- Our website www.evolution-law.com is owned and operated by Evolution Law Limited, whose registered office is 27 Old Gloucester Street, London WC1N 3AX.
- The term “Evolution Law” refers to Evolution Law Limited.
- The term “you” refers to the user of our Services and/or our website.
Evolution Law (“we”, “us”, or “our”) is a legal services consultancy which provides work-finding services and related coaching and training services and products to its clients and work-seekers (the “Services”). We must process personal data (including sensitive personal data) so that we can provide the Services – in doing so, we act as a data controller.
2. Collection and use of personal data
a. Purpose of processing and legal basis
We will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with our Services. This includes, for example, contacting you about job opportunities, assessing your suitability for those opportunities, updating our databases, putting you forward for job opportunities, giving you advice on your CV, helping you prepare for interview, responding to your queries, arranging payments to you and developing and managing our Services and relationship with you and our clients. We may also contact you in relation to training, coaching or strategy sessions, our digital products or membership or to advise you of upcoming seminars or webinars.
If you have opted-in, we may also send you marketing information and news via email/text. You can opt-out from receiving these at any time by clicking “unsubscribe” when you receive these communications from us.
In some cases, we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.
We must have a legal basis to process your personal data. The legal bases we rely upon to offer our Services to you are:
- Where we have a legitimate interest
- To fulfil a contractual obligation that we have with you
- To comply with a legal obligation that we have
- Your consent
b. Legitimate interest
This is where we have a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where we have relied on a legitimate interest to process your personal data, our legitimate interests are as follows:
- Managing our database and keeping work-seeker records up to date
- Providing our Services to you, our candidates and our clients
- Contacting you to advise you of upcoming seminars, webinars or training events related to the work-finding process or the industries to which we supply
- Organising and conducting training or coaching sessions with you, our candidates or our clients
- Contacting you to seek your consent where we need it e.g. in relation to sensitive personal data
- Managing temporary work assignments for you, our candidates and our clients
- Arranging payments to you and running payroll, where required
- Giving you information about similar or related products or services that you have used from us recently
- Developing and managing our Services and relationship with you, our candidates and our clients
c. Statutory/contractual requirement
We have certain legal and contractual requirements to collect personal data (e.g. to comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003, immigration and tax legislation, and in some circumstances safeguarding requirements). For example, we are legally required to check your identity, your right to work, your suitability for the role and your qualifications and experience. Our clients may also require this personal data, and/or we may need your data to enter into a contract with you. If you do not give us the personal data we need to collect, we may not be able to continue to provide our Services to you.
d. Recipient(s) of data
We will share your personal data and/or sensitive personal data with any of the following recipients:
- Clients (to whom we may introduce or supply you)
- Former employers (from whom we may seek references)
- Prospective new employers (to whom we may provide references)
- Academic institutions (from whom we may seek academic references or confirmation of academic results)
- Payroll service providers (who advise us or manage payroll on our behalf)
- CRM software providers (who host our database of candidates, clients and contacts)
We also may share your personal data and/or sensitive personal data with any of the following recipients:
- Other payment intermediaries to whom we may introduce you e.g. umbrella companies
- Other recruitment agencies in the supply chain
- Our insurers, legal advisers, accountants, bookkeepers and third parties who carry out audits to ensure that we run our business correctly
- Our website and CRM providers
- Providers of software, technology and IT tools
- Data processing or analysis service providers
- Finance, marketing or customer service providers
- Social networks e.g. where you join our Facebook or LinkedIn pages or groups
- Public information sources or third-party organisations which we may use to carry out suitability checks on work-seekers e.g. Companies House, the Disclosure and Barring Service (DBS) or credit reference agencies
- Government, law enforcement agencies and other Regulators e.g. the police, Home Office, HMRC, FCA, SRA, Law Society, Employment Agencies Standards Inspectorate (EASI)
- Any other organisations with which you may ask us to share your data
From time to time, we also may share anonymised information and/or statistics based on your personal data/sensitive personal data with our clients and third parties, including for marketing purposes. We may also use any feedback which you provide to us about our Services for marketing or promotional purposes, by including it in marketing materials sent to clients and third parties and/or displaying it on our website.
We do not sell your data to third parties.
