This Privacy Notice sets out the basis on which Evolution Recruitment Solutions Limited will process personal information provided to us, this information is also referred to as ‘personal data’. This privacy notice shall also apply to Real Time Recruitment Solutions (RTRS) and all references to “we”, “us”, “our” and “ours” shall include both Evolution Recruitment Solutions Ltd and RTRS.
This notice is to inform you of how we will use your personal information, which is primarily for recruitment purposes, and your rights in relation to that information. We take our obligations in respect of the privacy of personal data very seriously and we will only process personal information as detailed in this notice, unless we inform you otherwise. In order to ensure that the personal data we hold is accurate and up to date, we request that you inform us of any relevant changes to the personal information we hold about you.
This notice applies to job applicants and candidates who we approach regarding roles, who are or have been engaged or involved in the recruitment and selection process. It does not form part of any contract we have with you and we may amend it at any time.
Our Data Protection Officer is Jeni Howard, who can be contacted at email@example.com
Section 1: Personal Data
The personal data we collect and process includes the following
- Personal details e.g. your name, address, date of birth, gender and contact details etc.
- Information about your skills and experience e.g. educational and training records, CV, application for employment, previous work
- Information relating to your suitability for employment e.g. references, pre-employment checks, interview notes.
We may obtain your personal data from the following sources (please note that this list is not exhaustive):
- You via
- the application process (e.g. a CV, application or registration form) or
- Third parties including
- Online jobsites
- Recruitment companies
- Other staff including management
- Our clients, customers or suppliers
- Information may also be obtained from sources in the public domain including social media
Section 2: How we will use your personal data:
We process your personal information for recruitment purposes. The purposes of processing of your personal information may include:
- Collecting and storing your personal data, whether in manual or electronic files
- Assessing and reviewing your suitability for job roles whether initially or for the purpose of alternative roles or promotion
- Checking your experience, qualifications and/or eligibility to work in the UK, or any other jurisdiction in which you are or have worked for us
- Managing the selection process i.e. arranging interviews etc.
- Retaining records of the relationship
- Equal opportunities monitoring
Section 3: Why we process your personal data:
1. Entering into and performing a contract with you:
Where we are considering entering into a contract with you, we will be required to process certain information for the proper performance of that contract. We will for example require your personal details (name, address etc.) details of the role that you will undertake, remuneration and benefits in order to enter into the arrangement.
A contract will also contain obligations on both your part and our part and we shall process your data as is necessary for the purpose of those obligations. A separate Privacy Notice will be issued in the event that we enter into a contract with you.
2. Our legitimate interests:
We will also need to process certain categories of personal information in furtherance of our legitimate interests. These include
- Using your personal data for the purpose of:
- Identifying candidates for roles we have
- Completing the recruitment and selection process for those roles -
- Monitoring quality and compliance both generally and in respect of particular individuals
- Evaluating quality and compliance including compliance with this Privacy Notice
- Monitoring performance and conduct within our organisation
- Planning, review and development of company processes, objectives and strategies
- Detection and prevention of theft, fraud and other criminal activity
- Establishing company performance or value including collating information and/or reporting relating to the actual or potential acquisition or transfer or all or part of our business.
This means that for our commercial viability and to pursue these legitimate interests, we may continue to process your personal data for as long as we consider necessary for these purposes.
3. Consent to our processing of your data:
In certain circumstances we may rely upon your consent to process information for a specific purpose, for example, where you apply for a role. In some cases this consent may be quite clear from your actions. However, in other cases you may have provided your written or verbal consent to the use of your data for a specific reason.
You may withdraw your consent to our processing of your personal information for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations. Withdrawal of consent will not have any effect on the lawfulness of any processing based on consent before its withdrawal.
For the avoidance of doubt information that we process because of our contract, a legal obligation, or our legitimate interest does not require your consent.
4. Sensitive Personal Data (SPD)
Sensitive personal data, is information which is intensely personal to you, examples of SPD include information which reveals your political, religious or philosophical beliefs, your sexual orientation, or race or ethnic origin, or which may require processing of information relating to your health.
Regardless of the basis for your dealings with us, we request that you do not provide us with any sensitive personal data unless necessary, or specifically required by us. However, to the extent that you do provide us with any sensitive personal data, such as data which you choose to share with us in conversation, we shall only use that data for the purposes of our relationship with you. This will be for one or more of the following reasons:
- You have explicitly consented to the processing
- For the purpose of our assessment of your suitability for job roles or working capacity
- Where processing is necessary for the purpose of obligations or rights under employment, social security or social protection law, e.g. Health and safety, equalities legislation or to administer statutory payments such as statutory sick pay
Section 4: Who we share personal data, automated decision making & retention of records:
1. Sharing your personal data
We shall not share your personal information unless we are entitled to do so. The categories of persons with whom we may share your personal information include
- Parties who process data on our behalf, which may include
- Outsourced payroll and accountancy providers
- Storage service providers including cloud - background screening providers
- Legal and professional advisers
- Potential or actual purchasers or transferees relating to the whole or any part of our business
2. Automated decisions
We will not use your personal information in automated decision making processes, including profiling.
3. Retaining your data
In most circumstances your data will be retained for as long as we believe you may be suitable for a position with us or until you become an employee and an employee Privacy Notice is issued. It is our policy to only store your personal data for as long as is reasonably necessary for us to comply with our legal obligations and for our legitimate business interests. However, we may retain data for longer than a 6 year period where we have a legal or contractual obligation to do so, or we form the view that there is otherwise a continued basis to do so.
If, however you believe that we should delete your personal data at an earlier date, please inform us in writing of your reasons. Please see Section 6: Your Rights below.
Section 5: Other matters:
1. Transfer of data to jurisdictions outside of the EEA
In the course of the provision of our services, or in order that functions of our business may be performed we may transfer data to countries or international organisations outside of the EEA.
Where information is to be so transferred, it may be to a country in respect of which there is an adequacy decision from the EU Commission. However, if this is not the case, it is our policy to take steps to identify risks and in so far as is reasonably practicable, ensure that appropriate safeguards are in place. Details relating to appropriate safeguards that are in place in relation to transfer of personal data to specific countries or organisations are available on request from our DPO.
2. If you do not wish to provide us with necessary data
There may be circumstances where we require you to provide data which is necessary in order for us to meet statutory or contractual obligations, or to facilitate the entering into a contract with you.
If you do not wish to provide us with information we request then you may notify us of the same. However, please be aware that as a result we may be unable to engage you.
3. Group companies & transfer
Although this Privacy Notice applies to us your data may be accessible to, and shared with other organisations within our group including Evolution Recruitment Solutions PTE Ltd, Evolution Recruitment Solutions PTY Ltd, Evolution Personalvermittlungsgesellschaft mbH for any of the purposes set out within this Privacy Notice, or where we have shared administration systems and staff.
In the event of a sale, merger, liquidation, receivership or the transfer of all or part of our assets to a third party, we may need to transfer your information to a third party. Any transfer will be subject to the agreement of the third party to our data protection requirements.
4. Data Security and Confidentiality
It is our policy to ensure, in so far as is reasonably practicable, that our systems and records are secure and not accessible to unauthorised third parties in line with contemporary practice.
5. Changes to this Privacy Notice
This Privacy Notice is regularly reviewed and may be updated from time to time to reflect changes in our business, or legal or commercial practice. Where an update is relevant to our processing of your data, we shall notify you of the same.
Section 6: Your rights:
We take the protection of your personal data very seriously and it is important that you know your rights within that context, which include rights to:
- Request a copy of the personal data that we hold
- Object to our processing of your data where that processing is based upon legitimate interest and there are no compelling grounds for the continued processing of that data
- Request that we restrict processing of your data in certain circumstances
- Request that data is erased where the continued use of that data cannot be justified
- Object to any decision, which significantly affects you, being taken solely by a computer or via another automated process
- Withdraw your consent to our processing of your personal data for a particular purpose at any stage. However, please note that we may continue to retain, or otherwise use your personal information thereafter where we have a legitimate interest or a legal or contractual obligation to do so. Our processing in that respect will be limited to what is necessary in furtherance of those interests or obligations
- Request that inaccurate or incomplete data is rectified
- Request that data provided directly by you and processed by automated means is transferred to you or another controller; this right only being applicable where our processing of your data is based either on your consent or in performance of a contract
- Make a complaint to the Information Commissioner’s Office
Please note that should you exercise your right to request that we erase data or cease any processing activity, we may retain a record of this request and the action taken in order to both evidence our compliance, and to take steps to minimise the prospect of any data being processed in the future.
If you have any questions concerning your rights or should you wish to exercise any of these rights please contact our DPO.
If you are dissatisfied about any aspect of the way in which your data is processed you may, in the first instance refer the matter to our DPO. This does not affect your right to make a complaint to the Information Commissioner’s Office.