LEGAL
Sub-processor & Platform Provider Schedule
The third-party providers, integrations and data sources used to deliver the Nathan HRMS platform, and the data each one processes.
Published and effective on: 28 July 2026
1.Classification Model
Nathan Digital classifies third-party providers used in connection with the Nathan HRMS platform as follows:
| Classification | Meaning |
|---|---|
| Core HRMS Platform | A provider Nathan Digital contracts, controls and uses to run the Nathan HRMS platform or deliver the contracted services. Engaged as a subprocessor under the customer agreement. |
| Client-Authorized Integration | A third-party system the client owns, connects or grants access to — its own identity provider, mail server, messaging account, attendance hardware, e-signature account or statutory portal. Nathan Digital acts as an operator on the client's instruction; the client remains the contracting party with that provider. |
| External Data Source | A free or API-connected public data source used for reference or media content (public holiday calendars, stock imagery, public video and GIF libraries, geographic reference data). No personal data is processed beyond the search terms sent to the source. |
| Internal Operational Tool | A tool used by Nathan Digital staff to run delivery, support, monitoring or internal workflows. Access to production personal data is restricted to authorised personnel. |
2.Data Categories Processed
The platform processes the following categories of data on behalf of the client:
| Category | Data processed |
|---|---|
| Client and account data | Tenant and company records, company registration and contacts, contracts, subscription and licence records, seat counts, invoices and billing records, tenant administrator accounts. |
| Employee master data | Name, employee ID and system employee ID, work and personal contact details, date of birth, gender, marital status, nationality, photograph, home address, emergency contacts, dependants and family members, organisational placement (company, department, designation, grade, reporting manager, team, work location). |
| Identity and immigration documents | Passport, national ID / Emirates ID, visa and residency permits, work permits and labour cards, driving licences, educational and professional certificates, together with issue and expiry dates and scanned copies of those documents. |
| Payroll and financial data | Salary structure, allowances, deductions, overtime and off-cycle items, bank account and IBAN details, payroll runs and WPS / bank transfer files, payslips, end-of-service and gratuity calculations, loans, advances and salary increments, expense claims and receipt images, air-ticket entitlements, and statutory identifiers and filings (e.g. UK National Insurance number, tax code, RTI submissions). |
| Time and attendance data | Biometric terminal punch events (timestamp, device and terminal ID, in/out direction), geolocation captured at clock-in and clock-out, shift and roster assignments, timesheets and project allocations, overtime, and leave, work-from-home and TOIL balances and transactions. |
| Health, wellbeing and other special-category data | Sick-leave and medical certificates, medical insurance enrolment and dependant details, accessibility or accommodation needs, disciplinary and grievance records, and investigation or whistleblowing reports. Treated as special-category data under GDPR Article 9 where applicable. |
| Recruitment and candidate data | Job requisitions, applications, CVs and parsed CV content, candidate contact details, screening and assessment scores, interview schedules, AI interview audio recordings and transcripts, offer letters, and employee referrals. |
| Performance, learning and talent data | Goals and KPIs, appraisals and review cycles, 360 and peer feedback, probation evaluations, succession and talent assessments, disciplinary outcomes, course enrolments and progress, quiz and assessment results, and learning voice-assessment recordings. |
| Communications data | Email addresses, mobile numbers, WhatsApp and SMS message content, email and message templates, delivery, bounce, complaint, open and click events, push notification subscription tokens, and Microsoft Teams / Outlook message and meeting metadata. |
| Platform activity data | User actions, audit logs, approval and workflow history, comments, task actions, notification records, login and session records, IP address, device and user-agent details, API request logs and slow-request logs. |
| AI processing data | Prompts, retrieved context and vector embeddings, uploaded documents submitted for analysis, chat history, meeting transcripts and summaries, generated content (letters, job descriptions, reports, course material, images, video and audio) and AI usage and token accounting records. |
3.Subprocessor & Provider Schedule
3.aCore HRMS platform subprocessors
Engaged and controlled by Nathan Digital to deliver the contracted service.
