Candidate Privacy Notice

Synopsis

Through this Candidate Privacy Policy we aim to inform you about the types of personal data we collect from candidates, the purposes for which we use the data and the ways in which the data is handled.  We also aim to satisfy the obligation of transparency under the EU General Data Protection Regulation 2016/679 ("GDPR") and national laws implementing GDPR


Objective

Evaluate Topco Limited (company number 10333734) and its group companies, and subsidiaries, including Evaluate Limited (company number 5876322), ("Evaluate", "we", "us" or "our") are committed to protecting the privacy of recruitment candidates. We will ensure that the information you submit to us, or which we collect, via various channels, through written correspondence (including e-mail), or through any of our offices globally is only used for the purposes set out in this policy.  

Through this Candidate Privacy Policy we aim to inform you about the types of personal data we collect from recruitment candidates, the purposes for which we use the data and the ways in which the data is handled.  We also aim to satisfy the obligation of transparency under the EU General Data Protection Regulation 2016/679 ("GDPR") and national laws implementing GDPR.

For the purpose of this Candidate Privacy Policy the controller of personal data is Evaluate, and our contact details are set out in the Contact section at the end of this Candidate Privacy Policy. References in this Candidate Privacy Policy to our Group of companies is to the parent company of Evaluate, and to other subsidiaries of Evaluate.

For the purpose of this Candidate Privacy Policy, ATS refers to an Applicant Tracking System, which is a third-party web-based application.
The Company is registered with the Information Commissioner as a data controller, with registration number Z9730905.

The organisation collects and processes personal data relating to recruitment candidates to manage the employer-candidate relationship. The organisation is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

Scope

All Evaluate Group companies and subsidiaries

Policy

What information does Evaluate collect during the recruitment process?

Evaluate collects and processes a range of information about you during the recruitment process. This includes:

  • your name, address and contact details, including email address and telephone number, 
  • details of your qualifications, skills, experience and employment history, including start and end dates, with previous employers and with the organisation;
  • information about your nationality and entitlement to work in the UK;
  • information about medical or health conditions, including whether or not you have a disability for which Evaluate needs to make reasonable adjustments;
  • equal opportunities monitoring information, including information about your age, ethnic origin, sexual orientation, gender, health and religion or belief. 
  • Photographs if included on CVs or otherwise on supplementary document submitted as part of the recruitment process; and
  • The results of any personality profiling assessment that we may carry out as part of the recruitment process.

The organisation collects this information in a variety of ways. For example, data is collected through application forms, CVs or resumes; from correspondence with you; or through interviews, meetings or other assessments.

Data is stored within the designated ATS platform, and in other IT systems (including the organisation's email system).

Why does Evaluate process personal data?

Evaluate needs to process data to enter into an employer-candidate relationship with you, and to meet its obligations to you in accordance with the Equality Act 2010. 

For example, it needs to process your data to ensure that any laws pertaining to protected characteristics are complied with.

In some cases, Evaluate needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check an employee's entitlement to work in the UK. For certain positions, it is necessary to carry out criminal records checks to ensure that individuals are permitted to undertake the role in question.

In other cases, Evaluate has a legitimate interest in processing personal data before, during and after the end of the employer-candidate relationship. Processing candidate data allows Evaluate to:

  • run recruitment and promotion processes;
  • maintain accurate and up-to-date recruitment records 
  • operate and keep a record of disciplinary and grievance processes, to ensure acceptable conduct within the workplace;
  • ensure effective general HR and business administration;
  • respond to and defend against legal claims; and
  • maintain and promote equality in the workplace

Where Evaluate relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of recruitment candidates has concluded that they are not.

Some special categories of personal data, such as information about health or medical conditions, is processed to carry out employment law obligations (such as those in relation to candidates with disabilities and for health and safety purposes). 

Where Evaluate processes other special categories of personal data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is done for the purposes of equal opportunities monitoring. Data that Evaluate uses for these purposes is anonymised. Candidates are entirely free to decide whether or not to provide such data and there are no consequences of failing to do so.

Who has access to data?

Your information will be shared internally, including with members of the HR and subsequently the recruitment team.

Personal data provided will be accessible to members of the hiring team for any vacancy specifically assigned to them.

Your data may be transferred to countries outside the European Economic Area (EEA) to United States or Japan. Data is transferred outside the EEA on the basis of Privacy Shield (USA), binding corporate rules or other safeguards.

How does Evaluate protect data?

The organisation takes the security of your data seriously. The organisation has internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties. 

Where Evaluate engages third parties to process personal data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

For how long does Evaluate keep data?

Evaluate will hold your personal data for the duration of your candidacy.

Candidate profiles in any archived vacancies will be deleted from the ATS recruitment platform following 12 months from the date of creation. This does not include candidates in active jobs if there has been any correspondence or activity within a 6 month period.

Candidates sourced via recruiter, agencies or via the ATS’s own search feature will be deleted automatically after 30 days, if they have not been notified about our Privacy Notice.

We may ask for your consent to retain your CV within the ATS platform, for future vacancies for which you may be suited. We will delete any profiles and data upon request should your preferences change.

Your rights

As a data subject, you have a number of rights. You can:

  • access and obtain a copy of your data on request;
  • require Evaluate to change incorrect or incomplete data;
  • require Evaluate to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
  • object to the processing of your data where Evaluate is relying on its legitimate interests as the legal ground for processing; and
  • ask Evaluate to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the organisation's legitimate grounds for processing data.

If you would like to exercise any of these rights, please contact Lucy Ralph, Chief HR Officer at recruitment@evaluate.com.

You can make a subject access request by contacting the HR/Recruitment team at recruitment@evaluate.com, and outlining the details of your request.

If you believe that Evaluate has not complied with your data protection rights, you can complain to the Information Commissioner using any of the below contact methods:

Telephone:
0303 123 1111

Website:
https://ico.org.uk/concerns/ 

Post:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire

What if you do not provide personal data?

You have some obligations as a candidate to provide Evaluate with data. In particular, you are required to provide details such as your employment history, qualifications, and suitability for the relevant vacancy.

Certain information, such as contact details and your right to work in the UK have to be provided to enable Evaluate to enter an employer-candidate relationship with you. If you do not provide other information, this will hinder the organisation's ability to administer the rights and obligations arising as a result of the employer-candidate relationship efficiently.

Automated decision-making

Employment decisions are not based solely on automated decision-making.

Further Information on Data Protection and Personal Privacy

If you have any enquiries or if you would like to contact us about our processing of your personal information, including to exercise your rights as outlined above, please contact us centrally by any of the methods below. 

When you contact us, we will ask you to verify your identity. 

Contact name:
Nick Southwell

Telephone:    
+44 207 377 0800

Facsimile:     
+44 207 539 1801

Email:         
Privacy@evaluate.com 

Post:         
Suite 1,
3rd Floor,
11-12 St. James's Square
London
SW1Y 4LB, 
UK