Privacy Policy

Auratus Recruitment Limited – Privacy Policy

1. Introduction

1.1 This Privacy Policy governs the collection, storage and use of personal information collected by Auratus Recruitment Limited (trading as Humankind Global Recruitment), a company incorporated in England and Wales with registered company number 15068272 with its registered offices located at 3rd Floor, 17 Hanover Square, London, England W1S 1BN (Auratus Recruitment Limited, we or us ) and our group companies Auratus Services Limited

1.2 The information set out in this Privacy Policy is provided to individuals whose personal data we process (you or your)as data controller, in compliance with our obligations under Articles 13 and 14 of the UK General Data Protection Regulation (GDPR).

1.3 To make this information clear, we have divided the data we receive into the following groups and corresponding Schedules, where each of which refers to: the particular category of information we collect and retain; from where we obtain the information from; the purpose and legal basis of processing and to whom we will (if applicable) disclose the information:[1]

Schedule 1	Data about our potential, existing and previous candidates and consultants, including all other individuals in respect of whom we have acquired personal information in connection with any candidate or consultant related services offered by us
Schedule 2	Data about our potential, existing and previous hirers, clients, client contacts (including directors, shareholders, consultants, employees or other personnel of our hirers, clients and client contacts) and all other individuals in respect of whom we have acquired personal information in connection with the supply of resourcing services
Schedule 3	Data about our suppliers and supplier personnel
Schedule 4	Data about individuals who apply for employment or work experience with us
Schedule 5	Data about our directors and staff, and former directors and staff and other individuals who spend time with us (such as consultants and secondees)
Schedule 6	Data about referees and emergency contacts

1.4 In addition to the above, individuals who interact with us in any of the above capacities should also refer to the following:

Schedule 7	Data collected about staff and visitors to our offices
Schedule 8	Data collected about visitors of our website or mobile applications

2. Definitions

2.1 The following references in this Privacy Policy have the following meanings:

2.1.1 candidate means a potential or actual candidate for a role with a client;

2.1.2 client and hirer mean any hiring organisation to which we offer and/or provide recruitment or resourcing services;

2.1.3 client contact means a hiring manager or procurer/recipient of temporary resourcing services at a client and;

2.1.4 consultant means a person (including any such persons via a personal services company or umbrella company) whose services are supplied via Auratus Recruitment Limited to work on temporary assignment with a hirer.

3. Data controller details

3.1 We are the data controller in relation to the processing of the personal information that you provide to us. Our contact details are as follows:

3.1.1 Address: 5th Floor, Peter House, Oxford Street, Manchester M1 5AN

3.1.2 Email address: DPO@humankind-recruitment.com (please include “Personal Data Request” in your subject heading to ensure it receives the correct attention).

3.2 Our Data Protection Officer is Debby Fox, who can be contacted at DPO@humankind-recruitment.com

4. What does Auratus Recruitment Limited do?

4.1 We provide permanent and temporary recruitment services to candidates to help them find roles, specialising in the fields of Marketing and Creative, IT, Professional Services, and Customer Services. We do this through assessing and matching people with potential opportunities.

4.2 We work with clients to provide recruitment and temporary resourcing services to help them fill requirements for specialist skills.

5. How we collect your information

5.1 Generally, the information we hold about you comes from the way you engage with us, for example by doing any of the following:

5.1.1 as a result of you registering with us via our website at www.humankind-recruitment.co.uk

5.1.2 as a result of you responding to an advertisement posted by us on a job board, online CV library or via social media;

5.1.3 as a result of us matching your CV, as uploaded by you onto a job board, online CV library or a social media site, to a vacancy we are seeking to fill for one of our clients;

5.1.4 taking part in surveys, posting on our message boards or blogs;

5.1.5 downloading information or participating in any other interactive areas that appear on our services;

5.1.6 providing us, or one of our partners, with information in the course of any marketing event;

5.1.7 interacting with us using social media;

5.1.8 in the course of us providing permanent and/or temporary recruitment and resourcing services to you (Services);

5.1.9 if you are an employee or potential employee, as a result of you providing your CV and information directly to us or via a third party such as a recruiter; and

5.1.10 contacting us offline, for example by telephone, SMS, email or by post.

5.2 We may also obtain personal data about you as a result of a personal recommendation, from a company website, from your business card, from information you have uploaded to LinkedIn and from credit reference agencies and fraud prevention agencies.

6. Sharing your information

6.1 Please note that personal information we are holding about you may be shared with and processed by:

6.1.1 any company within the Auratus Group (which includes Auratus Services UK Limited) for the purposes set out in this Privacy Policy only (e.g. internal administration and management purposes);

6.1.2 regulators or other third parties for the purposes of monitoring and/or enforcing our compliance with any legal and regulatory obligations, including statutory or regulatory reporting or the detection or prevention of unlawful acts;

6.1.3 credit reference and fraud prevention agencies;

6.1.4 any third party in the context of actual or threatened legal proceedings, provided we can do so lawfully (for example in response to a court order);

6.1.5 other parties and/or their professional advisers involved in a matter where required as part of the conduct of the services;

6.1.6 our own professional advisers and auditors for the purpose of seeking professional advice or to meet our audit responsibilities;

6.1.7 our service providers and agents (including their subcontractors) or third parties which process information on our behalf e.g:

6.1.7.1 if you are a client or candidate, internet service and platform providers, our bank, payment processing providers and those organisations we engage to help us send communications to you) so that they may help us to provide you with the applications, products, services and information you have requested; and

6.1.7.2 if you are an employee, director or consultant, data storage providers, typing service providers, administrative support, third party payroll processors, third party providers of benefits (such as childcare vouchers, life insurers, pension providers), audit providers and our bank;

6.1.8 when we are using your personal information in the context of our recruitment or resourcing services, then we will share your personal information with clients where we believe that you will be appropriate for a particular role or vacancy with that client;

6.1.9 to umbrella companies, personal service companies, when you inform us that you are supplying or intend to supply services via Auratus Recruitment Limited to a client via such company;

6.1.10 if you have applied for employment or work experience with us, to recruitment agencies to communicate offer details (if any);

6.1.11 where an organisation such as a managed service provider acts as a gateway for the supply of Services made via Auratus Recruitment Linited to the hirer, we will share your information with such organisations to the extent that it is necessary for the purposes of the supply;

6.1.12 third parties as part of the arrangements for any event for which you have expressed an interest in attending;

6.1.13 third parties such as social media and advertising sites for marketing purposes (with your consent), e.g. our partners and other third parties with whom we work and whose products or services we think will interest you; and

6.1.14 another organisation to whom we may transfer our agreement with you or if we sell or buy (or negotiate to sell or buy) our business or any of our assets (provided that adequate protections and safeguards are in place).

7. International transfers

We will not transfer personal data relating to you to a country which is outside the UK and European Economic Area (EEA) unless:

7.1 the country or recipient is covered by an adequacy decision of the Commission under GDPR Article 45;

7.2 appropriate safeguards have been put in place which meet the requirements of GDPR Article 46 (for example using the UK’s approved contractual clauses for transfers of personal data outside the UK and EEA); or

7.3 one of the derogations for specific situations under GDPR Article 49 is applicable to the transfer.These include (in summary):

7.3.1 the transfer is necessary to perform, or to form, a contract to which we are a party:

7.3.1.1 with you; or

7.3.1.2 with a third party where the contract is in your interests;

7.3.2 the transfer is necessary for the establishment, exercise or defence of legal claims;

7.3.3 you have provided your explicit consent to the transfer; or

7.3.4 the transfer is of a limited nature, and is necessary for the purpose of our compelling legitimate interests.

8. Retention of personal data

Our retention and deletion policy can be found at Schedule 9 of this Privacy Policy.

9. Your rights in respect of your personal data

9.1 You have certain rights under existing data protection laws, including the right to (upon written request) access a copy of your personal data that we are processing. In accordance with the GDPR:

9.1.1 you will have the following rights:

9.1.1.1 right to access: the right to request certain information about, access to and copies of the personal information about you that we are holding (please note that you are entitled to request one copy of the personal information that we hold about you at no cost, but for any further copies, we reserve the right to charge a reasonable fee based on administration costs). Please email DPO@humankind-recruitment.com if you wish to submit a data subject access request;

9.1.1.2 right to rectification: the right to have your personal information rectified if it is inaccurate or incomplete; and

9.1.2 in certain circumstances, you will also have the following rights:

9.1.2.1 right to erasure/“right to be forgotten”: the right to withdraw your consent to our processing of the data (if the legal basis for processing is based on your consent) and the right to request that we delete or erase your personal information from our systems (however, this will not apply if we are required to hold on to the information for compliance with any legal obligation or if we require the information to establish or defend any legal claim);

9.1.2.2 right to restriction of use of your information: the right to stop us from using your personal information or limit the way in which we can use it;

9.1.2.3 right to data portability: the right to request that we return any information you have provided in a structured, commonly used and machine-readable format, or that we send it directly to another company, where technically feasible; and

9.1.2.4 right to object: the right to object to our use of your personal information including where we use it for our legitimate interests or for marketing purposes.

9.2 Please note that if you withdraw your consent to the use of your personal information for purposes set out in our Privacy Policy, we may not be able to carry out our contractual obligations to you or provide you with access to all or certain parts of our services.

9.3 Auratus Recruitment Limited tries to meet the highest standards when collecting and using personal information. We take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate.If you wish to complain about this policy or any of the procedures set out in it, please contact us at:complaints@humankind-recruitment.com

9.4 You can also make a complaint to our supervisory body for data protection matters, the Information Commissioner's Office (ICO). You can find details of how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

10. Third party sites

Our website contains links to other websites operated by third parties.Please we are not responsible for personal information that third parties collect, store and use through their website.You should always read the privacy policy of each website you visit carefully.