| Provider | Purpose | Data processed |
|---|---|---|
| MongoDB Atlas (hosted on AWS) | Primary multi-tenant application database. Stores all employee, payroll, attendance, leave, recruitment, performance, workflow, approval, configuration and audit records. Each tenant is provisioned its own database. | All structured application data, including special-category HR data. |
| Amazon S3 | All file and document storage — employee identity and immigration documents, contracts and generated letters, payslip PDFs, CVs and candidate attachments, claim receipts, learning media, meeting recordings, report exports and bulk imports. Served only through short-lived presigned URLs or authenticated proxy requests. | All uploaded files and generated documents. |
| Amazon SES / SES v2 | Default transactional email delivery — onboarding and portal invitations, MFA and OTP codes, approval and workflow notifications, payslip and document notices, document-expiry alerts, survey invitations and scheduled report distribution. | Recipient email addresses, message content, sender identity, delivery metadata. |
| Amazon SNS | Receives SES delivery, bounce, complaint and engagement events used for suppression management and email analytics. | Email addresses tied to delivery, bounce, complaint and engagement events. |
| AWS Secrets Manager | Secure storage and retrieval of platform and tenant integration secrets (database connection strings, provider API keys, signing keys). | No personal data — credentials and configuration secrets only. |
| Amazon Web Services — compute, networking, logging (ECS, EC2, CloudWatch) | Hosting and runtime for the Nathan HRMS API, web application, scheduler and supporting services, including infrastructure logs and monitoring. | All platform data at rest and in transit on the hosted infrastructure; application and access logs. |
| Redis (managed Redis / Amazon ElastiCache) | BullMQ background job queues and caching layer — payroll runs, attendance synchronisation, notification dispatch, report generation, document and video generation, and AI jobs. | Job payloads — tenant and company IDs, employee and document references; cached session and permission data. |
| Qdrant | Vector database supporting retrieval-augmented AI — HR policy and knowledge-base search, job-description search, and the immigration & contract lifecycle knowledge base. | Text embeddings derived from policies, job descriptions, knowledge-base articles and uploaded documents. |
| OpenAI | Primary LLM and multimodal provider across the platform — AI copilot and assistant, CV parsing and candidate screening, job-description and letter drafting, contract review, performance and feedback summarisation, payroll and BI insights, expense-receipt parsing, writing assistant, learning content generation, text embeddings, speech-to-text (Whisper), narration (text-to-speech), still-image generation (gpt-image-1) and realtime voice for AI interviews. | Prompts and retrieved context (may include employee, candidate, attendance and payroll data), uploaded documents, audio recordings, chat history, generated outputs. |
| Google — Gemini and Veo (Generative Language API) | Alternate LLM selectable per tenant and per AI agent; used in contract review and the AI research agent. Veo provides video generation for Learning & Development course media. | Prompts, document text, brand and course context, generated media. |
| Anthropic (Claude) | Alternate LLM provider selectable per tenant in AI Agent Configuration and available to the AI research agent. Not the default provider. | Prompts, retrieved context, generated content. |
| Tavily (REST API and MCP endpoint) | Live web search layer for the AI copilot and for resolving external further-reading links in AI-generated lessons. | Search queries derived from user prompts. No employee records are submitted deliberately. |
| Twilio | Default WhatsApp Business and SMS delivery — approval alerts, onboarding and task reminders, attendance and request notifications, and OTP messages. | Recipient phone numbers, message content, delivery status. |
| Google Maps Platform | Map rendering, geocoding and place lookup for work-location setup, attendance geofencing, and clock-in / clock-out location preview. | Work location coordinates and addresses; employee clock-in and clock-out coordinates. |
| Browser and device push services (Google FCM, Apple APNs, Mozilla autopush) | Delivery of Web Push notifications to the subscribed browser or device. Engaged automatically by the user's browser vendor when push is enabled. | Push subscription endpoints and tokens, notification title and body. |
3.bClient-authorized integrations
Connected, owned or authorised by the client. Nathan Digital operates these on the client's instruction.
