Privacy Shield HR Privacy Policy

EvaluatePharma USA, Inc Human Resources Privacy Statement

Edited: August 19, 2019

Your privacy is important to us and the Evaluate Group, including EvaluatePharma USA, Inc. (collectively “Evaluate”), is committed to protecting and respecting your privacy.

Evaluate is an international business with offices in the U.S. Our management and business processes cross borders which results in client and employee data being transferred across borders.

We may handle Personal Identifiable Information (“PII”) collected from individuals located within the European Union (“EU”) member countries, so we have therefore committed to comply with the Privacy Shield Principles as set forth by the U.S. Department of Commerce and European Commission regarding the collection, use and retention of PII from EU member countries.

EvaluatePharma USA, Inc., our U.S. office, has certified that it adheres to the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, recourse, enforcement and liability. We are subject to the investigatory and enforcement powers of the Federal Trade Commission. To learn more about the Privacy Shield Principles, and to view our certification, please visit

Collection and Use

Evaluate collects your PII when you apply to work at the Evaluate either by voluntary submission to the Company, by voluntary submission to third-party job posting sites or through recruiters. Evaluate collects additional PII when you start employment with Evaluate.

For the purposes of this Human Resources Privacy Policy, PII includes your name, email, phone number, social security number, work permit number (if applicable), Right to Work (if applicable), USCIS visa number (if applicable), address and bank account information.

Evaluate collects employee information from prospective employees to process and track incoming job applications.

We collect employee information from present employees for legitimate business purposes related to employment such as verification of employment, payroll, expense reimbursement and travel.

In compliance with the Privacy Shield Principles, Evaluate commits to resolve complaints about our collection or use of your personal information.  EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Evaluate at:

Kayla Pomponi
[email protected]

Evaluate has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of the employment relationship.

Your Choice

Any employee who provides PII to us shall be notified in detail how their PII will be used at the time of collection.

Evaluate will obtain affirmative consent from an employee before using such employee’s PII for any purpose other than described above. Employees may decline to provide this consent, and employees may withdraw their consent at any time.

Onward Transfer

Evaluate does not sell, trade or rent your PII to others. We will not disclose your PII unless we are under a duty to disclose or share your PII in order to comply with any legal obligation, including cooperation with an investigation carried out by anybody investigating criminal or fraudulent behavior.

Evaluate, as a "controller", may transfer personal data to third party partners, such as mainstream business systems providers for processing, storing and management purposes. All the "controller" to "processor" data transfers are ruled by Data Processing Agreements signed between Evaluate (controller) and each of its business partners (processor). It is Evaluate's liability to ensure that the data is processed by its business partners in compliance with the data protection legislations, and to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.      


Evaluate uses reasonable administrative, technical and operational security measures to safeguard PII in its possession against loss, theft and unauthorized use, disclosure or modification.


Upon written request, an employee may inspect his or her own personnel file during regular business hours.  If you wish to access, correct or delete your PII, please notify [email protected] or call us at +1-617 573-9450and ask for Kayla Pomponi. We will respond to your request within 30 days.

Remedies and Compliance

If you believe we are not in compliance with our Privacy Policy, or if you have any questions concerning this Privacy Policy or your PII, we encourage you to contact [email protected] or call us at +1-617 573-9450 and ask for Kayla Pomponi. We will investigate your complaint, take appropriate action and report back to you within 45 days.

If your information has been transferred from the EU to the U.S. and you believe that Evaluate has not adequately resolved any such issues, you may contact the Information Commissioner’s Office (“ICO”), the national data protection authority that Evaluate has agreed to cooperate with in regards to complaints related to PII. For more information visit or to submit a complaint visit If any request remains unresolved, you may have a right, under certain conditions, to invoke binding arbitration under Privacy Shield; for additional information, see


We reserve the right to amend this Privacy Policy at any time. Any changes made will be notified to you by email.