11. Automatic decision making

We do not make decisions based solely on automated data processing, including profiling.

12. Security

12.1 We keep your information protected by taking appropriate technical and organisational measures to guard against unauthorised or unlawful processing, accidental loss, destruction or damage. For example:

12.1.1 where appropriate, data is encrypted when transiting on our system or stored on our databases;

12.1.2 we have implemented safeguards in relation to access and confidentiality in order to protect the information held within our systems; and

12.1.3 we frequently carry out risk assessments and audits to monitor and review threats and vulnerabilities to our systems to prevent fraud.

12.2 However, while we will do our best to protect your personal information, we cannot guarantee the security of your information which is transmitted via an internet or similar connection. It is important that all details of any username, password and/or other identification information created to access our servers are kept confidential by you and should not be disclosed to or shared with anyone.

12.3 In the event of a data breach or possible data breach, we will report this to our Data Protection Officer who will report it to the ICO within 72 hours of the breach being identified.

13. Changes to this Privacy Policy

We may amend this Privacy Policy from time to time, for example to keep it up to date, to implement minor technical adjustments and improvements or to comply with legal requirements. We will always update this Privacy Policy on our website, so please try to read it when you visit the website (the “last updated” reference tells you when we last updated our Privacy Policy).

Last updated March 2024

Schedule 1

Data about our potential, existing and previous candidates and consultants, including all other individuals in respect of whom we have acquired personal information in connection with any candidate or consultant related services offered by us

What we collect:	We may use your information for the following purposes, based on the following legal grounds:
· Contact details such as your name, home/work addresses, email address, landline/mobile phone or fax numbers. · Employment related information and qualifications information such as your CV, position/title, current and previous employers, your education, academic record and professional specialisms and qualifications, reference information, right to work status, salary and benefits, references and other information related to your employment history. · Payment information including your bank account details. · Personal information such as professional and personal interests and languages spoken; details of your referees and emergency contacts. · Identification information such as details included in copy personal photographs and ID documents we receive e.g. passports/driving licence. · Visa documentation (right to work in the UK). · Timesheets: the contract for services we hold with your umbrella company or personal service company relating to the work you do or will do for our client, including timesheet data and charge rates relating to the work you perform under that contract.	· If it is necessary for the performance of our contract or for the purposes of entering into a contract: for the purpose of carrying services at your request including liaising with you and potential clients/hirers in order to find an employment or temporary role for you. · If it is in our legitimate interests to do so: o for internal record keeping for administration purposes; o for insight purposes (e.g. market research for internal use, to analyse market trends and demographics, and develop the service which we offer to you or other individuals in the future) and sending information to you about products and services which we think may be of interest to you for marketing purposes; o so that we can contact you (via email, SMS or phone) about opportunities and assignments that we believe you will be interested in; o to help us to provide suitable candidates and consultants for our clients who engage us to assist them fulfil their recruitment and resourcing requirements; o to provide a channel through which you can submit your CV for general applications, to apply for specific jobs or to subscribe to our job alerts; o to match your details with vacancies, to assist us in finding a position that is most suitable; o to enter into contracts which are necessary in order for your service to be supplied or made available to a hirer; o to provide recruitment-related support; o to develop an industry-relevant database of candidates and clients to help meet our clients' resourcing requirements and connect candidates with work opportunities; o for internal record keeping purposes; o to carry out services that we, you or our client have requested including work-related references, qualifications and criminal references checking services, verification of the details you have provided from third party sources, psychometric evaluations or skills tests; o to inform you of Auratus Recruitment Limited networking and other career-development related events; and o to contact you about roles which we think will be of interest to you, now or in the future, where we do not believe that this storage and use will unduly prejudice your rights or freedoms. · If it is in our legitimate interests to do so: where you are successful in securing temporary assignment work with one of our clients we will store and use your personal information for the purposes of completing and administering contracts with your chosen personal service company or umbrella company and for processing payment to such company in respect of services you have performed for our client. Such processing will be for our legitimate interests so that we can provide services to you and our client.We do not believe that this storage and use of your personal information will unduly prejudice your rights or freedoms. · With your consent: We will send your information to clients for potential jobs. Please note that we will always obtain verbal or written consent before presenting your personal details to a client. · Compliance with a legal obligation: in order to prevent fraud or money laundering or to comply with any other legal or regulatory requirements to which Auratus Recruitment Limited is subject, including but not limited to carrying out: o verification of your identity to comply with The Conduct of Employment Agencies and Employment Businesses Regulations 2003; and o right to work checks to comply with relevant immigration legislation.
· Information about criminal convictions and offences · Special category data such as information about race or ethnicity, health and religious information	· With your consent: o We may carry out background checks (criminal history) if requested by a client or hirer and will share this information with the relevant client/hirer. o We do not ordinarily collect special categories of information, however, if our client requires us to collect, store and use your health data and/or any other special category data we will, on our client's behalf, seek your consent to processing such data. · You can withdraw your consent at any stage but this may prevent us from being able to deliver our recruitment services to you.

What we collect:

We may use your information for the following purposes, based on the following legal grounds:

· Contact details such as your name, home/work addresses, email address, landline/mobile phone or fax numbers.

· Employment related information and qualifications information such as your CV, position/title, current and previous employers, your education, academic record and professional specialisms and qualifications, reference information, right to work status, salary and benefits, references and other information related to your employment history.

· Payment information including your bank account details.

· Personal information such as professional and personal interests and languages spoken; details of your referees and emergency contacts.

· Identification information such as details included in copy personal photographs and ID documents we receive e.g. passports/driving licence.

· Visa documentation (right to work in the UK).

· Timesheets: the contract for services we hold with your umbrella company or personal service company relating to the work you do or will do for our client, including timesheet data and charge rates relating to the work you perform under that contract.

· If it is necessary for the performance of our contract or for the purposes of entering into a contract: for the purpose of carrying services at your request including liaising with you and potential clients/hirers in order to find an employment or temporary role for you.

· If it is in our legitimate interests to do so:

o for internal record keeping for administration purposes;

o for insight purposes (e.g. market research for internal use, to analyse market trends and demographics, and develop the service which we offer to you or other individuals in the future) and sending information to you about products and services which we think may be of interest to you for marketing purposes;

o so that we can contact you (via email, SMS or phone) about opportunities and assignments that we believe you will be interested in;

o to help us to provide suitable candidates and consultants for our clients who engage us to assist them fulfil their recruitment and resourcing requirements;

o to provide a channel through which you can submit your CV for general applications, to apply for specific jobs or to subscribe to our job alerts;

o to match your details with vacancies, to assist us in finding a position that is most suitable;

o to enter into contracts which are necessary in order for your service to be supplied or made available to a hirer;

o to provide recruitment-related support;

o to develop an industry-relevant database of candidates and clients to help meet our clients' resourcing requirements and connect candidates with work opportunities;

o for internal record keeping purposes;

o to carry out services that we, you or our client have requested including work-related references, qualifications and criminal references checking services, verification of the details you have provided from third party sources, psychometric evaluations or skills tests;

o to inform you of Auratus Recruitment Limited networking and other career-development related events; and

o to contact you about roles which we think will be of interest to you, now or in the future, where we do not believe that this storage and use will unduly prejudice your rights or freedoms.

· If it is in our legitimate interests to do so: where you are successful in securing temporary assignment work with one of our clients we will store and use your personal information for the purposes of completing and administering contracts with your chosen personal service company or umbrella company and for processing payment to such company in respect of services you have performed for our client. Such processing will be for our legitimate interests so that we can provide services to you and our client.We do not believe that this storage and use of your personal information will unduly prejudice your rights or freedoms.

· With your consent: We will send your information to clients for potential jobs. Please note that we will always obtain verbal or written consent before presenting your personal details to a client.

· Compliance with a legal obligation: in order to prevent fraud or money laundering or to comply with any other legal or regulatory requirements to which Auratus Recruitment Limited is subject, including but not limited to carrying out:

o verification of your identity to comply with The Conduct of Employment Agencies and Employment Businesses Regulations 2003; and

o right to work checks to comply with relevant immigration legislation.

· Information about criminal convictions and offences

· Special category data such as information about race or ethnicity, health and religious information

· With your consent:

o We may carry out background checks (criminal history) if requested by a client or hirer and will share this information with the relevant client/hirer.

o We do not ordinarily collect special categories of information, however, if our client requires us to collect, store and use your health data and/or any other special category data we will, on our client's behalf, seek your consent to processing such data.

· You can withdraw your consent at any stage but this may prevent us from being able to deliver our recruitment services to you.

Schedule 2

Data about our potential, existing and previous hirers, clients, client contacts (including directors, shareholders, consultants, employees or other personnel of our hirers, clients and client contacts) and all other individuals in respect of whom we have acquired personal information in connection with the supply of resourcing services

What we collect:	We may use your information for the following purposes, based on the following legal grounds:
· Contact details such as your name, home/work addresses, email address, landline/mobile phone or fax numbers. · Employment information such as your position/title, employment history, professional specialisms and qualifications. · Other relevant information that you may provide when you engage us to source candidates or consultants for you.	· If it is necessary for the performance of our contract or for the purposes of entering into a contract: for the purpose of negotiating and entering into contractual agreements with you, for the purpose of making or receiving payments in the course of providing our services and in the course of providing our services as a specialist recruitment agency, such as presenting roles or candidate profiles that may be of interest to you and managing the recruitment and interview process for candidates. In the case of contacts at umbrella companies and personal service companies, we will store information so we can contact you to provide details of current and future assignments, related timesheet data and payment details. · If it is in our legitimate business interests to do so: for internal record keeping for administration purposes, for the purpose of communications in relation to establishing a client relationship, obtaining evidence of identity of our clients, communications regarding our service and fees, for insight purposes (e.g. to analyse market trends and demographics, and develop the service which we offer to you or other individuals in the future) and sending information to you about products and services which we think may be of interest to you for marketing purposes. · Compliance with a legal obligation: in order to prevent fraud or money laundering or to comply with any other legal or regulatory requirements.

What we collect:

We may use your information for the following purposes, based on the following legal grounds:

· Contact details such as your name, home/work addresses, email address, landline/mobile phone or fax numbers.

· Employment information such as your position/title, employment history, professional specialisms and qualifications.

· Other relevant information that you may provide when you engage us to source candidates or consultants for you.

· If it is necessary for the performance of our contract or for the purposes of entering into a contract: for the purpose of negotiating and entering into contractual agreements with you, for the purpose of making or receiving payments in the course of providing our services and in the course of providing our services as a specialist recruitment agency, such as presenting roles or candidate profiles that may be of interest to you and managing the recruitment and interview process for candidates. In the case of contacts at umbrella companies and personal service companies, we will store information so we can contact you to provide details of current and future assignments, related timesheet data and payment details.

· If it is in our legitimate business interests to do so: for internal record keeping for administration purposes, for the purpose of communications in relation to establishing a client relationship, obtaining evidence of identity of our clients, communications regarding our service and fees, for insight purposes (e.g. to analyse market trends and demographics, and develop the service which we offer to you or other individuals in the future) and sending information to you about products and services which we think may be of interest to you for marketing purposes.

· Compliance with a legal obligation: in order to prevent fraud or money laundering or to comply with any other legal or regulatory requirements.

Schedule 3
Data about suppliers and supplier personnel

What we collect:	We may use your information for the following purposes, based on the following legal grounds:
· Contact details such as your name, home/work addresses, email address, landline/mobile phone or fax numbers. · Employment information such as your position/title, employment history, professional specialisms and qualifications.	· If it is necessary for the performance of our contract or for the purposes of entering into a contract: for the purpose of negotiating and entering into contractual agreements with you, in the course of receiving services from you e.g. contacting individuals where we need to do so to provide instructions and discuss work involved. · If it is in our legitimate business interests to do so: for internal record keeping for administration purposes, for the purpose of communications in relation to establishing a supplier relationship, obtaining evidence of identity of our suppliers, communications regarding our service and fees, for insight purposes (e.g. to analyse market trends and demographics, and develop the service which we offer to you or other individuals in the future) and sending information to you about products and services which we think may be of interest to you for marketing purposes. · Compliance with a legal obligation: in order to prevent fraud or money laundering or to comply with any other legal or regulatory requirements.
· Identification information contained in or provided to us as part of our supplier ID checks. This includes details included in copy personal photo and ID documents we receive.	· Compliance with a legal obligation: in order to prevent fraud or money laundering or to comply with any other legal or regulatory requirements.

What we collect:

We may use your information for the following purposes, based on the following legal grounds:

· Contact details such as your name, home/work addresses, email address, landline/mobile phone or fax numbers.

· Employment information such as your position/title, employment history, professional specialisms and qualifications.

· If it is necessary for the performance of our contract or for the purposes of entering into a contract: for the purpose of negotiating and entering into contractual agreements with you, in the course of receiving services from you e.g. contacting individuals where we need to do so to provide instructions and discuss work involved.

· If it is in our legitimate business interests to do so: for internal record keeping for administration purposes, for the purpose of communications in relation to establishing a supplier relationship, obtaining evidence of identity of our suppliers, communications regarding our service and fees, for insight purposes (e.g. to analyse market trends and demographics, and develop the service which we offer to you or other individuals in the future) and sending information to you about products and services which we think may be of interest to you for marketing purposes.

· Compliance with a legal obligation: in order to prevent fraud or money laundering or to comply with any other legal or regulatory requirements.

· Identification information contained in or provided to us as part of our supplier ID checks. This includes details included in copy personal photo and ID documents we receive.

· Compliance with a legal obligation: in order to prevent fraud or money laundering or to comply with any other legal or regulatory requirements.

Schedule 4
Data about individuals who apply for employment or work experience with us

What we collect	We may use your information for the following purposes, based on the following legal grounds:
· Contact details such as names, home and work addresses, landline/mobile phone or fax numbers, email addresses, previous addresses.	Our legitimate interest in processing such information for contacting individuals where we need to do so and for obtaining/verifying evidence of identity.
· Employment related history and qualifications information such as position/title, date of birth, employment history and CV, references from previous employees, professional specialisms, education and qualifications, salary and benefits, disciplinary record.	Our legitimate interest in processing such information for assessing your suitability for the role, or considering potential packages and offers.
· Personal information such as professional and personal interests and languages spoken.	Our legitimate interest in processing such information for assessing your suitability for the role.
· Information contained in or provided to us as part of our recruitment or take on process such as details included in copy personal photographs and residential ID documents we receive. · Visa documentation (right to work in the UK).	Our legitimate interest in processing such information for obtaining/verifying evidence of identity. Compliance with a legal obligation in order to confirm that the individual is entitled to work in the UK and for the purpose of security and prevention of crime.
· “Special categories of information” such as: information about your race or ethnicity; and · Information about unspent convictions.	We will use such information in the following ways where it is necessary for the performance of our contract, to protect your vital interests, to comply with our legal obligations or where it is in our legitimate interests, and based on the following legal grounds under the Data Protection Act 2018: · Pursuant to Schedule 1, Part 2(8) of the Data Protection Act 2018, we may use information about your race or national or ethnic origin, for the purpose of identifying or keeping under review the existence or absence of equality of opportunity or treatment. · Pursuant to Schedule 1, Part 1(1)(1) of the Data Protection Act 2018, we consider and process information about unspent convictions under our rights conferred by law in connection with employment (Exceptions Order to the Rehabilitation of Offenders Act 1974). · Consent: we do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. · In limited circumstances we may approach you for your written consent to allow us to process certain particularly sensitive or other personal data (such as if we need to disclose it to certain recipients). If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us. · In accordance with Schedule 1, Part 4, S.39 of the Data Protection Act 2018, Auratus Recruitment Limited · Retains a policy document and records of processing of all special category and criminal convictions data collected.

Schedule 5

Data about our directors and staff, consultants, secondees, those on work experience, temporary staff, former directors and staff, next of kin, spouses, beneficiaries

What we collect	We may use your information for the following purposes, based on the following legal grounds:
· Contact details (work) such as name, work address, landline/mobile phone or fax numbers, email address. · Contact details (personal) and other personal information such as home address, landline/mobile phone number, email address, previous addresses, emergency contact details, date of birth, marital status, next of kin, spouse, beneficiaries’ names and contact details.	· Necessary for the performance of our contract in our capacity as your employer. · Necessary to protect the vital interests of the individual concerned for the purposes of security and prevention of crime. · Our legitimate interest in processing such information (work contact details) for contacting individuals where we need to do so in the individual’s capacity as employee, director or other member of staff. · Our legitimate interest in processing such information (personal contact details) for the purpose of contacting individuals where we need to do so in the individual’s capacity as employee, director/shareholder or other member of staff, in order to keep appropriate employment records, for obtaining/verifying evidence of identity or for contacting next of kin, spouses and beneficiaries if the circumstances require (such as in an emergency). · Compliance with a legal obligation to comply with right to work legislation.
“Special categories of information” such as: · Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions; and · Information about your health, including any medical condition, health and sickness records such as details of any absences (other than holidays) from work including time on statutory parental leave and sick leave.	We will use such information in the following ways where it is necessary for the performance of our contract, to protect your vital interests, to comply with our legal obligations or where it is in our legitimate interests, and based on the following legal grounds under the Data Protection Act 2018: · Pursuant to Schedule 1, Part 1(1)(1) of the Data Protection Act 2018, we will use information relating to leaves of absence, which may include sickness absence or family related leaves, to comply with employment and other laws and where it is in our legitimate interest to do so for operational purposes.We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits including statutory maternity pay and statutory sick pay. · Pursuant to Schedule 1, Part 2(8) of the Data Protection Act 2018 and where it is in our legitimate interest, we may use information about your race or national or ethnic origin, for the purpose of identifying or keeping under review the existence or absence of equality of opportunity or treatment. · We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. · In limited circumstances such as where we need to obtain medical records from your GP in the event of long-term sickness, we may approach you for your written consent to allow us to process certain particularly sensitive or other personal data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us. · In accordance with Schedule 1, Part 4, S.39 of the Data Protection Act 2018, Auratus Recruitment Limited retains a policy document and records of processing of all special category and criminal convictions data collected.
· Employment and performance related information such as position/title, date of birth, employment history and CV, references from previous employees, professional specialisms, education and qualifications, salary and benefits, disciplinary records, performance records, appraisals, performance feedback, interview notes, languages spoken, practising certificate details and caveats, professional indemnity information, working patterns (days worked and non-work days).	· Necessary for the performance of the employment contract in order to keep appropriate employment records and carry out our contractual obligations as employer. · Our legitimate interest in processing such information in order to keep appropriate employment records, for assessing their continued suitability for their role and for planning progression.
· Payment and financial information such as bank details, transaction history, salary and benefits, life insurance, pension related information, tax-related information, National Insurance number, payroll documentation (P45 / P60 / P11D).	· Necessary for the performance of the employment contract to pay or compensate the individual. · Our legitimate interest in processing such information in order to keep appropriate employment records and to allow the individual to receive pension and other benefits. · Consent in order to allow nominated family members or beneficiaries to receive benefits or insurance funds.
· Information contained in or provided to us as part of our recruitment or take on process such as details included in copy personal photographs and ID documents we receive. · Visa documentation (right to work in the UK).	· Our legitimate interest in processing such information for obtaining/verifying evidence of identity. · Compliance with a legal obligation in order to confirm that the individual is entitled to work in the UK and for the purpose of security and prevention of crime.
· Monitoring information such as images via CCTV, entrance/exit dates/times, movement within the building via security card system.	· Our legitimate interest in maintaining a safe environment and in preventing and detecting crime. · Necessary to protect the vital interests of the individual concerned: for security purposes and in order to maintain a safe environment. · Compliance with a legal obligation: in order to prevent fraud or money laundering or to comply with any other legal or regulatory requirements.

What we collect

We may use your information for the following purposes, based on the following legal grounds:

· Contact details (work) such as name, work address, landline/mobile phone or fax numbers, email address.

· Contact details (personal) and other personal information such as home address, landline/mobile phone number, email address, previous addresses, emergency contact details, date of birth, marital status, next of kin, spouse, beneficiaries’ names and contact details.

· Necessary for the performance of our contract in our capacity as your employer.

· Necessary to protect the vital interests of the individual concerned for the purposes of security and prevention of crime.

· Our legitimate interest in processing such information (work contact details) for contacting individuals where we need to do so in the individual’s capacity as employee, director or other member of staff.

· Our legitimate interest in processing such information (personal contact details) for the purpose of contacting individuals where we need to do so in the individual’s capacity as employee, director/shareholder or other member of staff, in order to keep appropriate employment records, for obtaining/verifying evidence of identity or for contacting next of kin, spouses and beneficiaries if the circumstances require (such as in an emergency).

· Compliance with a legal obligation to comply with right to work legislation.

“Special categories of information” such as:

· Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions; and

· Information about your health, including any medical condition, health and sickness records such as details of any absences (other than holidays) from work including time on statutory parental leave and sick leave.

We will use such information in the following ways where it is necessary for the performance of our contract, to protect your vital interests, to comply with our legal obligations or where it is in our legitimate interests, and based on the following legal grounds under the Data Protection Act 2018:

· Pursuant to Schedule 1, Part 1(1)(1) of the Data Protection Act 2018, we will use information relating to leaves of absence, which may include sickness absence or family related leaves, to comply with employment and other laws and where it is in our legitimate interest to do so for operational purposes.We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits including statutory maternity pay and statutory sick pay.

· Pursuant to Schedule 1, Part 2(8) of the Data Protection Act 2018 and where it is in our legitimate interest, we may use information about your race or national or ethnic origin, for the purpose of identifying or keeping under review the existence or absence of equality of opportunity or treatment.

· We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law.

· In limited circumstances such as where we need to obtain medical records from your GP in the event of long-term sickness, we may approach you for your written consent to allow us to process certain particularly sensitive or other personal data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

· In accordance with Schedule 1, Part 4, S.39 of the Data Protection Act 2018, Auratus Recruitment Limited retains a policy document and records of processing of all special category and criminal convictions data collected.

· Employment and performance related information such as position/title, date of birth, employment history and CV, references from previous employees, professional specialisms, education and qualifications, salary and benefits, disciplinary records, performance records, appraisals, performance feedback, interview notes, languages spoken, practising certificate details and caveats, professional indemnity information, working patterns (days worked and non-work days).

· Necessary for the performance of the employment contract in order to keep appropriate employment records and carry out our contractual obligations as employer.

· Our legitimate interest in processing such information in order to keep appropriate employment records, for assessing their continued suitability for their role and for planning progression.

· Payment and financial information such as bank details, transaction history, salary and benefits, life insurance, pension related information, tax-related information, National Insurance number, payroll documentation (P45 / P60 / P11D).

· Necessary for the performance of the employment contract to pay or compensate the individual.

· Our legitimate interest in processing such information in order to keep appropriate employment records and to allow the individual to receive pension and other benefits.

· Consent in order to allow nominated family members or beneficiaries to receive benefits or insurance funds.

· Information contained in or provided to us as part of our recruitment or take on process such as details included in copy personal photographs and ID documents we receive.

· Visa documentation (right to work in the UK).

· Our legitimate interest in processing such information for obtaining/verifying evidence of identity.

· Compliance with a legal obligation in order to confirm that the individual is entitled to work in the UK and for the purpose of security and prevention of crime.

· Monitoring information such as images via CCTV, entrance/exit dates/times, movement within the building via security card system.

· Our legitimate interest in maintaining a safe environment and in preventing and detecting crime.

· Necessary to protect the vital interests of the individual concerned: for security purposes and in order to maintain a safe environment.

· Compliance with a legal obligation: in order to prevent fraud or money laundering or to comply with any other legal or regulatory requirements.

