1. Introduction:

1.1 RWA People Ltd (“we”, “us”, “our”) respects your privacy and is committed to complying with the Privacy Act 2020 of New Zealand.

1.2 This Privacy Policy sets out how we collect, use, disclose, store, and protect personal information through our website, recruitment and contractor services, and business operations.

2. What Personal Information We Collect:

2.1 “Personal information” refers to any information about an identifiable individual.

2.2 We may collect the following types of personal information:

• a. Full name, job title, and contact information (e.g. phone number, email address, postal address).
• b. Curriculum Vitae (CV), employment history, qualifications, and references.
• c. Job preferences, salary expectations, work eligibility, and professional interests.
• d. Contractor and payroll information - payment and bank details, IRD number and tax details, insurance details, timesheets, and rates.
• e. Background and pre-employment check information - where relevant to a role and with your authorisation, including reference checks, qualification verification, criminal-history checks, credit checks, and anti-money-laundering (AML) checks.
• f. Correspondence or communications sent to us, including emails, phone calls, SMS, or contact-form submissions.
• g. Technical information such as IP address, browser type/version, device identifiers, and usage data collected through cookies or analytics tools.
• h. Any other personal information you voluntarily provide to us.

3. How We Collect Personal Information:

3.1 We collect personal information through the following methods:

• a. Directly from you when you contact us, apply for a role, register your CV, enter a contracting arrangement, subscribe to communications, or interact with us in person or online.
• b. Automatically when you use our website, through browser cookies, server logs, and similar technologies.
• c. From third parties such as referees, previous employers, our clients, recruitment platforms, job boards, or publicly available sources (e.g. LinkedIn).

4. Purpose of Collection and Use:

4.1 We collect and use your personal information for the following purposes:

• a. To provide recruitment, contractor management, and related consulting services.
• b. To match you with current or future opportunities and assess your suitability for roles.
• c. To manage contractor engagements, including timesheets, invoicing, and payments.
• d. To communicate with you regarding opportunities, engagements, events, or updates.
• e. To support clients with staffing needs (with your consent).
• f. To manage our internal operations, meet legal, tax and regulatory obligations, and improve our services.
• g. To conduct statistical or market analysis (in de-identified form).

5. Disclosure of Personal Information:

5.1 We may share your personal information with the following parties:

• a. Clients or prospective employers - with your express consent.
• b. Technology and service providers who host or process data on our behalf (see section 6).
• c. Referees or third parties you have authorised us to contact.
• d. Legal, regulatory, or governmental authorities where required by law, and Inland Revenue for contractor tax purposes.

5.2 We do not sell, rent, or trade your personal information to third parties.

6. Where Your Information Is Stored:

6.1 Your personal information is stored securely in the cloud. We use trusted third-party service providers to host and process personal information on our behalf, including providers of:

• a. Applicant tracking and recruitment services;
• b. Contractor timesheet, invoicing and payment services;
• c. Pre-employment screening and background-check providers (for reference, qualification, criminal-history, credit and AML checks);
• d. Email and document storage;
• e. Accounting;
• f. Electronic document signing; and
• g. Workflow automation and service-review tools.

6.2 Your personal information is stored primarily on secure servers located in New Zealand and Australia. Some of our providers may host data in other locations; where information is sent or accessed overseas, we apply the safeguards described in section 7.

6.3 Our website is a static site and does not itself collect personal information (other than any cookies/analytics described in section 11).

7. International Transfers:

7.1 As set out above, some of our providers store personal information outside New Zealand (primarily in Australia). We may also share information with clients or service providers located overseas - for example, where overseas qualification, police, credit or AML checks are carried out with your authorisation.

7.2 Where we do so, we take reasonable steps (consistent with the Privacy Act 2020, including Information Privacy Principle 12) to ensure the receiving organisation is subject to comparable privacy safeguards - for example, through binding contractual commitments or another mechanism permitted under the Act.

8. Data Storage and Security:

8.1 We take reasonable steps to protect your personal information from loss, misuse, unauthorised access, alteration, or disclosure.

8.2 Security measures include, but are not limited to:

• a. Reputable cloud providers with encryption of data in transit and at rest.
• b. Role-based access controls and multi-factor authentication.
• c. Staff training on privacy and data protection.
• d. A documented process for responding to privacy incidents and data breaches.

8.3 While we take security seriously, no system is completely secure. If we experience a privacy breach that is likely to cause serious harm, we will notify affected individuals and the Office of the Privacy Commissioner as required by the Privacy Act 2020.

9. Retention of Personal Information:

9.1 We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected or to comply with legal, tax and contractual requirements.

9.2 If you are not actively seeking roles, we may retain your profile for consideration in future opportunities unless you request deletion. When information is no longer required, we securely delete or de-identify it.

10. Your Privacy Rights:

10.1 You have the following rights under the Privacy Act 2020:

• a. Right to access the personal information we hold about you.
• b. Right to request correction of your personal information.
• c. Right to request deletion of your personal information (subject to legal limitations).
• d. Right to withdraw consent where applicable.
• e. Right to make a complaint with the Office of the Privacy Commissioner (www.privacy.org.nz).

10.2 To exercise any of these rights, contact us using the details in section 14. We will respond to access and correction requests within the timeframe required by the Privacy Act 2020 (generally 20 working days).

11. Cookies and Website Tracking:

11.1 Our website uses cookies and similar technologies to:

• a. Ensure functionality and performance.
• b. Analyse user behaviour and traffic.
• c. Improve user experience.

11.2 You may disable cookies in your browser settings, but doing so may affect functionality.

12. Links to Other Websites:

12.1 Our website may contain links to external websites that we do not operate or control.

12.2 We are not responsible for the privacy practices or content of those sites. We encourage you to review their privacy policies before providing any personal information.

13. Changes to This Privacy Policy:

13.1 We may update this Privacy Policy from time to time to reflect changes to our practices, services, or legal requirements.

13.2 Any changes will be posted on our website with the effective date.

14. Contact Us:

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us: