WE AT EVOLVE TAKE THE ISSUE OF PRIVACY EXTREMELY SERIOUSLY.
We at (EVOLVE) Evolve Coaching and Consulting Limited, along with our subsidiaries and affiliates (collectively, ‘EVOLVE’), are committed to protecting Personal Information. We provide a safe and secure service for all individuals who are referred to us by client organisations. We ensure that the information submitted to us is used accurately and only for the purposes set out in this policy. This Fair Processing Notice (the ‘Notice’) describes our data collection practices, use, and transfer of information collected by EVOLVE. The information you provide us with can be submitted to us in person, via email or via an on-line service.
PERSONAL INFORMATION WE COLLECT
EVOLVE collects information that identifies you as an individual (“Personal Information”) to provide services to our clients and to operate our business. The type of Personal Information we collect about you depends on the service offering being delivered.
- During our services, we may collect Personal Information such as your: name, e-mail address, telephone number, location, first language, CV / Resume aspects (e.g. job title, work history, education) and references.
- For certain services a client may request demographic information to be included within the project reporting element in relation to our offering. We, in turn, may request this information from yourself. For instance, for services relating to diversity and inclusion agendas we may include demographic questions on: gender, race, age or ethnicity.
- If necessary, we will ask for information regarding your physical health for accessibility purposes.
- We do not require any other sensitive information from you, unless asked for in these limited situations. For instance, we will not ask for sensitive information relating to political opinions, as part of normal practise.
Please do not provide us with any Personal Information if you do not agree with this Policy.
HOW WE COLLECT PERSONAL INFORMATION
As you interact with EVOLVE, you provide some Personal Information directly.
We may collect Personal Information when you register to use our Online Platform, submit your CV, complete online surveys, psychometrics or 360s.
If you submit Personal Information about other people to us, you represent that you have the authority to do so and permit us to use the information in accordance with this Policy.
Personal Information about you may also come from our clients to whom we provide Services. These clients may be your employer or an organisation with which you are seeking employment.
HOW WE USE THE INFORMATION WE COLLECT
EVOLVE uses the Personal Information collected to support the delivery of our Services. This information is held, used and disclosed by us as follows:
- Fulfilling client requests: to help EVOLVE to fulfil our contractual obligations with a client, where you may be a current or prospective employee of that client.
- Fulfilling your Requests: to answer any questions you may have about EVOLVE, our processes or for any other request you may have.
- Analytics: we may retain and use Personal Information about you for benchmarking, creating norms, including validation studies, to improve and enhance our services or to develop new Services in the field of leadership development. The end product will be aggregated and anonymised and therefore is no longer considered Personal Information due to the fact that you cannot identify any individual. The norms we develop across particular industries, geography or levels, when compared with your own Personal Information, generate insights and form a significant part of the assessment offering for our clients.
- Third Party Sub-processors: EVOLVE use third parties, who comply with similar undertakings of privacy and confidentiality as EVOLVE, as they perform outsourced operational functions on our behalf and who also provide services to us. These organisations include:
- Technology operations companies who run EVOLVE’s IT or support EVOLVE’s systems.
- Supplier of our communication distribution platform.
- Associate Leadership Consultants.
- Psychometric Assessment Suppliers
- Operating our Business: your name and date of the delivery of a service to a client may be included in such matters as client audits, internal communication, administering our services, procurement and financial transactions.
- Law: we may also release Personal Information to regulatory or law enforcement agencies, if they require us to do so. We will also disclose subject information where we are permitted and requested to do so by law.
- Marketing: we may use your Personal Information to send you information or marketing materials. Please note that if we obtained your Personal Information in the course of a consulting engagement with our client, you will not receive marketing materials as a result of the Personal Information we obtained from those Services.
If we wish to use your information for any of the reasons not listed above, we will seek your explicit consent to collect, hold, use and disclose your Personal Information.
HOW EVOLVE WORKS WITH YOU
As defined under GDPR, EVOLVE is a data controller. As we determine the purposes and means of processing Personal Information, this classifies us as a data controller. This relates to the way in which we work with our clients and with you.
Where a client has requested that EVOLVE provide a leadership consulting service to them which relates to you, this service will always be commissioned by our client with your knowledge and agreement. This service may be in relation to assessment (for recruitment or development), coaching, workshops, psychometrics or other leadership consulting services.
At the beginning of EVOLVE’s engagement, we will ask for basic information like contact details. During an assessment process you will be asked, verbally, to share personal and career history with your assigned EVOLVE consultant. We will also ask you to complete psychometric profiling tests.
Your EVOLVE assessment report will make recommendations to our client about your potential and/or development profile. Your psychometric profiling data will form part of an overall assessment by the consultant. This assessment report is developed individually by the consultant and is not automated.
Whenever your record appears in an analysis from our benchmarking database, this will be in aggregated and anonymised form, and you will not be identifiable by the recipient of such an analysis. EVOLVE’s data subjects’ individual Personal Information, and the benchmarking database, are not shared with any other organisations.
WHO HAS ACCESS
How your Personal Information is disclosed will depend upon the situation: –
While providing our Services, we will disclose your Personal Information to our client who has engaged our services in relation to yourself. We will not share any of your Personal Information with any other client.
From time to time, we disclose Personal Information to an associate leadership consultant who provides services, on EVOLVE’s behalf, to our clients. This would take place only if they were engaged on this piece of delivery and for no other reason.
EVOLVE discloses Personal Information to third parties who provide support for our Services of business operations. These include, but not limited to, IT consulting services, communication tools and any audit administration firms commissioned.
RETENTION PERIOD OF PERSONAL INFORMATION
In general, we will retain your Personal Information for the necessary period to fulfil our purpose as defined by GDPR regulations. This is commonly a three-year retention period for our services, with our reports being valid for a two-year period. We will only retain information about you past this three-year retention point if it is necessary: such as your name, email address and why and when you used our services.
LOCATION OF PERSONAL INFORMATION
EVOLVE is a consulting organisation, with clients all over the world. Some of EVOLVE’s clients are among the largest global corporations. EVOLVE’s consulting projects at times bring together Personal Information on subjects from many global regions, including the EEA. Our policy on data storage is to store EU subject Personal Information within the EEA. Your Personal Information will only be shared or accessible by EVOLVE staff outside the EEA under a legal framework which allows this, and where required by specific global client project requirements.
USE OF THE INTERNET
Given that the Internet is a global environment, the use of the Internet to collect and process Personal Information necessarily involves the transmission of data on an international basis. Therefore, by browsing our website and/or communicating electronically with us, you acknowledge and agree to our processing of Personal Information in this way.
YOUR CHOICES REGARDING YOUR INFORMATION
The Personal Information you give us is provided on a voluntary basis. However, if you do not wish to share some Personal Information with us, you may not be able to participate in our services.
You have the right to ask EVOLVE to stop using your information. EVOLVE’s policy is to make every effort to satisfy the requests of data subjects relating to access requests and data deletions. After your engagement with EVOLVE, if you wish to access, correct or do not wish us to retain your Personal Information, please refer to the contact details below. We may ask you to verify your identity, and to put your request in writing.
If you are listed in EVOLVE’s marketing database for events, research updates and other mailings, you can unsubscribe at any time by following the links provided in every alert email that you receive.
However, if your request involves deletion of your file, please be aware that in some circumstances, we may not be required or able to do so, particularly where your file also holds information about our clients or includes financial information that we need to keep for periods of up to three years. Where we are unable to comply with your request, we will provide reasons for not doing so. For instance, we may need to retain your email address so as to be able to honour other opt-out requests.
UPDATE TO OUR PRIVACY NOTICE
This Fair Processing Notice may be changed by EVOLVE at any time. If we change it in the future, we will advise you of changes or updates by a prominent notice on our website. Continued use of this website or our services after such changes will constitute your acceptance of such changes.
If, at any time, you have questions or concerns about EVOLVE’s online privacy commitment, please feel free to e-mail us at email@example.com or by writing to us at:
39 – 41 Wellington Street,
Central, Hong Kong