Schedule 6
Referees and emergency contacts

What we collect:	We may use your information for the following purposes, based on the following legal grounds:
· Contact details such as name, title, address email and telephone number	· If it is in our legitimate business interests to do so: so that we can contact you for a reference or as an emergency contact for one of our candidates or consultants.

Schedule 7
Data about visitors to our offices

What we collect:	We may use your information for the following purposes, based on the following legal grounds:
· Monitoring information such as images via CCTV, entrance/exit dates/times, movement within the building via security card system. · Dietary preferences (if catering is arranged).	· If it is in our legitimate business interests to do so: for security purposes and pursuant to our legitimate interest in maintaining a safe environment, for the purpose of confirming attendance/location of the individual, for determining contract performance (in the case of employees and suppliers), and for use where catering is arranged (in the case of dietary preferences). · Necessary to protect the vital interests of the individual concerned: for security purposes and in order to maintain a safe environment. · Compliance with a legal obligation: in order to prevent fraud or money laundering or to comply with any other legal or regulatory requirements.

What we collect:

We may use your information for the following purposes, based on the following legal grounds:

· Monitoring information such as images via CCTV, entrance/exit dates/times, movement within the building via security card system.

· Dietary preferences (if catering is arranged).

· If it is in our legitimate business interests to do so: for security purposes and pursuant to our legitimate interest in maintaining a safe environment, for the purpose of confirming attendance/location of the individual, for determining contract performance (in the case of employees and suppliers), and for use where catering is arranged (in the case of dietary preferences).

· Necessary to protect the vital interests of the individual concerned: for security purposes and in order to maintain a safe environment.

· Compliance with a legal obligation: in order to prevent fraud or money laundering or to comply with any other legal or regulatory requirements.

Schedule 8
Data about visitors to our website or mobile applications

What we collect:	We may use your information for the following purposes, based on the following legal grounds:
· Contact information (including your name and email address)	· Where we have obtained consent: We may use your information to send marketing communications to you. Our site operates a marketing/subscription-based email system, used to inform subscribers about information supplied by our site. Users can subscribe through an online automated process should they wish to do so but do so at their own discretion. Some subscriptions will be manually processed through prior written agreement with the user. · You can request to unsubscribe from job alerts and marketing materials at any time.
· Technical and device information/social networks	· If it is in our legitimate business interests to do so: we may use certain technical log data (such as your IP address) for research or statistical purposes; to analyse user traffic and for ensuring the proper administration of our site; for analytics and insight purposes e.g. to monitor market trends and demographics and to improve the user experience within our site; and to ensure that content from our site is presented in the most effective manner for you and for your computer or other device from which you access our site and/or the services we offer through the site.
· Cookies (and other web-tracking technology)	· We may use “cookies” and other anonymous web tracking technologies (such as “web beacon” and “pixel tags”) implemented by us or by third party service providers. A cookie is a small file of letters and numbers that is sent to your device when you visit our site, allowing our site to recognise your browser if you revisit it. Cookies may store your online preferences and other information about the interaction you make in the site. Please refer to our Cookie Policy https://www.humankind-recruitment.com/legal_documents/cookies for more information about the type of cookies used and how we use cookies/tracking technologies within our site. · Where we collect “essential” cookies (such as functionality cookies) we will rely on the legitimate interest ground. We will only collect and process “non-essential” cookies (such as analytics and advertising cookies) where your consent has been obtained.

Schedule 9
Retention and deletion policy

Unless we are required or permitted by law to hold on to your information for a specific retention period, we may retain your information for the following purposes and periods:

Category of personal data	Period for which personal data will be stored
· Data about our candidates, consultants, clients, business contacts, visitors of our website and third parties involved in matters in relation to which we provide services to our clients.	Contracts and general correspondence (emails, post and other communications) obtained in the course of providing our services: Such information will be stored for 6 years following completion of the services or termination or expiry of the contract with our client (whichever is later). Contact details for marketing purposes: Contact information relating to clients and contacts will be held for so long as we believe the information to remain accurate and the individual concerned remains a genuine connection of ours, or of one of our directors and staff. We have a programme for reviewing our contacts regularly, and removing any information which is considered to be out of date or no longer relevant.
· Data about our suppliers and supplier personnel.	Contracts and general correspondence (emails, post and other communications) obtained in the course of providing your services: Such information will be stored for 7 years following completion of the services or termination or expiry of your contract (whichever is later).
· Referees and emergency contacts	Personal data obtained in respect of referees and emergency contacts will be deleted after 1 month after exit
· Data about individuals who apply for employment or work experience with us	Personal data obtained from employment or work experience applicants will be deleted after 2 years.
· Data about our directors and staff, former directors and staff and other individuals who spend time with us (such as consultants and secondees).	Unless required to be retained pursuant to any applicable laws: · Human resources (HR) records will be destroyed 7 years following employment.For the purposes of administration this will be actioned [annually] in [December] of each year; and · Personal data stored in private workspaces created for members of HR (including for appraisals, promotion and probation reviews) will be deleted 7 years after creation.

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