Employment Managed Privacy

1. Who we are

Employment Managed is provided by Bear & Willow HR ("we", "us"), the data controller for the personal information described here. Contact: Support@bearandwillowhr.co.uk. 22 Friary Place. Kingswood. HU73PL ICO ZC105574

Who this notice is for?

Employment Managed is for adults aged 18 and over. We do not knowingly collect information about anyone under 18. If you believe someone under 18 has created an account, please tell us at Support@bearandwillowhr.co.uk and we will delete it.

2. Personal information, and special category data

Personal information ("personal data") is anything that can identify you, on its own or combined with other details, such as your name, date of birth, address, or information about your health and circumstances. Some of it is "special category" data and given extra protection; this includes information about your health. We handle all of it carefully and use it only to support you.

3. What we collect

Personal identifiers — your name, date of birth and National Insurance number.
Contact information — your address, telephone number and email.
Activity information — your sign-in details and how you use the app (for example, targets you set and applications you track).
Demographic information — your occupation, employment history, qualifications and academic progress, and your career goals.
Health & sensitive information — the barriers to work you choose to record, including any health-related details. If you are on a supported programme, your employment advisor may also record whether a Work Capability Assessment is not needed, booked or completed, and the date. We do not record medical detail. You stay in control of what you share with your employment advisor.
Appointments and reminders — appointments booked with your employment advisor. If you turn reminders on, your phone schedules them itself; the reminder does not leave your device and we do not use a notification service.
Questions you send to a person — where the app cannot answer something, you can send a written question to a real professional (careers, HR or a work coach). Your question, and anything you choose to include in it, is shown to that person so they can reply.
Device security — you can choose to lock the app with your fingerprint, face or device passcode. This uses your phone's own security. We never see, receive or store anything biometric.

4. How and why we use it, and our lawful bases

You give us most of your information when you build your profile; your keyworker may add to it with your consent. We use it to help you build your CV and cover letters, understand your options, set goals and find work.

Consent — for linking to a keyworker, sharing progress with a funded programme, and asking questions of our advisers.
Contract / legitimate interests — to provide and improve the service you have signed up to.
Special category (health) data — processed on the basis of your explicit consent and/or a substantial-public-interest condition.

5. AI features

When you use an emmy feature, the relevant parts of your profile are sent securely to our AI provider (Anthropic) to generate that content.

For CV and cover letter help, that means your skills, work history and qualifications. For the "find work that fits" adviser it also includes the barriers you have chosen to record, which may include health-related details.

For course and careers searches, we send only what you typed and the first part of your postcode (for example HU), never your full postcode, your name or anything that identifies you. The search is limited to a fixed list of verified colleges, universities and government websites, and results are stored briefly so that the same search does not have to be run again.

Your information is used only to answer your request, is never used to train AI models, and we never send more than the feature needs. Anthropic may process this data outside the UK; see International transfers below.

6. Where we store it, and how we protect it

We store your information securely in the cloud on UK/EU data centres, and cache it on your own device. We protect it with encryption in transit and at rest, strict role-based access controls so people only see what they are allowed to, and a log of who opens your record.

7. How long we keep it

We keep your information for as long as you have an account. If you delete your account, we erase your personal details, your CV and your documents. We keep only a minimal record, such as your name, email and key dates, for up to 6 years where the law requires it, to meet our legal obligations and to establish or defend legal claims. After that period it is automatically deleted. (See the Data Retention & Deletion Schedule.)

8. Who we share it with

Your linked employment advisor (only with your consent; you can unlink at any time), and, where you are on a funded programme, the organisation funding your support (such as your local council or the DWP) for case management and outcome reporting. Your employment advisor can correct your personal details, for example a misspelled name or a changed phone number; you can see and correct the same details yourself, and we log who opens your record.

Where an organisation supports someone who does not use the app, it may keep a minimal record of that person in its own dashboard. In that case the organisation decides how that information is used, and is responsible for telling that person.

We also use anonymised, combined figures to measure and improve the service. We never sell your information. We use trusted processors to run the service (for example cloud hosting, AI generation and email); a current list is available on request and in our Data Processing Agreement.

9. International transfers

Some processors (for example our AI provider) may process data outside the UK. Where they do, we rely on appropriate safeguards such as the UK International Data Transfer Agreement or Standard Contractual Clauses.

10. Your rights

Ask for a copy of the personal information we hold about you.
Ask us to correct anything that is wrong.
Ask us to delete your information (your "right to erasure").
Withdraw consent at any time — for example, by unlinking your keyworker.

To make a request, contact Support@bearandwillowhr.co.uk. You can also complain to the Information Commissioner’s Office (ICO) at ico.org.uk.

11. Changes

We may update this policy as the service grows; if we make significant changes we will tell you in the app.

Bear & Willow HR LTD, 22 Friary Place, Kingswood, Hull HU7 3PL. ICO registration ZC105574. Contact: Support@bearandwillowhr.co.uk