3. Information to be provided when data collected is not from the data subject
Generally, we will collect your personal data/sensitive personal data from you directly as set out in section 1 above. Sometimes, however we may collect your personal data/sensitive personal data from other sources. These sources may include:
- Job boards or LinkedIn
- A former employer
- A referee whose details you previously provided to us
- Software providers who we use to support our Services
- The cookies listed in section 7
- A third party who refers you to us
- A public source (e.g. a company website)
The personal data which we collect about you from these sources, may include the following categories of data:
- Name, address, telephone and/or mobile telephone number, email address, LinkedIn profile page
- National insurance no.
- Academic and career history
- Work experience and information generally found on a CV (e.g. IT skills, language abilities, memberships)
Sensitive personal data:
- Health information (including whether you have a disability)
- Criminal conviction(s)
This information may, or may not, come from a publicly accessible source.
4. Overseas Transfers
We may transfer the information you provide to us to countries outside the European Economic Area (“EEA”), including to the United States, for the purposes of providing you with our Services. We will take reasonable steps to ensure that adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.
Currently, we use the services of third party companies who may process your data on servers located outside the EEA, including in the United States. These include:
|Service Provider||Function||Location||Service Provider’s Privacy Information|
|Stripe||Payment processing platform||Global (incl. US)
Note: Payment data may be transferred, processed and stored outside of the UK (including in the US) and may be subject to the disclosure requirements of applicable laws outside of the UK.
|Xero||Accounting software||Countries outside of the EEA, including the US||https://www.xero.com/uk/legal/privacy/
|Zoom||Video communication software||Global (incl. US)||Privacy | Zoom
5. Data retention
We will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time. For example, the Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with our Services.
We must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation. This is currently 3 to 6 years.
Where we have obtained your consent to process your sensitive personal data, we will do so in line with our retention policy. Upon expiry of that period we will seek further consent from you. Where consent is not granted we will cease to process your sensitive personal data.
6. Your rights
Please be aware that you have the following data protection rights:
- The right to be informed about the personal data which we process on you;
- The right of access to the personal data which we process on you;
- The right to rectification of your personal data;
- The right to erasure of your personal data, in certain circumstances;
- The right to restrict processing of your personal data;
- The right to data portability, in certain circumstances;
- The right to object to the processing of your personal data that was based on a public or legitimate interest;
- The right not to be subjected to automated decision making and profiling; and
- The right to withdraw consent at any time.
Where you have consented to us processing your sensitive personal data, you have the right to withdraw that consent at any time by contacting:
Tel: 07967 506 257
Note, that if you withdraw your consent to further processing that does not affect any processing done prior to the withdrawal of that consent, or which is done according to another legal basis.
There may be circumstances where we will still need to process your data for legal or official reasons. Where this is the case, we will tell you and we will restrict the data to only what is necessary for those specific reasons.
If you believe that any of your data that we process is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary.
You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.
8. Log Files
We use IP addresses to analyse trends, administer the site, track users’ movements, and to gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.
9. Links to external websites
Our website may contain links to other external websites. Be aware that we are not responsible for the privacy practices of such other sites. When you leave our site, we encourage you to read the privacy statements of each and every website that collects personally identifiable information.
10. Sale of business
If our business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.
11. Data Security
We take every precaution to protect our users’ information.
Any information you provide to us via our registration form or email is stored either on our Microsoft secure servers or the secure servers of our CRM providers. Your information may also be stored locally in the United Kingdom and may be accessible by any of our consultants or team members in the United Kingdom. Access is password protected. Only those individuals who need the information to perform a specific job for us (e.g. our consultants, accounts or payroll team or a marketing or administrative assistant) are granted access to your information.
We have website security provided by SUCURI. In addition, our website has an SSL certificate. This means that all information which passes through our website or is inputted (e.g. via our contact form) is encrypted.
We use all reasonable efforts to safeguard your personal information. However, you should be aware that the use of email and the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email or the internet.
If you share a device with others we recommend that you do not select the “remember my details” function when that option is offered.
If you have any questions about the security at our website, you can email Geraldine Gobbi at firstname.lastname@example.org.
13. Complaints or queries
Tel: 07967 506 257
You also have the right to raise concerns with the Information Commissioner’s Office on 0303 123 1113 or at https://ico.org.uk/concerns/, or any other relevant supervisory authority should your personal data be processed outside of the UK, if you believe that your data protection rights have not been respected.