relation to which we rely on the legitimate interests condition prejudice Candidates in any way – in fact, they help us to offer you a more tailored, efficient service. However, you do have the right to object to us processing your personal data on this basis. If you would like to know more about how to do so, please refer to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.
• We may in certain circumstances process your personal data for the purposes below if it is necessary for us to deliver a contractual service to you (or to fulfil a pre-contract request from you). Article 6(1)(b) of the GDPR says that we can process your data where it “is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.”
• When we process your information for recruitment activities based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on such consent before the consent is withdrawn by referring to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.

Marketing Activities

• We will periodically send you information that we think you may find interesting, or to ask for your help with connecting other Candidates with jobs. In particular, we will use your data for the purposes listed below. Please note that this list is not exhaustive.
• We need your explicit opt-in consent for some aspects of these activities or soft-opt-in (which we explain further below).
• Soft opt-in consent is a specific type of consent which applies where we have obtained your contact details from an occasion when you previously engaged with us (for example by informing one of our consultants that you are interested in our services, submitting a job application or CV, or registering a vacancy to be filled), and we are e-marketing or sending by text message other recruitment-related services of our own. Under ‘soft opt-in’ consent, we will take your consent as given unless or until you object or opt out (and we will remind you of your right to do this and provide you with the opportunity to opt-out, in each e-marketing message that we send to you). For most people, this is beneficial as it allows us to provide you with information that we think will be of interest to you and suggest other jobs to you alongside the specific one you applied for, significantly increasing the likelihood of us finding you a new position. We will use your personal data to send you e-marketing materials with your ‘soft opt-in’ consent if we deem that it is in our legitimate interests to do so.
• For other types of e-marketing, we are required to obtain your explicit consent. If you are not happy about our approach to marketing, you have the right to opt out or withdraw your consent at any time and can find out more about how to do so by referring to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy. Even if you have opted out from our marketing communications, it is possible that your details may be recaptured through public sources in an unconnected marketing campaign. We will try to make sure this doesn't happen, but if it does, we're sorry. We'd just ask that in those circumstances you opt out again.

To help us to establish, exercise or defend legal claims

• Sometimes it will be necessary for us to process personal data in reliance on the legitimate interests legal basis and, where appropriate and in accordance with local laws and requirements, special category data in connection with exercising or defending legal claims. Article 9(2)(f) of the GDPR allows this where the processing “is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity”.
• This will arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.

Profiling, Algorithms and Automated Decision Making

• Profiling is a type of processing activity which enables us better to understand the information that we collect about you, to help us to develop a personalised “profile” for you. This helps us to gain a better idea of how you like to interact with us and our services, the sorts of requests you like to make of us and the sorts of things you don’t like.  The purpose of our building this personalised profile is to enable us to provide the best possible service to you and maximise the chances that we will be able quickly and efficiently to provide you with access to content that is most likely to be relevant and helpful to you.
• We will use profiling methods in relation to your personal data if we consider this is necessary for our legitimate interests as detailed in the table below. If you are not happy about this, in certain circumstances you have the right to object and can find out more about how and when to do this by referring to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.
• We also sometimes use automated systems such as filtering tools or Customer Relationship Management software to help us quickly, efficiently and more accurately to analyse data we have about you and other Candidates, as well as data we hold on our Clients' needs, and this ultimately helps us to make decisions based on this data. This can include applying tools which use algorithms (such as filtering tools or machine learning) to Candidate personal data in order to help us come up with the best possible shortlist for a particular role. Such technology should reduce significantly the amount of time needed to consider when Candidates might be the best fit for relevant jobs. This should in turn make the recruitment process much more efficient and effective, which, we hope, will improve your overall experience with us.
• As new and better technology becomes more prevalent, some of our profiling activities and our processing activities which use automated systems such as those described above, may amount to Automated Decision Making within the meaning of Article 22 of the GDPR. This means a process of making a decision by automated means with limited, or even no, human intervention in reaching the decision. We will only use automated decision making in relation to your personal data where we consider this is necessary for the completion of pre-contractual steps taken at your request.
• Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please click here.

Compliance with a legal obligation

• In some circumstances, we will use your personal data to comply with our legal obligations. Article 6(1)(c) of the GDPR says that we can process your data where it “is necessary for compliance with a legal obligation to which (we) are subject”.
• Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please click here.

