EERA Privacy Policy

Version 1.0

Effective date: 18 October 2026
Policy reference: 2026-10-18-v1.0

​

1. Who we are

​

EERA LTD, trading as EERA and Edwards Employment & Recruitment Agency, provides recruitment, career development, business support, talent development and creative services.

EERA LTD is the controller of most personal information described in this notice.

​

Company number: 17504364
Registered office: 108 Peckham High Street, London, England, SE15 5ED
Privacy and general contact: contact@eerauk.com
Telephone: 020 8050 3629
Website: www.eerauk.com
ICO registration: ZC271439

​

In some projects, EERA may process personal information solely on the documented instructions of a client or partner. In those circumstances, that organisation may be the controller and EERA may act as its processor. The relevant agreement or project notice will explain the arrangement where this applies.

2. What this policy covers

This policy explains how EERA collects, uses, shares, stores and protects personal information when you:

• visit the EERA website;

• create or use a Wix member account;

• use the My EERA individual portal;

• use the EERA for Business portal;

• register as a candidate, client, business contact, partner, artist, athlete or creative professional;

• enquire about or receive recruitment, consultancy, development, creative or talent services;

• apply for an opportunity or approve an introduction;

• submit a business profile, hiring brief or project request;

• purchase or request access to an optional EERA service or resource;

• communicate with EERA; or

• exercise a privacy right or make a complaint.

This policy applies to personal information about individuals. Information about a limited company is not always personal information, but details relating to directors, employees, sole traders, partners, contacts and other identifiable people are personal information.

3. The information we may collect

The information we collect depends on your relationship with EERA and the service you use.

Account and contact information

This may include:

• your name;

• email address;

• telephone number;

• postal or business address;

• Wix member ID, member status and verified-email status;

• account preferences;

• profile photograph, where supplied;

• communication preferences; and

• records of sign-in, account access and security activity.

Candidate, career and professional information

This may include:

• CVs and employment history;

• education, training, qualifications and professional registrations;

• skills, experience, achievements and portfolio information;

• preferred roles, sectors, salary, location, hours and availability;

• work eligibility or sponsorship information relevant to a role;

• interview and assessment information;

• vacancy preferences and applications;

• records of roles discussed, approved introductions and submissions;

• references and verification results;

• interview, offer and onboarding information;

• placement and aftercare records;

• feedback, development priorities and agreed next steps; and

• information you choose to share about career, music, sport, creative work or personal-brand goals.

Client and business information

This may include:

• business or trading name;

• company number, legal structure and registered address;

• public registration and regulatory particulars;

• contact details for directors, owners, managers and authorised users;

• sector, locations, workforce and organisational information;

• recruitment requirements and vacancy details;

• salaries, working arrangements and role criteria;

• health and safety information relevant to a vacancy or assignment;

• business goals, challenges and development priorities;

• hiring briefs, project requests, service enquiries and approvals;

• business readiness and setup responses;

• details of services discussed, proposed or delivered;

• order, invoice and access-status information; and

• feedback, complaints and aftercare information.

We do not ask businesses to place passwords, private government credentials, full tax credentials or other unnecessary secrets into an ordinary business profile.

Documents and content

This may include:

• CVs;

• supporting documents;

• images;

• approved portfolio material;

• business documents;

• project files;

• brand assets;

• written reflections;

• progress evidence; and

• documents or links you specifically choose to share with EERA.

You should not upload identity documents, criminal-record certificates, detailed health records or other highly sensitive evidence through a general upload area unless EERA has provided a specifically approved secure route.

Communications and service records

We may retain:

• emails, forms and messages;

• call or meeting notes;

• booking and consultation information;

• service instructions;

• proposals and agreements;

• complaints and requests;

• decisions, approvals and version history; and

• factual internal notes relevant to delivering or protecting the service.

Internal notes remain personal information where they relate to an identifiable person and will be handled accordingly.

Payment and purchase information

Purchases are completed through the EERA Wix website or its payment provider rather than inside the Cloudflare portal.

When payment functions are enabled, EERA may receive:

• customer and order identity;

• product or service purchased;

• amount and payment status;

• purchase date;

• access period;

• refund or cancellation status; and

• invoice or transaction references.

EERA does not ordinarily need to receive or store your full payment-card details. Those details are normally processed by the checkout or payment provider.

Technical, device and security information

This may include:

• IP address;

• browser and device type;

• operating system;

• approximate access time;

• requested pages;

• authentication and security events;

• session identifiers;

• error and diagnostic information; and

• information needed to prevent misuse, fraud or unauthorised access.

4. Where information comes from

We usually receive personal information directly from you.

We may also receive information from:

• your Wix member account;

• a client, hirer or authorised business representative;

• a candidate or professional you have authorised to refer you;

• referees;

• professional or regulatory bodies;

• qualification, identity or eligibility verification providers;

• publicly available professional sources, such as a company website or professional profile;

• event, programme or delivery partners;

• service providers acting for EERA; or

• public authorities where disclosure is lawful and relevant.

Where we obtain personal information from another source, we will provide appropriate privacy information within the required period unless an applicable exception applies.

5. Why we use information and our lawful bases

EERA uses personal information only where there is a lawful basis and the use is necessary and proportionate.

Depending on the circumstances, we may rely on the following bases.

Steps before entering into a contract or performance of a contract

We may use information to:

• respond to an enquiry;

• assess whether EERA can provide a requested service;

• administer an account;

• prepare or perform a service agreement;

• coordinate a recruitment instruction;

• manage an application, project, purchase or placement;

• provide a purchased service or resource; or

• deliver agreed aftercare.

Legitimate interests

EERA may rely on legitimate interests to:

• provide and improve recruitment and business services;

• understand a candidate’s professional direction;

• assess role-related evidence;

• manage client and candidate relationships;

• maintain accurate service and contact records;

• coordinate approved introductions;

• identify business support needs;

• create explainable in-portal suggestions;

• prevent duplicate submissions;

• maintain security;

• prevent fraud and misuse;

• manage complaints;

• protect legal rights; and

• operate and improve the EERA website and portals.

Where EERA relies on legitimate interests, we consider whether the use is necessary, whether you would reasonably expect it and whether your interests or rights override EERA’s interest.

Legal obligation

We may use and retain information to comply with legal and regulatory obligations, including obligations relating to:

• employment-agency records;

• suitability and verification checks;

• company and tax records;

• accounting;

• fraud prevention;

• data-protection rights;

• safeguarding;

• health and safety;

• court orders; and

• cooperation with authorised regulators or public authorities.

Consent

We rely on consent where the law requires it, including for certain:

• optional marketing communications;

• non-essential cookies or similar technologies;

• sensitive disclosures;

• publication permissions;

• portfolio or media uses; and

• other clearly optional activities.

You may withdraw consent at any time. Withdrawal does not make earlier lawful processing unlawful.

Vital interests

In a genuine emergency, we may use or share limited information where necessary to protect someone’s life or physical safety.

6. Required and optional information

Some information is necessary for EERA to create an account, assess a request, comply with legal duties or provide a service. Required fields will normally be identified.

You are not required to purchase optional CV, coaching, branding, training or similar services in order to receive ordinary recruitment work-finding services.

When optional information is requested, you may usually decline to provide it. However, EERA may be unable to provide a particular service, make an introduction, complete a required check or proceed with a transaction if essential information is missing.

7. Recruitment, screening and matching

EERA may compare information in your profile, CV or approved documents with the stated requirements of an opportunity.

The current portal uses explainable text-evidence matching. It may identify words, experience or evidence relevant to stated criteria. It can miss context or misread documents and does not prove qualifications, suitability or entitlement to work.

The matching process:

• does not use a generative AI provider;

• does not automatically reject a candidate;

• does not automatically submit an application;

• does not automatically disclose a candidate to a client; and

• does not make a solely automated decision with a legal or similarly significant effect.

EERA staff review relevant information and remain responsible for recruitment and introduction decisions. You may correct your information, pause suggestions, ask for an explanation or request human review.

Clients cannot browse a general candidate database or view private candidate profiles. EERA coordinates named, role-specific introductions. Candidate information is shared with a named prospective employer only after the opportunity and intended sharing have been discussed and approved.

8. Business assessments and service suggestions

The EERA for Business portal may ask questions about:

• legal and trading identity;

• public registration particulars;

• workforce and workplace arrangements;

• data and systems;

• recruitment;

• business goals; and

• support priorities.

The purpose is to understand the business, coordinate requested services and identify information that may need clarification.

Responses may produce deterministic internal support signals such as:

• information missing;

• clarification needed;

• setup in progress; or

• a reported support need.

These signals are not an automatic legal or compliance assessment. They do not certify whether a business is compliant.

A business may decline personalised sales suggestions. Its factual setup responses may still be used to coordinate existing or requested services, but optional service-proposal prompts will be restricted in line with its stated preference.

The personalised-suggestion preference is separate from permission to receive marketing emails or messages. No sales email is sent automatically from the portal.

9. Special-category and criminal-offence information

Special-category information can include information about health, disability, ethnicity, religion, sexual orientation, trade-union membership and biometric or genetic information.

EERA does not seek this information unless it is relevant and necessary, for example to:

• arrange a reasonable adjustment;

• respond to a safeguarding concern;

• comply with employment or social-protection law;

• establish or defend a legal claim; or

• provide a specifically requested service.

Where EERA processes special-category information, it must identify both an ordinary lawful basis and an additional condition under data-protection law. A more specific notice or secure process may be provided where appropriate.

Criminal-offence information is requested or used only where it is lawful, necessary and relevant to the role or service. It must not be uploaded through a general document area unless EERA has provided an approved route.

10. Who we may share information with

EERA does not sell personal information.

We may share limited information with:

• named prospective employers or clients, following an approved introduction;

• referees and verification providers;

• professional, regulatory or qualification bodies;

• delivery partners involved in an agreed service or programme;

• Wix, for the public website, member accounts, bookings and checkout;

• Cloudflare, for portal hosting, database and private document storage;

• Google Workspace, for business email and communications;

• payment providers, where a purchase is made;

• an approved private document-security or malware-scanning provider, when uploads are enabled;

• accountants, insurers, legal advisers and other professional advisers;

• regulators, courts, law-enforcement bodies or public authorities where required or permitted by law;

• a purchaser or successor where EERA undergoes a genuine business reorganisation, subject to appropriate protections; or

• another person where you have specifically authorised the sharing.

Access within EERA is restricted according to role, responsibility and assigned account. Staff should only access information required for their authorised work.

Candidate and business portal records remain separated. Aftercare feedback from a candidate and a client is stored as separate records and is not automatically shown to the other party.

11. Service providers and processors

EERA uses service providers to operate its website, portals, communications, storage, security and payments.

Providers may act as processors for EERA and must only process information for agreed purposes, under appropriate contractual and security obligations.

EERA reviews the suitability of providers, the information they receive, their security measures, their sub-processors and arrangements for deletion or return of information when services end.

New providers, including any future AI, analytics, messaging or document-processing provider, will be assessed before personal information is sent to them. This policy will be updated where a new use materially affects individuals.

12. International transfers

Some service providers operate in more than one country or may process information outside the United Kingdom.

Where data-protection transfer rules apply, EERA will use an available lawful transfer mechanism, such as:

• UK adequacy regulations;

• approved contractual safeguards;

• another legally recognised safeguard; or

• a limited exception where legally permitted.

Where required, EERA will also consider whether additional contractual, technical or organisational safeguards are needed.

EERA does not claim that all personal information is hosted only in the United Kingdom unless that has been specifically verified for the relevant service.

13. How long we keep information

EERA keeps personal information only for as long as reasonably necessary for the purpose for which it was collected, legal obligations, complaints, safeguarding, financial requirements or legal claims.

The following are the current standard retention positions.

General enquiries

Where EERA takes no work-finding or service action, enquiry records will normally be reviewed for deletion 12 months after the last meaningful contact.

Candidate and hirer work-finding records

Active recruitment records will be reviewed periodically.

Records required under employment-agency rules will be retained for at least 12 months after their creation and for at least 12 months after EERA last provides work-finding services to the relevant candidate or hirer.

Unnecessary material may be removed sooner where no legal or operational reason requires it.

Placement and aftercare records

Placement records will be retained throughout the placement and agreed aftercare period, including Day 1 and month 3, 6, 9 and 12 reviews where applicable.

After the aftercare period, records will be reviewed under the applicable contract, statutory-record, complaint and legal-claims periods.

Client contracts, projects and service records

Contracts, accepted terms, proposals, material project records and placement records will normally be retained for up to six years after the relationship, project or contract ends, unless a shorter or longer period is justified.

Financial and transaction records

Invoices, payment and accounting records will normally be retained for at least six years, or longer where required by tax, accounting or legal obligations.

Marketing records

Marketing preferences will be retained while marketing continues.

Where you withdraw consent or object, EERA may retain a minimal suppression record for as long as needed to ensure that your preference continues to be respected.

Privacy requests, complaints and incidents

Privacy requests, formal complaints and material security-incident records will normally be retained for up to six years after closure, subject to proportionality, legal requirements and any legal hold.

Inactive portal accounts

Accounts may be reviewed after 12 months of inactivity.

Closing an account does not automatically delete information that EERA must retain for recruitment, contractual, financial, safeguarding, complaint or legal reasons.

There is no unattended automatic deletion of all contractual or recruitment records. Deletion and restriction requests are assessed individually.

14. Security and document uploads

EERA uses technical and organisational measures intended to protect information against loss, unauthorised access, alteration, disclosure or misuse.

Measures include, where applicable:

• authenticated access;

• verified member accounts;

• role-based permissions;

• account-scoped records;

• encrypted transport;

• private document storage;

• access logging;

• session expiry;

• revision and integrity checks;

• staff access controls;

• backups;

• incident handling; and

• security review of service providers.

No online service can guarantee absolute security.

