Last updated 26 August 2023
This privacy notice for Evolve: A Social Impact Company (‘Evolve’, ‘we’, ‘us’, or ‘our’), describes how and why we might collect, store, use, and/or share your information when you use our services (‘Services’), such as when you:
- Visit our website at www.evolvesi.com.
- Apply to work with us.
- Become one of our valued employees.
- Subscribe to our newsletter, or sign up for other marketing content.
- Become a client , either directly or indirectly.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by using our table of contents below.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Evolve and the Services, the choices you make, and the products and features you use.
Do we process any sensitive personal information? We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.
Do we receive any information from third parties? We may receive information from public databases, marketing partners, social media platforms, and other outside sources.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.
In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.
How do we keep your information safe? We have organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
How do you exercise your rights? The easiest way to exercise your rights is by emailing us at email@example.com. We will consider and act upon any request in accordance with applicable data protection laws.
If you want to learn more about what Evolve does with any information we collect you can review the privacy notice in full below.
Table Of Contents
- What Information Do We Collect?
- How Do We Process Your Information?
- What Lawful Bases Do We Rely On To Process Your Personal Information?
- When And With Whom Do We Share Your Personal Information?
- How Long Do We Keep Your Information?
- How Do We Keep Your Information Safe?
- Do We Collect Information From Minors?
- What Are Your Privacy Rights?
- Controls For Do-Not-Track Features
- Do We Make Updates To This Notice?
- How Can You Contact Us About This Notice?
1. What Information Do We Collect?In Short: We collect personal information that is either provided to us by you, is automatically collected or shared by other sources.
Personal information provided by youWe collect personal information that you voluntarily provide to us when you engage with our Services, express an interest in obtaining information about us or our products and Services, apply to work for us, or otherwise when you contact us. The personal information that we collect depends on the context of your interactions with us and our Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
- Email addresses
- Job titles
- Employment data
- Qualifications and grades
- Survey responses
Information automatically collectedWe automatically collect certain information when you visit our website such as your Internet Protocol (IP) address and/or browser and device characteristics. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies. The information we collect includes:
- Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’), and hardware settings).
- Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
- Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.
Information shared by other sourcesWe collect data from our school and education clients along with public databases and marketing partners.
- School and education clients. As part of our Service to schools and other educational providers, we analyse survey responses from students and teachers within our evaluation tool called the Wellbeing Compass. This platform also collects the following student data from school management information systems:
- assessment records
- attendance records
- behaviour records
- employee records
- exclusion records
- student records
Student records include the following Special Category Data that is sensitive information and processed under a different legal basis:
- data concerning health
- personal data revealing racial or ethnic origin
- Public databases and marketing partners. In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, data providers, and from other third parties.
This information includes:
- Mailing addresses
- Job titles
- Email addresses
- Phone numbers
- Intent data (or user behaviour data)
- Internet Protocol (IP) addresses
- Social media profiles
- Social media URLs
- Custom profiles (for targeted advertising and event promotion)
2. How Do We Process Your Information?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, and to comply with law. We may also process your information for other purposes with your consent.
We process personal information for a variety of reasons, depending on how you interact with our Services:
- To facilitate the delivery of our obligations as an employer to job seekers. We may process your information to provide you with employment services, including but not limited to application review, interview selection, credential vetting and reference checking.
- To facilitate the delivery of our obligations as an employer to our employees. We may process your information to provide you with employment services, including but not limited to payroll, performance management and annual leave entitlement.
- To facilitate the delivery of our Services to Clients. We may process your information to provide you with our Service. This includes analysis of agreed performance data, including Wellbeing Compass survey responses.
- To facilitate account creation, authentication and management of user accounts. We may process your information so you can create and log in to your Wellbeing Compass account.
- We process Special Category Data (health and ethnicity) to deliver and facilitate delivery of our Services to children and young people. This information includes the status of pupils relating to: education healthcare plans, special educational needs and disabilities, pupil premium and school performance.
- To inform the design and delivery of our Services. We may process this information to help ensure fair access to education services provided by ourselves and our Clients.
- To facilitate delivery of services to marketing contacts. We may process your information to provide you with requested information related to our Services. This includes newsletter subscriptions and processing requests for further information about our Services.
3. What Lawful Bases Do We Rely On To Process Your Information?
In Short: We only process your personal information when we believe it is necessary and we have a lawful basis to do so under UK GDPR Law.
The General Data Protection Regulation (GDPR) and UK GDPR Law require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
- Performance of a contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you.
- Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent here at the bottom of the page.
- Reasons of substantial public interest. We may process the special category data outlined above under this condition for processing from Article 9 of the UK GDPR. In particular, the substantial public interest conditions set out in paragraphs 6 to 28 of Schedule 1 of the DPA 2018 are as follows:
- (8) Equality of opportunity or treatment
- (16) Support for individuals with a particular disability or medical condition
- (18) Safeguarding of children and individuals at risk
In legal terms, we are generally the ‘data controller’ of the personal information provided by you and information automatically collected as described in this Privacy Notice. This is because we determine the means and/or purposes of the data processing that we perform.
This Privacy Notice does not apply to the personal information shared by other sources. In these situations, we are a ‘data processor’ on behalf of our clients that we provide services to and with whom we have entered into a data processing agreement with. It is the ‘data controller’ who is responsible for your personal information.
If you want to know more about our clients’ privacy practices, you should read their privacy policies and direct any questions you have to them.
4. When And With Whom Do We Share Your Personal Information?In Short: We may share information in specific situations described in this section with associated third parties.
We may share your data with Research Partners, Consultants, and Other Third-Party Service Providers (‘third parties’) who perform services for us and/or on our behalf. They require access to specific information to do this work.
We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do so. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period they are under our instruction. The third parties that we may share personal information with are as follows:
- Research Partners – University College London and Simetrica Jacobs
- Software Development Partners – 48k
- Advertising, Direct Marketing, and Lead Generation – HubSpot CRM
- Cloud Computing Services – Google Workspace
- Data Backup and Security – Amazon Web Services (AWS)
- Web and Mobile Analytics – Google Analytics
6. How Long Do We Keep Your Information?
In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (for example, tax and accounting). No purpose in this notice will require us to keep your personal information for longer than twelve (12) months past the termination of the Service or user account.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
7. How Do We Keep Your Information Safe?In Short: We aim to protect your personal information through a system of organisational and technical security measures.
We have implemented a variety of appropriate and reasonable technical and organisational security measures to protect personal data and information that we process. This involves a combination of policies, procedures, and technical controls, including the use of encrypted software.
Here are several steps that we take as part of this process to reduce the risk of data breaches and ensure the security and privacy of personal information:
- Conduct risk assessments to help identify the potential risks to personal data and information. This helps us to determine what security measures are necessary and what level of protection is required.
- Develop and review security policies that outline our approach to protecting personal data and information. It includes policies and procedures for data access, storage, and transmission. It also outlines employee responsibilities and the consequences of non-compliance.
- Implement access controls so that access to personal data and information is restricted to authorised individuals only. This includes passwords, encryption, multi-factor authentication, and role-based access controls.
- Data is stored in secure locations, whether these are physical or digital. For physical storage, access is limited and secure. For digital storage, data is encrypted and protected with firewalls and anti-virus software.
- Employees are trained on security policies and procedures. This includes regular security awareness training within our CPD schedule to ensure that employees are aware of the risks and how to protect personal data and information.
- We perform regular security audits to identify vulnerabilities and ensure that security measures are effective. This includes testing of the security controls, scanning for vulnerabilities, and monitoring for unauthorised access.
- We created an incident response plan to outline the steps that will be taken in the event of a security breach. This includes identifying the breach, containing the breach, and notifying affected individuals.
However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Service is at your own risk. Therefore, you should only access our Service within a secure environment.
8. Do We Collect Information From Minors?
In Short: We collect survey responses from children under 18 years of age as part of our contracts with Clients. We do not knowingly collect data from or market to children under 18 years of age.
We process the student information outlined above that is shared with us by Clients to enable us to deliver our Services and fulfil our contractual obligations. We also collect survey responses from students as part of our Services and to monitor their effectiveness.
We do not knowingly solicit data from or market to children under 18 years of age. By using our Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records.
If you become aware of any data we may have collected from children under age 18, please contact us at firstname.lastname@example.org.
9. What Are Your Privacy Rights?
In Short: You may review, change, or ask us to delete your personal information at any time.
You have certain rights under UK GDPR laws, including:
- Your right of access. You have the right to ask us for copies of your personal information.
- Your right to rectification. You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure. You have the right to ask us to erase your personal information in certain circumstances.
- Your right to restriction of processing. You have the right to ask us to restrict the processing of your personal information in certain circumstances.
- Your right to object to processing. You have the right to object to the processing of your personal information in certain circumstances.
- Your right to data portability. You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You have the right to request access to the personal information that we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please contact us using email@example.com and we will act upon your request in accordance with applicable data protection laws. If you make a request, we will respond to you within one month, as required.
If you have any concerns about our use of your personal information, please let us know by emailing us using firstname.lastname@example.org. If you are unhappy with how we have used your data, you can also complain to the Information Commissioner’s Office:
Information Commissioner’s Office
Wycliffe House, Water Lane
SK9 5AF, United Kingdom
Helpline number: 0303 123 1113
ICO website: www.ico.org.uk
Withdrawing your consent. If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the “How Can You Contact Us About This Notice” section below.
However, please note that this will not affect the lawfulness of any processing before its withdrawal, nor will it affect the processing of your personal information that is conducted upon any legal bases other than consent.
Opting out of marketing and promotional communications. You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the “How Can You Contact Us About This Notice” section below. You will then be removed from the marketing lists.
However, we may still communicate with you if this is necessary for the delivery of our Services, administration and use of your online account, to respond to service requests as part of our contractual obligations to you, or for other non-marketing purposes.
Cookies and similar technologies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove and reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. You may also opt out of interest-based advertising by advertisers on our Services.
10. Controls For Do-Not-Track Features
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (DNT) feature or setting that you can activate to change your privacy preference to not have data about your online browsing activities monitored and collected.
No uniform technology standard for recognising and implementing DNT signals has been introduced. Therefore, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If such a standard for online tracking is adopted, we will inform you about the practice that we will follow in a revised version of this privacy notice.
11. Do We Make Updates To This Notice?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The revision date will appear at the top of the document next to “Last updated on” and the updated version will be effective as soon as it is accessible.
We may notify you by sending a notification if we make material changes to this privacy notice. We encourage you to review these updates so that you stay informed with how we are protecting your information.
12. How Can You Contact Us About This Notice?
If you have any other questions or comments about your privacy rights that are not covered within this privacy notice, please contact us using the following details:
Phone: 0845 519 8446
Evolve: A Social Impact Company
Central Hall, Alice Street
Keighley, West Yorkshire
BD21 3JD, UK