Sharing of data

• We will share your personal data with various parties, in various ways and for various reasons. Primarily we will share your information with prospective employers to increase your chances of securing the job you want. Unless you specify otherwise, we will also share your information with any of our group companies and associated third parties such as our service providers and selected job aggregators where we feel this will help us to provide you with the best possible service and maximise your chances of getting what you want.
• If you would like to see a full list of who we will share your personal data with, please refer to the section entitled “Who do we share your personal data with” in the General Privacy Information section of this Privacy Policy.

Clients

This section of the Privacy Policy applies to Clients.

Clients include our customers, clients, and others to whom Evolve provides services in the course of its business or whom Evolve reasonably considers would be interested in our services.

What kind of personal information do we collect?

The information described below is in addition to any personal data we are required by law to process in any given situation.

The data we collect about Clients is actually very limited. We generally only need to have your contact details or the details of individual contacts at your organisation to enable us to ensure that we can reach out to you about our services, ensure our relationship runs smoothly and in certain circumstances, provide services to your employees. We also hold information relating to your online engagement with other material published by Evolve, which we use to ensure that our marketing communications to you are relevant and timely. We may also hold extra information that someone in your organisation has chosen to tell us. In certain circumstances, our calls with you may be recorded or monitored. If we need any additional personal data for any reason, we will let you know.

• Key identification and contact information

About yourself or individual contacts at your organisation, including:

• Names;
• Job titles;
• Telephone numbers;
• Email addresses;
• Automatically collected information
  • Information relating to your online engagement with other material published by Evolve;
  • IP address;
  • Extra Usage information that you choose to tell us; including the dates, times and frequency with which you access our services;
  • User choices (e.g. marketing preferences);
  • Log and troubleshooting information;
  • Device information when access or use our services;
  • Website browsing data e.g. pages viewed (limited to Evolve websites);
  • Email engagement with Evolve;
  • Location information (inferred from jobs, IP address, application history or system stored data);
• Information that others provide about you
  • Extra information that our Candidates may tell us about you, or that we find from other third party sources; and
• Additional information that you choose to tell us
  • Extra information that you or someone in your organisation has chosen to tell us, including when corresponding with us via email or otherwise.

Please note that the above list of categories of personal data we collect is not exhaustive.

To the extent that you access our website or click through any links in an email or text message from us, we will also collect certain data from you. If you would like more information about this, please refer to the Context-Specific section of this Privacy Policy that applies to Website Users.

How do we collect your personal data?

We collect Client personal data in the following ways:

• Personal data that we receive from you;
• Personal data that we collect or receive from other sources; and
• Personal data that we collect automatically.

Personal data that we receive directly from you

• We both share the same goal – to make sure that you have the best staff for and at your organisation. We will receive data directly from you in two ways:
  • Where you contact us proactively, usually by phone or email; and/or
  • Where we contact you, either by phone or email, or through our consultants' business development activities more generally.
• The types of information that we receive from you in this way include:
  • Key identification and contact information; and
  • Additional information that you choose to tell us,

as described in the section entitled “What Kind of Personal Information Do We Collect?” above.

Personal data we receive from other sources

• Where appropriate and in accordance with any local laws and requirements, we will seek more information about you or your colleagues from other sources generally by way of due diligence or other market intelligence:
  • From third party market research and by analysing online and offline media (which we will do ourselves or employ other organisations to do for us);
  • From reputable vendors of business-to-business data lists to the extent we are able to use such data from such sources in compliance with the GDPR;
  • From delegate lists at relevant events; and
  • From other limited sources and third parties, for example, from our Candidates to the extent that they provide us with your details to act as a referee for them or where they give feedback on a particular assignment.
• The types of information that we receive about you in this way may include information that others provide about you as described in the section entitled “What Kind of Personal Information Do We Collect?” above.

Personal data we collect via our website or through links and emails

• To the extent that you access our website or read or click on an email or text message from us, where appropriate and in accordance with any local laws and requirements, we will also collect your data automatically or through you providing it to us. For more information, please refer to the Context-Specific section of this Privacy Policy that applies to Website Users.
• The types of information that we collect about you in this way include the automatically collected information as described in the section entitled “What Kind of Personal Information Do We Collect?” above.

How do we use your personal data?

We use Client information for:

• Providing our services;
• Marketing Activities; and
• To help us to establish, exercise or defend legal claims.

Providing our services

• Our services broadly consist of: (i) providing you with Candidates; (ii) RPO services; (iii) CSO programmes; and (iv) consultancy and advisory services. We've listed below the various ways in which we use your data in order to facilitate this.
• In most cases, we will use your personal data for the purposes below if we deem it necessary to do so for our legitimate interests.
• Article 6(1)(f) of the GDPR says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of you which require protection of personal data.”
• We don't think that any of the activities in relation to which we rely on the legitimate interests condition prejudice Clients in any way. However, you do have the right to object to us processing your personal data on this basis. If you would like to know more about how to do so, please refer to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.

