Data Category and Lawful Basis of Processing

Data Category	Purpose
HR Data, which includes information received from employees (Talent and internal staff), and applicants such as: Employee (Talent and internal staff) and applicant contact details (and link to social media if provided) – name, business and/or personal phone, email, address Identification and proof of employment eligibility documents which may contain demographic data such as name, dob, age, gender, citizenship, work authorization status. (ssn, drivers license number, state ID number) Work history, performance, discipline, work samples (ex. Portfolio images) Education, training, and career interests Health and safety information related to or needed for emergency contacts, sick time, medical leave, or accommodation/accessibility purposes Other information required for employment purposes, such as payment of compensation and benefits and maintenance of employment records (may include information such as student loans, interview records, receipts and invoices for reimbursements)	Communication regarding finding work, problem resolution, other employment related matters Business and Employment records Recruitment Payment and required withholdings Talent and staff onboarding Background checks in accordance with applicable law and client requirements Employment eligibility verification Performance management Payment and tracking of benefits Disability accessibility and accommodation requirements Expense reimbursement Legal requirements
Information received from Client, Prospective Client and Prospective Talent (applicants) Information which may include business contact details, job title, industry, Company, IP address.	To provide services, for operational purposes, and to improve our products and services To enable access to systems such as MyAquent Sales and marketing Recruiting Billing
Information received from third parties such as vendors, credit reference agencies, background screening companies, including company number, VAT number, bank details, contact details (which may be personal data in some instances).	Payment Business records Legal requirements To verify identity, credit worthiness
Information we collect from you that falls into special categories of data including: Health data regarding a condition or disability, or leaves of absence and family leaves Background screening data which may include drug, alcohol and criminal background checks Certain demographic data such as race, gender, sexual orientation, religious of philosophical beliefs, trade union membership Biometric data such as a photo and fingerprints	Legal requirements To comply with contractual commitments where permitted by law To provide employment related benefits Health and safety of employees Subject to legal requirements, some demographic data may also be used to improve diverse representation in our candidate submissions, to direct talent outreach, and to develop resources that support our talent community and foster an inclusive environment. Your demographic data is not disclosed to clients or Aquent Agents. Clients may be provided reporting of aggregated data to help them understand the composition of their candidate pool and assist them in managing their diversity recruiting effort, but personally identifiable demographic data is not shared with them. Disclosure of demographic data is completely voluntary and self-reported
Information we collect through your use of our website including: Website user credentials such as User ID and password General Location data, for example if you provide us with the Aquent market closest to your location Information collected through the use of Cookies and similar technologies (see our Cookies Notice for more information)	Marketing and communication regarding topics we believe are relevant to you, management and improvement of websites
Information Collected from Aquent Gymnasium registered users including: Name Email address User name Password Gymnasium Course Records Information from your LinkedIn profile if you create your account using LinkedIn	To communicate with you about Aquent Gymnasium and other products and services in which you may be interested To maintain your user account and a record of your course work and certifications Marketing Analysis and internal reporting User support

Lawful Basis of Processing EU Resident Personal Data. Aquent may only process EU resident personal data if we have a lawful basis to do so. In most cases the lawful basis for processing your data will be one of the following:

To comply with a contractual obligation, for example for providing services to and billing clients, or to perform our obligations under an employment agreement
To comply with our legal obligations, for example obtaining proof of your right to work status, or in order to comply with applicable employment or tax laws
Where you have given your consent to the relevant processing activity for the purposes of which we have informed you. Where this is the case, you always have the right to withdraw that consent
Where it is necessary for our legitimate interests or those of a third party, provided that our legitimate interests are not overridden by your interests or rights which require protection of your data. For example, to manage our recruitment process effectively, to protect Aquent's against risk, to maintain product development and enhancement, for effective marketing.

Special Categories of Data. We also may collect and use special categories of data in certain situations. Generally the basis for processing such data will be:

You have provided your explicit consent. Where this is the case, you always have the right to withdraw that consent
We need to do so to carry out our legal obligations (e.g. in the context of employment, social security and social protection law, or for a collective agreement) for example, complying with our obligations under equality legislation or in relation to statutory sickness or maternity rights;
Where the processing relates to personal data which you have made public
It is necessary for the establishment, exercise, or defense of legal claims;

Updated: October 2022