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Data Processing Policy

Effective Date: 1st October 2025
Approved By: Leanne Divertie, National Operations Manager
Version: 1.0

1. Purpose

This Data Processing Policy outlines how TLH Recruitment New Zealand (“TLH”, “we”, “us”, “our”) collects, uses, stores, discloses, and protects personal information in accordance with the Privacy Act 2020 and the Information Privacy Principles (IPPs).

The policy ensures transparency, supports safe handling of candidate and client data, and reinforces TLH’s commitment to protecting privacy at every stage of the recruitment and employment process.

2. Scope

This policy applies to:

  • All TLH Recruitment NZ employees, consultants, and contractors
  • All candidate and client personal information processed by TLH
  • All data processing systems (electronic, cloud-based, and hard copy)
  • Any third-party provider acting on behalf of TLH


This policy covers the full lifecycle of personal information collected for recruitment, employment placement, onboarding, compliance, and client service delivery.

3. Types of Personal Information Collected

TLH may collect and process the following categories of personal information:

Data Collection and Processing

TLH Recruitment collects and processes personal data for the following purposes:

3.1 Candidate Information

  • Name, date of birth, contact details
  • CV, employment history, qualifications, licences
  • Right to work and identity documents
  • Reference check details
  • Criminal record check results (when legally permitted)
  • Medical or fitness-for-work information (where necessary and with consent)
  • Timesheets, pay details, tax information
  • Emergency contact information
 
3.2 Client Information
  • Contact names, job titles, business addresses
  • Billing information
  • Job orders and workforce requirements
  • Communication records
 
3.3 Website & System Data
  • IP addresses
  • Device information
  • Browsing behaviour
  • Online enquiries or form submissions

4. Lawful Basis for Processing Data

TLH Recruitment NZ processes personal information only where lawful and necessary, including:

  • Consent (e.g., candidate permission to store and use their CV)
  • Performance of a contract (e.g., payroll, work placement processing)
  • Legal obligations (e.g., immigration checks, IRD requirements)
  • Legitimate business interests (e.g., recruitment matching and workforce coordination)
  • Employment-related reasons (e.g., safety, onboarding, inductions)

5. How Personal Information Is Used

Personal information is used for the following purposes:

  • Recruitment and talent matching
  • Conducting right-to-work and background checks
  • Workforce scheduling, rostering, and assignments
  • Payroll processing and billing
  • Managing workplace incidents, safety checks, and compliance
  • Maintaining communication with candidates and clients
  • Improving TLH services, systems, and client relationships
  • Meeting legal and regulatory obligations
    TLH will not use personal information for reasons not disclosed in this policy without consent or a
    lawful requirement.

6. Data Storage and Security

TLH takes all reasonable steps to protect information from loss, unauthorised access, misuse, alteration, or disclosure.

Security measures include:

  • Encrypted cloud storage
  • Restricted access based on job role
  • Multi-factor authentication (MFA)
  • Password protection
  • Secure destruction of hard-copy documents
  • Vendor security assessments for third-party systems
  • Staff training in privacy and data protection

7. Data Sharing & Disclosure

TLH may share personal information only when appropriate and lawful:

7.1 With Clients
To assess suitability for a role or confirm employment details.

7.2 With Third-Party Providers

Such as:

  • Payroll services
  • Criminal record check providers
  • Training and induction platforms
  • IT and software partners
  • Insurance providers (e.g., injury managementAll third-party partners must meet TLH’s security and privacy requirements.

7.3 Legal or Regulatory Requirements
Where required under New Zealand law, including:

  • WorkSafe NZ
  • Immigration New Zealand
  • Inland Revenue (IRD)
  • New Zealand Police (when legally permitted)

TLH will never sell personal information to external parties.

8. Data Retention & Disposal

Personal information is held only for as long as needed for lawful business purposes.

Typical retention periods:

  • Candidate records: up to 6 years after last activity
  • Payroll & tax records: 7 years (legal requirement)
  • Health & safety records: as required under H&S legislation
  • Job applications: up to 12 months if not placed

When information is no longer required, TLH securely destroys or anonymises it.

9. Rights of Individuals

Under the Privacy Act 2020, all individuals have the right to:

  • Request access to their personal information
  • Request correction of inaccurate or outdated information
  • Withdraw consent (where applicable)
  • Lodge a complaint with TLH or the Office of the Privacy Commissioner

TLH must respond to access or correction requests within 20 working days.

10. Data Breach Response

In line with the Privacy Act 2020 notification requirements:

If TLH experiences a data breach that may cause serious harm, we will:

  1. Immediately investigate the breach
  2. Contain the incident
  3. Notify affected individuals as soon as practicable
  4. Notify the Office of the Privacy Commissioner
  5. Take corrective action to prevent future breaches
  6. Review and document the incident

11. Staff Responsibilities

All TLH employees must:

  • Complete privacy and data handling training
  • Report any suspected breaches immediately
  • Follow internal procedures for secure storage and disposal
  • Only access data necessary for their role
  • Treat all personal information confidentially

Breach of this policy may result in disciplinary action.

12. Contact Details

Questions, complaints, or requests regarding this policy can be directed to:

Privacy Officer – TLH Recruitment New Zealand
Email: [email protected]
Phone: 0800 300 155
Address: 155 Fanshawe Street, Auckland CBD, NZ

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