Marketing Activities

• Subject to any applicable local laws and requirements, we will not, as a matter of course, seek your consent when sending marketing materials to a corporate postal or email address.
• If you are not happy about this, you have the right to opt out of receiving marketing materials from us and can find out more about how to do so by referring to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.

Profiling, Algorithms and Automated Decision Making

• Profiling is a type of processing activity which enables us better to understand the information that we collect about you, to help us to develop a personalised “profile” for you. This helps us to gain a better idea of how you like to interact with us and our services, the sorts of requests you like to make of us and the sorts of things you don’t like.  The purpose of our building this personalised profile is to enable us to provide the best possible service to you and maximise the chances that we will be able quickly and efficiently to provide you with access to content that is most likely to be relevant and helpful to you.
• We will use profiling methods in relation to your personal data if we consider this is necessary for our legitimate interests as detailed in the table below. If you are not happy about this, in certain circumstances you have the right to object and can find out more about how and when to do this by referring to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.

Sharing of data

• We will share your data: (i) primarily to ensure that we provide you with a suitable pool of Candidates; (ii) to provide you with a CSO programme; (iii) to provide you with RPO services; to (iv) provide you with consultancy and advisory services and/or (v) to provide services to your employees, such as training courses to teaching staff who work for our Clients in the education sector. Unless you specify otherwise, we will share your information with any of our group companies and associated third parties such as our service providers to help us meet these aims.
• If you would like to see a more detailed list of who we will share your personal data with, please refer to the section entitled “Who do we share your personal data with” in the General Privacy Information section of this Privacy Policy. Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please click here.

To help us to establish, exercise or defend legal claims

• In more unusual circumstances, we will use your personal data in reliance on the legitimate interests legal basis to help us to establish, exercise or defend legal claims.

Website Users

This section of the Privacy Policy applies to Website Users.

What kind of personal information do we collect?

We collect a limited amount of data from our Website Users which we use to help us to improve your experience when using our website and to help us manage the services we provide. This comprises information such as how you use our website, the frequency with which you access it, your browser type, your type of device, the location you view our website from, the language you choose to view it in and the times that our website is most popular. If you contact us via the website, we will collect any information that you provide to us, for example your name and contact details:

• Key identification and contact information
  • Names;
  • Telephone numbers;
  • Email addresses;
• Automatically collected information
  • Information relating to your online engagement with material published by Evolve;
  • IP address;
  • Extra Usage information that you choose to tell us; including the dates, times and frequency with and location from which you access our services;
  • User choices;
  • User reports;
  • Log and troubleshooting information;
  • Device information when you install, access or use our services;
• Additional information that you choose to tell us
  • Any other information that you may provide to us including when corresponding with us via email or otherwise,

Please note that the above list of categories of personal data we collect is not exhaustive.

How do we collect your personal data?

When you visit our website or mobile apps there is certain information that we will automatically collect, whether or not you decide to use our services namely your IP address, the date and the times and frequency with which you access the website, the way you browse its content and other technical information. We will also collect data from you when you contact us via the website.

We collect your data automatically via cookies or similar technology such as tracking pixels and HTML5 Local Storage in line with the cookie settings that you specify via the “Cookie Preferences” link at the bottom of the website, or the settings in your browser. If you are also a Candidate or a Client of Evolve, we will use data from your use of our websites to enhance other aspects of our communications with or service to you. If you would like to find out more about cookies or similar technology, including how we use them and what choices are available to you, please refer to the section entitled “Cookies” in the General Privacy Information section of this Privacy Policy.

The types of information that we collect about you in this way include:

• Key identification and contact information; and
• Automatically collected information,

as described in the section entitled “What Kind of Personal Information Do We Collect?” above.

How do we use your personal data?

We use your data to:

• provide you with the service you registered for or the services you participated in, for example sending you a newsletter or taking part in an online survey;
• protect our Systems from attacks and other illegal activities; and
• to help us to improve your experience of using our website or our mobile apps, for example by analysing your recent job search criteria to help us to present jobs or Candidates to you that we think you'll be interested in.

We will use your personal data for these purposes if we deem this to be necessary for our legitimate interests. If you are not happy about this, you have the right to object and can find out more about how to do so by referring to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.