Live document uploads remain disabled until EERA has connected and approved an appropriate private malware-scanning process. When uploads are enabled, files may be checked by a security provider before being accepted or made available.

You should use only EERA’s approved routes and should not send passwords or highly sensitive information by ordinary email.

15. Cookies and storage technologies

The EERA website and portals use cookies or similar storage technologies.

The portal uses essential session and security technologies to:

• authenticate users;

• maintain a secure session;

• complete the Wix-to-portal handoff;

• prevent unauthorised access; and

• provide functions specifically requested by the user.

A portal session normally expires after eight hours.

At the date of this policy, no optional advertising or behavioural-tracking scripts have been added to the Cloudflare portal.

Wix pages use their own cookies and storage technologies. Wix cookie information and preference controls apply to the public website and Wix member experience.

If EERA introduces non-essential analytics, advertising or other storage technologies, it will provide appropriate information and obtain consent or provide an applicable objection mechanism before those technologies are used.

The sample portal preview may store fictional demonstration changes locally on a device. It must not be used to enter real personal, candidate or business information.

16. Marketing and service communications

Service communications are messages needed to administer an enquiry, account, application, placement, project, purchase, legal obligation or requested service.

Marketing communications are optional.

Where required, EERA will obtain valid consent before sending email, text or similar direct marketing. You may withdraw consent or object to direct marketing at any time.

Business contacts also have the right to object to the use of their personal information for direct marketing. Where you opt out, EERA may retain limited details on a suppression list rather than deleting every record, so that your preference can continue to be honoured.

Portal marketing choices do not automatically update every separate Wix, email or external marketing list. EERA must reconcile preferences before using an external marketing system.

17. Your rights

Subject to legal conditions and exemptions, you may have the right to:

• be informed about how your information is used;

• request access to your personal information;

• ask for inaccurate or incomplete information to be corrected;

• request deletion;

• request restriction of processing;

• object to processing based on legitimate interests;

• object to direct marketing;

• request data portability where applicable;

• withdraw consent where consent is relied upon; and

• challenge a qualifying solely automated decision.

These rights are not absolute. For example, EERA may need to retain certain recruitment, financial, contractual, complaint or legal records.

To exercise a right, contact contact@eerauk.com.

Please explain what you would like EERA to do and provide enough information to identify the relevant records. EERA may need to verify your identity before disclosing or changing information.

EERA will respond without undue delay and normally within one month. Where the law permits more time because a request is complex or numerous, EERA will explain this.

18. Account closure and withdrawal from a service

You may stop using an EERA account or service and may ask EERA to close your portal access.

Account closure:

• ends ordinary access to the portal;

• does not automatically cancel a separate contract or purchase;

• does not automatically withdraw an application already sent with your approval;

• does not automatically recall information already lawfully shared with a named recipient; and

• does not require EERA to delete information that must lawfully be retained.

EERA will assess any associated deletion, restriction, objection or portability request separately.

19. Children and people under 18

The self-service candidate and business portals are intended for people aged 18 or over.

A parent, guardian, young person, partner or representative should contact EERA before information about anyone under 18 is entered into the portal.

EERA must agree appropriate:

• parental or guardian authority;

• safeguarding arrangements;

• service scope;

• communication routes;

• representation terms; and

• privacy information suitable for the young person.

The general portal is not a completed child-facing safeguarding system.

20. Complaints

Please contact EERA first if you have a concern about how your information has been handled:

Email: contact@eerauk.com
Post: EERA LTD, 108 Peckham High Street, London, England, SE15 5ED
Telephone: 020 8050 3629

EERA will investigate and provide a reasoned response.

You also have the right to complain to the Information Commissioner’s Office, the United Kingdom’s data-protection regulator. Details of how to complain are available through the ICO’s official website.

Making a privacy complaint will not disadvantage you in a recruitment, service or business relationship.

21. External websites

The EERA website and portals may contain links to external websites, booking systems, professional profiles, payment pages or partner services.

EERA is not responsible for the privacy practices of an independent external organisation. You should review its privacy information before providing personal information.

22. Changes to this policy

EERA will review this policy periodically and when there is a material change to:

• its services;

• its technology;

• its service providers;

• its legal obligations;

• its matching or decision processes;

• its international transfers; or

• the way personal information is collected or used.

A new use of personal information will be brought to the attention of affected individuals before it begins where required.

The current version and effective date will be shown at the top of this page. Where a material change affects existing portal users, EERA may also provide an in-account or direct notice.

23. Contact

Questions, rights requests, accessibility requests and privacy complaints should be sent to:

EERA LTD
108 Peckham High Street
London, England
SE15 5ED

Email: contact@eerauk.com
Telephone: 020 8050 3629
Company number: 17504364
ICO registration: ZC271439