PRIVACY POLICY

Last Updated: July 10, 2025

1. Introduction

Fortis Recruitment Limited ("we," "our," or "us") is committed to protecting the privacy of your personal information. This Privacy Policy outlines how we collect, hold, use, and disclose your personal information in accordance with the New Zealand Privacy Act 2020 ("the Act") and other applicable laws.

By using our website, services, or providing us with your personal information, you consent to the practices described in this Privacy Policy. We encourage you to read this policy carefully.

2. Who This Policy Applies To

This policy applies to:

Individuals seeking employment or contract assignments ("Candidates").
Clients seeking to fill vacancies ("Clients").
Referees providing information about Candidates.
Visitors to our website.
Suppliers and their employees/contractors.
Our own prospective employees, employees, and contractors.
Anyone else who interacts with us where personal information is collected.

3. What Personal Information We Collect

We collect personal information that is necessary for us to provide our recruitment services and operate our business. The types of personal information we may collect include:

For Candidates:

Contact Information: Name, address, email address, phone numbers.
Identification & Eligibility: Date of birth, gender, passport, visa details, work eligibility in New Zealand.
Employment Information: CV/Resume, cover letter, employment history, education, qualifications, professional memberships, skills, work performance, career aspirations, salary expectations.
Reference Information: Details of referees (name, contact details, job title, and their confidential opinions about your suitability for roles).
Background Checks (where relevant and lawful): Results of criminal convictions checks, credit history checks (for finance roles), and medical history (position-related), psychometric test results.
Communication Data: Records of your interactions with us, including emails, phone calls, and interview notes.
Sensitive Information (only where necessary and with explicit consent): This may include health information (for roles requiring specific physical abilities or to accommodate disabilities), or information related to equal opportunities monitoring (e.g., ethnicity, if provided voluntarily and anonymised for statistical purposes).

For Clients:

Contact Information: Name, job title, company name, address, email address, phone numbers.
Organisational Needs: Details of your business, hiring requirements, and confidential feedback regarding Candidates.
Financial Information: Billing and payment details.

For Referees:

Contact Information: Name, job title, company name, address, email address, phone numbers.
Opinions: Your confidential opinions about a Candidate's skills, experience, and suitability for work.

For Website Visitors:

Technical Data: IP address, browser type, operating system, referring URLs, and website usage data (collected through cookies and analytics tools). This information is generally aggregated and does not directly identify you.

4. How We Collect Personal Information

We collect personal information in various ways, including:

Directly from you: When you register on our website, apply for a job, submit your CV, attend interviews, communicate with us via phone, email, or in person.
From third parties:
- From Clients who provide your details for recruitment purposes.
- From Referees whom you have nominated.
- From publicly available sources such as LinkedIn, professional networking sites, and company websites.
- From other recruitment service providers or talent sourcing platforms.
- From third-party service providers who assist us with pre-employment screening and testing.
Through our website: Via online forms, cookies, and website analytics.

5. How We Use Your Personal Information

We use your personal information for the following purposes:

Recruitment Services: To match Candidates with suitable job opportunities, assess suitability, process applications, and facilitate the recruitment process.
Client Management: To understand Client needs, provide recruitment solutions, and manage our business relationship.
Communication: To communicate with you regarding job opportunities, applications, services, and updates.
Verification: To confirm your identity, qualifications, employment history, and eligibility to work in New Zealand.
Marketing: To provide you with information about our services, market insights, and job alerts that may be of interest to you (you can opt-out at any time).
Business Operations: To conduct our business activities, improve our services, for internal record keeping, and for staff management.
Legal Compliance: To comply with our legal obligations, including health and safety requirements, and to respond to lawful requests from government agencies or courts.
Risk Management: For fraud prevention and to protect our rights and interests, or those of others.

6. Disclosure of Personal Information

We may disclose your personal information to the following parties:

Clients: With your consent, we will share your personal information (e.g., CV, application details) with our Clients for potential employment opportunities.
Referees: To contact individuals you have nominated as referees for the purpose of obtaining references.
Service Providers: Third-party service providers who assist us in providing our services, such as:
- Hosting and data storage providers.
- Applicant tracking systems and recruitment software providers.
- Background check and screening service providers.
- Payroll and timesheet providers (for contract/temp roles).
- Marketing and analytics service providers.
- Professional advisors (e.g., lawyers, accountants).
Government and Regulatory Bodies: Where required by law, court order, or to comply with regulatory obligations (e.g., IRD, Immigration New Zealand).
Law Enforcement: If we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law.
Related Entities: To other companies within the Fortis Recruitment group (if applicable) for the purposes outlined in this policy.

We will not sell or rent your personal information to third parties for their marketing purposes without your explicit consent.

7. International Data Transfers

As Fortis Recruitment Limited operates internationally (based on your website content indicating locations like Hong Kong, London, New York, Singapore), please note that your personal information may be transferred to, stored, and processed in countries outside of New Zealand where our clients, service providers, or related entities are located.

When we transfer your personal information overseas, we will take reasonable steps to ensure that the recipient is subject to privacy laws that provide comparable safeguards to the New Zealand Privacy Act 2020, or that we have put in place appropriate safeguards (e.g., contractual clauses) to protect your privacy.

8. Data Quality and Security

We take reasonable steps to ensure that the personal information we collect, use, and disclose is accurate, complete, up-to-date, relevant, and not misleading.

We implement appropriate technical and organisational security measures to protect your personal information from loss, misuse, unauthorised access, modification, or disclosure. These measures include:

Physical security for our offices and data storage.
Password protection and multi-factor authentication for electronic records.
Encryption of sensitive data where appropriate.
Regular review and update of our security practices.
Staff training on privacy and data security.

While we strive to protect your personal information, no data transmission over the internet can be guaranteed to be 100% secure. Therefore, we cannot guarantee the absolute security of any information you transmit to us online.

9. Data Retention

We will retain your personal information for no longer than is necessary for the purposes for which it was collected, or as required by law. When your personal information is no longer required, we will take reasonable steps to securely destroy or de-identify it.

10. Your Rights

Under the New Zealand Privacy Act 2020, you have the following rights regarding your personal information:

Right to Access: You have the right to request confirmation of whether we hold personal information about you and to request access to that information.
Right to Correction: You have the right to request that we correct any inaccurate, incomplete, or outdated personal information we hold about you.
Right to Object/Withdraw Consent: You may object to certain processing activities or withdraw your consent at any time, subject to legal or contractual restrictions. This may impact our ability to provide you with certain services.
Right to Complain: If you believe we have breached your privacy rights, you have the right to lodge a complaint with our Privacy Officer or the New Zealand Privacy Commissioner.

To exercise any of these rights, please contact our Privacy Officer using the details provided below. We will respond to your request within 20 working days.

11. Cookies

Our website may use "cookies" to enhance your experience. A cookie is a small text file placed on your computer by our website as a tool to remember your preferences and to help analyse website traffic. You can choose to set your browser to refuse cookies or to alert you when cookies are being sent. However, if you do so, some parts of our website may not function properly.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. Any changes will be posted on this page with an updated "Last Updated" date. We encourage you to review this Privacy Policy periodically.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our handling of your personal information, please contact our Privacy Officer:

Privacy Officer Fortis Recruitment Limited

2 Pitchill Street

Blenheim

New Zealand

Leighton@fortisrecruitment.co.nz

+64 0211527015