Privacy Policy
1. Who we are
Hakuhana Limited (“Hakuhana”, “we”, “us”, “our”) is a company registered in England and Wales under company number 12816409, with its registered office at Suite 20, 70 Churchill Square, Kings Hill, Kent ME19 4YU. We are a UK employment business, and this policy explains how we collect, use, and protect personal data belonging to visitors to our website, job applicants, workers we employ or place, and clients of our business advisory and staffing services.
We are the data controller for the personal data described in this policy unless stated otherwise. We are registered with the Information Commissioner’s Office (ICO), registration number ZC119588 ICO REGISTRATION NUMBER.
If you have any questions about this policy or how we handle your data, contact us at data@hakuhana.com or by post at the address above, marked for the attention of Director – Petrina Baldwin. 70 Churchill Square, Suite 20. Kings Hill. Kent ME19 4YU
2. The personal data we collect
The data we collect depends on how you interact with us:
Website visitors
- Technical data (IP address, browser type, device information) collected via cookies and similar technologies – see Section 7.
- Information you submit through contact or enquiry forms (name, email, phone number, company name, message content).
Job applicants and workers
- Identity and contact details (name, date of birth, address, phone number, email, National Insurance number).
- Right-to-work documentation and immigration status where applicable.
- Employment history, qualifications, references, and CV/application content.
- Bank details and tax information for payroll purposes.
- Health information where relevant to a role, statutory sick pay, or reasonable adjustments (this is “special category” data under UK GDPR and is handled with additional safeguards).
- Emergency contact details.
- Performance, attendance, and disciplinary records arising from your employment or engagement with us.
Client businesses
- Business contact details of individuals we deal with at client organisations (name, role, email, phone number).
- Information relevant to advisory, staffing, or consultancy services provided under our contract with the client.
3. How we use your data and our legal basis
We only use personal data where we have a valid legal basis to do so under UK GDPR. Depending on the purpose, this will be one or more of the following:
- Performance of a contract – for example, employing or placing a worker, or delivering services to a client under an agreed contract.
- Legal obligation – for example, right-to-work checks, PAYE and tax reporting, or health and safety record-keeping.
- Legitimate interests – for example, responding to enquiries, improving our services, or maintaining business records, provided this does not override your rights and interests.
- Consent – for example, non-essential cookies, or optional marketing communications, which you may withdraw at any time.
- Special category data (such as health information) is processed only where a further condition under Article 9 UK GDPR applies, such as employment law obligations or explicit consent.
4. Sharing your data
We do not sell personal data. We may share data with:
- Client businesses, where you are a worker being placed or introduced to that client, and only the information relevant to the placement.
- Service providers who process data on our behalf, such as payroll and invoice-financing providers, IT and hosting providers, and professional advisers (accountants, solicitors), under appropriate data processing agreements.
- Regulatory or government bodies where required by law, such as HMRC or the ICO.
- Professional advisers in connection with a business transaction (such as a sale or restructuring of the business), where permitted by law.
We do not knowingly transfer personal data outside the UK. If this changes, we will update this policy and ensure appropriate safeguards (such as UK adequacy regulations or standard contractual clauses) are in place.
5. How long we keep your data
We retain personal data only for as long as necessary for the purposes it was collected, including to satisfy any legal, accounting, or reporting requirements. As a general guide:
- Job applicant data where the application is unsuccessful: up to 12 months, unless you consent to us retaining it for future opportunities.
- Employment and payroll records: 6 years from the end of employment, in line with HMRC and statutory requirements.
- Website enquiry data: up to 24 months, or until the enquiry is resolved and no further contact is required.
6. Your rights
Under UK GDPR, you have the right to:
- Access the personal data we hold about you
- Request correction of inaccurate or incomplete data.
- Request erasure of your data, where applicable.
- Object to or restrict certain processing.
- Request a copy of your data in a portable format, where applicable.
- Withdraw consent at any time, where processing is based on consent.
To exercise any of these rights, contact us at data@hakuhana.com. We will respond within one month, as required by law.
If you are unhappy with how we have handled your data, you have the right to complain to the Information Commissioner’s Office (ICO) at ico.org.uk or by calling 0303 123 1113. We would appreciate the opportunity to resolve any concerns directly first.
7. Cookies
Our website uses cookies to enable core functionality and, where you consent, to understand how visitors use the site. You can manage or withdraw cookie consent at any time through the cookie settings banner on our website, or through your browser settings. Disabling some cookies may affect how the website functions.
8. Security
We take appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or misuse, including access controls, secure storage, and staff awareness of data protection obligations. No method of transmission or storage is completely secure, but we work to protect your data to industry-appropriate standards.
9. Changes to this policy
We may update this policy from time to time to reflect changes in our practices or legal requirements. The “last updated” date at the top of this page shows when it was last revised. We encourage you to review this policy periodically.
10. Contact us
Hakuhana Limited
Suite 20, 70 Churchill Square, Kings Hill, Kent ME19 4YU
Email: data@hakuhana.com
Company number: 12816409