If you would like to find out more about cookies or similar technology, including how we use them and what choices are available to you, please refer to the section entitled “Cookies” in the General Privacy Information section of this Privacy Policy.

Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please click here.

General Privacy Information

Who do we share your personal data with?

Where appropriate and in accordance with local laws and requirements, we generally share your personal data with the following categories of people:

• Appropriate colleagues within Evolve;
• Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data;
• Service providers  who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, administration functions, technical support functions and IT consultants carrying out testing and development work on our business technology Systems);
• Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
• Marketing technology platforms and suppliers; and
• If Evolve merges with or is acquired by another business or company in the future, (or is in meaningful discussions about such a possibility) we may share your personal data with the (prospective) new owners of the business or company.

There are also certain categories of people that we share your personal data with if you are a Candidate.

Candidates:

If you are a Candidate, we may also share your personal data with the following categories of people:

• potential employers and other recruitment agencies/organisations to increase your chances of finding employment;
• third party partners, job boards, job platforms, job aggregators, software providers and cloud based databases where we consider this will improve the chances of finding you the right job or improving recruitment processes more generally;
• internal and external auditors of our Clients when we are required to share this data with them upon request in order to comply with our contractual or regulatory obligations; and
• third parties helping us by developing services and processes to optimise the Candidate selection process in order to improve the quality and efficiency of recruitment services.

How do we safeguard your personal data?

• We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.
• If you suspect any misuse or loss of or unauthorised access to your personal information please let us know immediately. Details of how to contact us can be found here.

How long do we keep your personal data for?

• In determining the appropriate retention period for different types of personal data, we always consider the amount, nature, and sensitivity of the personal data in question, the potential risk of harm from unauthorised use or disclosure of that personal data, the purposes for which we need to process it and whether we can achieve those purposes by other means (in addition of course to ensuring that we comply with our legal, regulatory and risk-management obligations).
• We set out below the retention practices that we apply to certain categories of people.

Candidates:

• If you are a Candidate, we will keep your personal data on our Systems for a period of up to five years from the point that we collect such personal data or subsequently have meaningful contact with you (or, where appropriate, the company you are working for or with). After this period, it is likely your data will no longer be relevant for the purposes for which it was collected.  We may keep your personal data on our Systems for a longer period than this if we believe in good faith that we need to do so, for example, because of our obligations to tax authorities or in connection with any anticipated litigation.  
• We will consider there to be meaningful contact with you in this context if you, for example, submit a CV to us via our website, take part in any of our online training, communicate with us about potential roles (either by verbal or written communication) or click through from any of our marketing communications. Your receipt, opening or reading of an email or other digital message from us will not count as meaningful contact for these purposes, only where you click-through or reply directly – we will only deem that we have had meaningful contact with you if there is positive action on your part.
• For those Candidates whose services are provided via a third party company or other entity, meaningful contact with you means meaningful contact with the company or entity which supplies your services. Where we are notified by such company or entity that it no longer has that relationship with you, we will retain your data for no longer than two years from that point or, if later, for the period of five years from the point we subsequently have meaningful contact directly with you.
• If you have expressly indicated as a Candidate that you would rather we didn't retain your personal data, then we will Delete it from our Systems unless we believe in good faith that we need to preserve it, for example, because of our obligations to tax authorities or in connection with any anticipated litigation.
• We will invite you to revise the data we hold about you, and remind you that you are signed up for our services, once every five years. We advise that you keep your data with us up-to-date in the interim, to ensure that we’re finding the best and most relevant opportunities for you.

Clients:

• If you are a Client we will retain your personal data in order to provide you with services or to receive services from you, or to provide you with information about our services that we believe you may be interested in.
• If you have expressly indicated that you're not interested in our services, then we will Delete your personal data from our Systems unless we believe in good faith that we need to preserve it, for example, because of our obligations to tax authorities or in connection with any anticipated litigation.

Website Users:

• If you are a Website User we will retain your IP address and any other information that is required to operate the website for up to 365 days.

Other Categories of people:

• We will otherwise retain your data for as long as it is necessary to achieve the purpose it was collected or processed for. If this time has come or you have expressly indicated that you’re not interested in one of our website or mobile app services anymore, we will Delete it from our Systems unless we believe in good faith that we need to preserve it, for example, because of our obligations to tax authorities or in connection with any anticipated litigation. 

How can you access, amend or take back the personal data that you HAVE given to us?

• One of the GDPR's main objectives is to protect and clarify the rights of EU citizens and individuals in the EU with regards to data privacy. This means that you retain various rights in respect of your data, even once you have given it to us. These are described in more detail below.
• To get in touch about these rights, please contact us. We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that we will, where necessary, keep a record of your communications to help us resolve any issues which you raise.
• Right to object: this right enables you to object to us processing your personal data where we do so for one of the following four reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, or statistical purposes.
• The “legitimate interests” and “direct marketing” categories above are the ones most likely to apply to our Website Users, Candidates, Temporary Workers, Clients and Suppliers. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:
  • we can show that we have compelling legitimate grounds for processing which overrides your interests; or
  • we are processing your data for the establishment, exercise or defence of a legal claim.
• If your objection relates to direct marketing, we must act on your objection by ceasing this activity.
• Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, in order to use cookies or pixels in certain jurisdictions), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.
• Data Subject Access Requests (DSAR): You may ask us to confirm what information we hold about you at any time, and request us to modify, update or Delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is “manifestly unfounded or excessive”. If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.
• Right to erasure: You have the right to request that we erase your personal data in certain circumstances. Normally, the information must meet one of the following criteria:
  • the data are no longer necessary for the purpose for which we originally collected and/or processed them;
  • where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
  • the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);
  • it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or
  • if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
• We would only be entitled to refuse to comply with your request for one of the following reasons:
  • to exercise the right of freedom of expression and information;
  • to comply with legal obligations or for the performance of a public interest task or exercise of official authority;
  • for public health reasons in the public interest;
  • for archival, research or statistical purposes; or
  • to exercise or defend a legal claim.
• When complying with a valid request for the erasure of data we will Delete the relevant data.
• Right to restrict processing: You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.
• The circumstances in which you are entitled to request that we restrict the processing of your personal data are:
  • where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
  • where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;
  • where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
  • where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.
• If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.
• Right to rectification: You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
• Right of data portability: If you wish, you have the right to transfer your personal data between data controllers. In effect, this means that you are able to transfer your Evolve account details to another online platform. To allow you to do so, we will provide you with your data in a commonly used machine-readable format that is password-protected so that you can transfer the data to another online platform. Alternatively, we will directly transfer the data for you. This right of data portability applies to: (i) personal data that we process automatically (i.e. without any human intervention); (ii) personal data provided by you; and (iii) personal data that we process based on your consent or in order to fulfil a contract.
• Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority. Details of how to contact them can be found here.
• If you would like to exercise any of these rights, or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), details of how to contact us can be found here. Please note that we will, where necessary, keep a record of your communications to help us resolve any issues which you raise.
• You may ask to unsubscribe from job alerts and other marketing communications from us at any time. Details of how to do so can be found here.
• It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.

How do we store and transfer data internationally?

• So you want to know more about how we store and transfer your data internationally? In order to provide you with the best service and to carry out the purposes described in this Privacy Policy, your data will be transferred:
  • between and within Evolve entities;
  • to third parties (such as advisers or other Suppliers to the Evolve business);
  • to overseas Clients where applicable;                                               
  • to Clients within your country, where applicable, who may, in turn, transfer your data internationally;
  • to a cloud-based storage provider; and
  • to other third parties as set out in the section entitled “Who do we share your personal data with” above.
• We want to make sure that your data are stored and transferred in a way which is secure. We will therefore only transfer data outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:
  • by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by data controllers in the EEA to data controllers and processors in jurisdictions without adequate data protection laws; or
  • transferring your data to a country where there has been a finding of adequacy by the European Commission in respect of that country's levels of data protection via its legislation; or
  • by way of scheme approved by the European Commission (whether as a successor to the Privacy Shield or otherwise) which regulates exchanges of person data between jurisdictions; or
  • where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interests for the purposes of that contract (for example, if we need to transfer data outside the EEA in order to meet our obligations under that contract if you are a Client of ours); or
  • where you have consented to the data transfer.
• To ensure that your personal information receives an adequate level of protection, we have put in place appropriate procedures with the third parties we share your personal data with to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the law on data protection.

How To Contact Us

For the purposes of this document, the body responsible for processing your personal data is Evolve Selection Ltd. If you wish to exercise your rights as outlined above, you can write to us at our registered address: 4 Appleton Court, Calder Park, Wakefield, United Kingdom, WF2 7AR, or alternatively email our Data Protection Officer at aa@evolveselection.com.

If you are unhappy with a decision we have made in relation to your data, you can contact the Information Commissioner’s Office:

• Phone: 0303 123 1113
• Email: casework@ico.org.uk
• Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF