Privacy Policy

Fair Processing Notice for Employees 

Privacy Notice 

Statement and purpose of policy 

A. This Privacy Notice explains how Empower Partnerships handles and uses personal data we collect. Where in this statement we refer to ‘we’ or ‘our’ or ‘us’ we are referring to Empower Partnerships, and where we refer to ‘you’ or ‘your’ we are referring to:

a. Website Visitors 

b. Job Seekers/Candidates 

c. Those acting on behalf or for the benefit of job seekers/candidates (i.e. professional references 

d. Customers 

e. Vendors 

Why we hold your personal data

A. We are required to hold your personal data for various legal and practical purposes, without which we would be unable to adequately provide you with our services. 

B. Holding your personal data enables us to meet various administrative and legal obligations (e.g. for employment purposes). 

C. We will also process your personal information in other circumstances, provided you have given your consent for us to do so. 

Lawful basis for processing personal data

A. The lawful bases for processing your personal data as described in this document are one or more of the following: a. For the performance of a contract with you 

b. You have provided your consent to do so 

c. For legitimate interests that do not conflict with your rights 

d. For compliance with legal obligations 

B. For further detail on our legitimate interests as they may apply to your personal data, please Contact Us at 

Personal data held by Empower Partnerships 

A. We hold information collected when you visit our website(s), request information for our services, respond to a job advertisement, or when you provide your data to us in any other way or form. We may also request information from you directly. When we request information from you we will inform you whether providing us with such information is voluntary and consequences of electing not to provide the information, which may include our inability to adequately provide you with our services. Any personal data collected from you is subject to our privacy policy. 

Additionally, we may collect your personal data from our third-party sources – such as reference check and pre-employment screening vendors. Any personal information provided by you to a third-party is subject to that party’s privacy policy.

B. Potential sources of personal data may include: a. Information provided by you via completion of a form, application, or other request for information 

b. Third party websites such as job boards and professional/social media sources (e.g. LinkedIn) where you post information publicly 

c. Information provided by references you submit to us 

d. Pre-employment screening providers 

e. Service providers such as recruitment platforms 

f. Clients for the purpose of performing relevant work for them 

C. For business and commercial purposes, we may collect the following data: 

a. Identifiers such as your name, e-mail address, telephone number, mailing and/or physical address, references or contacts 

b. Demographic data such as your race, gender, national origin, or disability status as required and/or permitted by law and in support of compliance-based reporting practices 

c. Professional, employment-related, or education information such as your work history, nature and scope of the work you’ve performed, work authorization, your resume or C.V., educational achievements and certifications, professional licensing information, links to professional networking sites or online work portfolios, skills and behavioural assessment information, and other information you voluntarily provide to us that you, us, or our clients determine relevant to qualifying you for a position with us or one of our clients 

d. Career Objectives such as your professional interests, compensation and benefits expectations, desired work location, and other information as it relates to your career 

e. Device Information such as IP address, operating system, device type, browser information, and geolocation 

f. Information from outside sources provided by you to our third-party services for the purpose of conducting business 

g. Other information voluntarily provided by you electronically, verbally, or other formats for the purpose of performing business 

Sensitive personal data held by Empower Partnerships 

A. You may be asked to provide information that is considered sensitive personal information. Examples of such sensitive personal information include:

a. Records may contain:

• Information that confirms your work eligibility such as national identifiers or similar information 

• Your racial or ethnic origin or religious or similar information in order to monitor compliance with equal opportunity legislation 

How your personal data is used by Empower Partnerships 

A. Your data is used by us for business and commercial purposes including:

    • Talent Acquisition activities for employment opportunities (current and future) with us or our clients, this includes performing activities that allow us to determine your eligibility for such employment opportunities 
    • Providing services to our customers or receiving services from our vendors 
    • Compliance with laws and regulatory requirements such as equal opportunity legislation 
    • Marketing and promotional communications such as outreach e-mails, invitations to special events, flyers, or other promotional communications 
    • Internal reporting and record keeping 
    • Administrative purposes (e.g. in order to process fees or payments) 
    • Responding to data access requests you make 
    • Anonymization and aggregation of you data for purposes of business analytics, at which point such anonymized data is no longer identifiable to a person 
    • Contacting you, your next of kin, or other relevant contact in case of an emergency 
    • Business Development activities such as contacting you in consideration for a job opportunity or as a prospective customer

B. Communications to you may be sent by the communication methods provided by you or a party you have authorized to represent you; which may include post, telephone or email address. 

C. If you have concerns or queries about any of these purposes, or how we communicate with you, please contact us at the address given below. We will always respect a request by you to stop processing your personal data, and in addition your statutory rights are set out below. 

Sharing your data with others

A. Personal data, including sensitive personal data, may be shared with customers who legitimately need the information to carry out their normal duties to enable an employment relationship with them. We endeavor to ensure that sensitive personal data is only shared with your explicit consent. However, circumstances may arise where this data is shared with without gaining your consent. This will only occur if it is necessary to protect your vital interests or the vital interests of another person; or for certain other reasons where it is not possible or appropriate to gain your consent such as to meet statutory obligations relating to equality monitoring. 

B. Empower Partnerships may disclose certain personal data to third-party vendors. These external organizations, and the purpose for sharing the information, are set out below. a. We may share any or all of your personal data internally within Empower Partnerships as relevant business needs arise such as for the purpose of performing talent acquisition or talent management activities 

b. Relevant data, including resumes or CV’s, career objectives, and assessment results will be shared with our customers with which we are working to perform talent acquisition activities on behalf of 

c. Relevant data may be shared with your next of kin but only with your consent or in an emergency 

d. Relevant data may be shared with vendors for the purpose of executing talent acquisition activities, including reference check submissions, behavioral and skills assessments, and pre-employment screening activities 

e. With your permission we may share information about you for publicity and marketing purposes online, in print and on social media. 

C. Otherwise, Empower Partnerships does not share data with any third party, except as allowed for in other privacy notices or required by law. We do not sell your personal data to third parties under any circumstances, or permit third parties to sell on the data we have shared with them. 

Transfer of personal data to other countries

A. Empower Partnerships and its service providers are based in the United States. You may be based in a country or jurisdiction that may have different data privacy laws and protections than the United States. The legal basis, where required, for the transfer of data is to provide our Services, which may include matching you with suitable roles for our clients, which are discussed with you in advance of submittal. 

How long data is kept

A. We will keep your personal data only as long as is necessary for the purpose(s) for which it was collected, and in accordance with our Data Protection Policy. Data will be securely destroyed when no longer required. 

Your rights 

You have the following rights To be informed 

This Privacy Notice provides the information you are entitled to receive 


Please contact us if you would like confirmation that your data is being processed and access to your personal data. 

There is no charge for us providing you with this data and it will usually be provided within a month of the request (unless the request is unfounded or excessive). 


Please inform us of any data which you would like rectified and we will usually respond within a month of the request. 

We will pass on the changes to any third parties who need to change their records and let you know this has been done. 


You may exercise your right to have your personal data erased in a number of circumstances (e.g. if the data is no longer necessary in relation to the purpose for which it was created or you withdraw your consent). Where possible we will comply with all such requests. 

Restrict processing 

You can tell us that we can keep your data but must stop processing it, including preventing future mailings and communications. 

If possible we will inform any third parties to whom your data has been disclosed of your requirement. 

Data portability 

Your data is across manual records and databases. We will do our best to provide information in a portable format but it is unlikely that we 

can create systems to do so. 

to object 

If we can, we will stop processing your data if you object to processing based on legitimate interests or the performance of a task in the public interest / exercise of official authority (including profiling). 

We will stop processing your data for direct marketing if you tell us to. 

We will stop processing your data if you object to processing for purposes of research and statistics.