Candidate Policy

1. Equal opportunities

Evan Craig Limited is committed to a policy of equal opportunities for all work seekers and shall adhere to such a policy at all times and will review on an on-going basis on all aspects of recruitment to avoid unlawful or undesirable discrimination. We will treat everyone equally irrespective of sex, sexual orientation, gender reassignment, marital or civil partnership status, age, disability, colour, race, nationality, ethnic or national origin, religion or belief, political beliefs or membership or non-membership of a trade union and we place an obligation upon all staff to respect and act in accordance with the policy.

 

Evan Craig Limited shall not discriminate unlawfully when deciding which candidate/temporary worker is submitted for a vacancy or assignment, or in any terms of employment or terms of engagement for temporary workers. Evan Craig Limited will ensure that each candidate is assessed only in accordance with the candidate’s merits, qualification and ability to perform the relevant duties required by the particular vacancy.

 

2. Criminal record disclosure

We ask our candidates to complete information in relation to job roles which are not exempt from the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975 (2013 and 2020). For this reason you are only required to disclose information about unspent convictions. You are not required to disclose spent convictions.

 

Additionally, you are not required to declare any information about ‘protected’ offences – (offences to which the filtering rules apply).  If you are unsure as to whether a conviction is unspent/spent or protected (filtered) please see the additional guidance or you can contact organisations such as NACRO  or Unlock for further information

 

If you wish to be put forward for/if any role is identified which may be suitable for you but which is exempt from the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975 (2013 and 2020), meaning that you are required to disclose spent convictions, we will ask you to complete an additional criminal disclosure form. You are not required to complete that additional form if you do not wish to be put forward for that type of work.

 

If you have declared any convictions you are welcome to provide us with any additional information that you think may be relevant and which will help us to determine your suitability to be put forward for roles with our clients. This could include for example information about the circumstances of the offence, any work (paid or voluntary) or training that you have undertaken since, change in your circumstances etc.

We will seek to put forward/supply the best possible candidates to our clients. Having a criminal conviction will not necessarily exclude you from the process.

 

The information given will be treated in the strictest of confidence and only taken into account where, in our reasonable opinion, the offence is relevant to the post to which you are applying. Failure to declare a conviction may require us to exclude you from our register if the offence is not declared but later comes to light. If you are working in an assignment with a client at the time that we are made aware of a conviction that have not disclosed to us, we may be legally required to inform our client of that information and your assignment may be terminated.

 

3. Health and Disability

We want to ensure that we provide work finding services to all work seekers fairly and equally. 

If a permanent role or temporary assignment requires an intrinsic function to be completed, we will discuss your ability to undertake this function after you have been successfully registered with the Agency.

 

* Intrinsic means if that particular task could not be performed the job could not be carried out.

4. Data Protection Statement

 

Evan Craig Limited provides work-finding services to its clients and work-seekers. We must process personal data (including sensitive personal data) so that we can provide these services – in doing so, we act as a data controller.  This is why we have asked for your personal data on this form.  When we process your personal data we must do so in accordance with data protection laws.  Those laws require us to give you a Privacy Statement to explain how we manage your personal data.

 

Please see our GDPR Privacy policy below

 

Evan Craig Limited (company number 12795384) (collectively referred to as “Evan Craig”, "we", "us" or "our" in this privacy policy) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you. This policy explains how Evan Craig processes personal data if you are:

• any person, firm or body corporate (together with any subsidiary or associated company as defined in s1159 of the Companies Act) who approaches Evan Craig with a view to engaging a Candidate (as defined below) (Clients);
• an applicant for a permanent role advertised or promoted by Evan Craig (Candidates); and
• a user of our website (Website Users).

This privacy policy is divided into sub-sections in relation to Associate Companies, Clients, Candidates and Website Users. It contains different information depending on who the information refers to.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.  

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy policy

This privacy policy aims to give you information on how Evan Craig collects and processes your personal data through your use of this website, our services or Programme, including any data provided by any Associate Companies, Clients, Candidates or Website Users.

This website is not intended for children and we do not knowingly collect data relating to children.

Controller

Evan Craig is the controller and responsible for your personal data.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

Full name of legal entity: Evan Craig Limited (company number: 12795384)

Email address: info@evancraig.co.uk

Postal address: 71 - 75 Shelton Street, Covent Garden, London, WC2H 9JQ

Telephone number: 0121 5611423

Data Protection Contact: Lucy Bayliss

 

Information Commissioner’s Office

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated in Sept 2023 and historic versions can be obtained by contacting us on the details set out above.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Clients

• Identity Data may include first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes residential address, email address and telephone number.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments from you.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, preferences, feedback and survey responses. 
• Usage Data includes information about how you use our website and portal / database.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Associate Companies

• Identity Data includes first name, maiden name, last name, marital status, title, and gender.
• Associate Data includes employment history.
• Contact Data includes billing address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to you.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password.
• Usage Data includes information about how you use our website and portal / database.

Candidates

• Identity Data may include first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Candidate Data includes curriculum vitaes, referee details, employment history, education history, start date, copies of passports, diversity information, and other information provided by a Client to Evan Craig or an Associate Company for the purposes of assessing their suitability for a job vacancy (and may also include Contact Data and consist of Special Category Data and Criminal Convictions Data);
• Contact Data includes residential address, email address and telephone number;
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, feedback and survey responses. 
• Usage Data includes information about how you use our website and portal / database.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

As mentioned above, we may (when required and permitted by law) collect Special Categories of Personal Data from Candidates (which may include details about a Candidate’s race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) (Special Category Data).

 

We may also (when required and permitted by law) collect information in relation to any criminal convictions and/or offences relating to a Candidate (Criminal Offence Data).

Website User

• Identity Data may include first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.  

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you to provide you with recruitment services. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data:

Associate Companies

• Direct interactions. Associate Companies may give us Identity Data, Contact Data, Associate Data and Financial Data by corresponding with us by post, phone, email or signing up to the Programme.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookies Policy for further details.
• Third parties. We may receive personal data such as Identity Data, Contact Data and Associate Data about you from various third parties and receive referrals from third party recruiters.
• Online sources. We will sometimes collect Identity Data from publicly available sources, such as Companies House.

Candidates

• Direct interactions. Candidates may give us Identity Data, Contact Data, Candidate Data (which may include Special Category Data and Criminal Offence Data) and Financial Data by corresponding with us by post, phone, email or otherwise responding to job advertisements posted by Evan Craig or Associate Companies, or give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookies Policy for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below when you interact with our website:
  • Technical Data from the following parties:
    • analytics provider Google based outside the UK; and
    • advertising networks such as Adzuma, Talent.com, CV Library, ApplyGateway, Trovit based inside the UK,and Adzuma, Talent.com, Trovit, Zip Recruiter, Apply Gateway.com, based outside of the UK (in the US).

• Identity Data, Candidate Data and Contact Data from various third parties and from third party recruiters.

• Other online sources. We will sometimes collect Candidate Data from publicly available sources, such as LinkedIn.

Clients

We use different methods to collect data:

• Direct interactions. Clients may give us Identity Data, Contact Data, Profile Data and Financial Data by corresponding with us by post, phone, email or otherwise when a Client asks us to provide them with recruitment services.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookies Policy for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:  
  • Technical Data from analytics provider Google (based outside the UK);

• We will sometimes collect Client Data from publicly available sources, such as LinkedIn.

Website Users

• Direct interactions. Website Users may may give us Identity Data by corresponding with us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• where we need to perform the contract we are about to enter into or have entered into with you;
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
• where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Please note that personal data provided by Candidates may (as part of our service) be shared with Associate Companies and Clients for the purposes of providing our services to the Candidate.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register new Associate Companies / Clients / Candidates	(a) Identity (b) Contact	Performance of a contract with you
To create an account for Associate Companies / Clients / Candidates on our portal	(a) Identity (b) Contact	Performance of a contract with you
To assist Candidates with finding suitable employment with Clients	(a) Identity (b) Contact (c) Candidate	Performance of a contract with you
To process and deliver the recruitment services to Clients and Candidates: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e)Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts/fees due to us)
To manage our relationship with Clients and Candidates which will include providing notifications about changes to our terms or privacy policy	(a) Identity (b) Contact (c) Profile (d)Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how Clients and Candidates use our recruitment services)
To administer and protect our business, our website and our portal (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business and providing our recruitment services) (b) Necessary to comply with a legal obligation
To use data analytics to improve our website, recruitment services, marketing, customer relationships and experiences for Candidates, Clients, Associate Companies and Website Users.	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to Clients, Candidates and Website Users about recruitment services that may be of interest.	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f)Marketing and Communications	Necessary for our legitimate interests (to develop our services and grow our business)

            Special Category Data

In addition to the above, where we collect and process any Candidate’s Special Category Data, we do so to ensure we are providing appropriate recruitment services. Generally, we will obtain explicit consent from Candidates in order to collect and process any Special Category Data and to share it with any Client, Associate Company or third party (see below). However, we may process and share any Special Category Data with a third party without the Candidate’s explicit consent where it is necessary to protect the vital interests of those of another person where they are physically or legally incapable of giving consent (for example, in the event of a medical emergency.

Criminal Offence Data

In addition to the above, where we collect and process any Candidate’s Criminal Offence Data, we do so to ensure we are providing appropriate and relevant recruitment services to Candidates and Clients. Generally, we will obtain explicit consent from Candidates in order to collect and process any Criminal Offence Data and to share it with any Client or Associate Company if appropriate.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us.  

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, warranty registration, service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.  If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.  For more information about the cookies we use, please see our Cookie Policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table above.

• Clients who request the Candidate Data of any Candidate.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
• Specific third parties who support or service delivery such as Natwest to process and administer payment of your order.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

Many of our external third parties are based outside the United Kingdom so their processing of your personal data will involve a transfer of data outside the United Kingdom.

Whenever we transfer your personal data out of the United Kingdom, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
• where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see section 9 (your legal rights) below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.