| Provider | Purpose | Data processed |
|---|---|---|
| Microsoft Entra ID (Azure AD) | Single sign-on (OIDC) into the platform using the client's own tenant and app registration; optional SCIM-style user provisioning from directory data. | User identity, email address, authentication tokens, directory and group claims. |
| Microsoft Graph API | Microsoft Teams approval and workflow notifications and meeting creation; Teams meeting recordings and transcripts for Meet AI; Outlook email analytics; user profile photos; calendar synchronisation. | Teams channel, chat and meeting IDs, notification content, meeting transcripts and recordings, email metadata, profile photos, calendar events. |
| Google Workspace SSO | Google OIDC sign-in where enabled by the client. | User identity, email address, authentication tokens. |
| SAML 2.0 identity providers | Enterprise SSO where the client operates its own SAML identity provider. | Identity assertions — user identifier, email, attribute claims. |
| Client SMTP server | Tenant-configured outbound email using the client's own mail server in place of the platform default. | Recipient email addresses, message content, sender identity. |
| SendGrid / Mailgun | Alternative email providers selectable per tenant on the client's own account. | Recipient email addresses, message content, delivery metadata. |
| Meta WhatsApp Cloud API | Alternative WhatsApp channel using the client's own WhatsApp Business account and phone number. | Recipient phone numbers, message content, template and delivery metadata. |
| SMSGlobal / Etisalat / other client SMS gateway | Tenant-configured SMS delivery for notifications and OTP. | Recipient phone numbers, message content. |
| Biometric and attendance device APIs (e.g. ZKTeco-family terminals and vendor-hosted attendance servers) | Scheduled pull of punch data from the client's terminals or attendance server, and an inbound biometric push endpoint secured by a per-tenant API key. | Employee and device identifiers, punch timestamps, terminal IDs, in/out direction. |
| DocuSign | E-signature for contracts and legal documents in the contract lifecycle module, on the client's DocuSign account. When unconfigured, the platform falls back to an in-app signature captured and stored on platform infrastructure. | Signer name and email address, document content, signature and audit trail. |
| HMRC (United Kingdom) | Real Time Information (FPS / EPS) payroll filing and Data Provisioning Service retrieval for UK payroll. | Employee names, National Insurance numbers, tax codes, pay, tax and deduction figures. |
| Government and immigration portals (statutory gateway) | Statutory submissions and status retrieval for visa, labour and immigration processes, using per-tenant portal credentials. | Employee identity and immigration document data, application and case status. |
| Client banking / WPS channel | Payroll disbursement files (WPS / SIF / bank transfer formats) generated by the platform and transmitted by the client to its bank. | Employee name, employee and labour card identifiers, IBAN, net pay amounts. |
3.cExternal data sources
Public reference and media sources. No personal data is processed beyond publicly available content.
| Source | Purpose | Data processed |
|---|---|---|
| YouTube Data API v3 | Suggests genuine reference videos for Learning & Development video lectures. | Search terms derived from course and lesson topics. No personal data. |
| Pexels API | Retrieves stock photography for AI-generated presentation slides and course media. | Search terms. No personal data. |
| GIPHY API | Powers the GIF picker (search and trending) in Announcements. | Search terms. No personal data. |
| Google Calendar public holiday feeds | Imports public holiday calendars by country into the holiday calendar module. | Public holiday data. No personal data. |
| Bundled public reference datasets (country / state / city, IANA timezone database, airport and airline codes, IBAN rules, nationality lists) | Geographic, timezone, travel and banking reference data used in forms, air-ticket entitlements and payroll validation. Bundled with the application; no runtime call-out. | None. |
3.dNathan Digital first-party services
Operated by Nathan Digital on its own infrastructure. Listed for completeness; these are not third-party subprocessors.
| Service | Purpose | Data processed |
|---|---|---|
| Notification microservice | Nathan Digital-operated fan-out service for email and WhatsApp dispatch, used when a tenant is configured for the shared notification channel. | Recipient email addresses and phone numbers, message content, template data. |
| Scheduler / cron service | Scheduled jobs — document-expiry and probation reminders, task deadline reminders, attendance synchronisation and daily summary regeneration, leave accruals, scheduled reports and payroll reminders. | Employee, attendance, leave and payroll records; recipient contact details for reminder emails. |
| WhatsApp assistant service | Conversational WhatsApp interface for employee self-service requests and approvals. | Phone numbers, message content, employee and request records referenced in the conversation. |
| CRM and Support Ticket API | Nathan Digital internal systems used for subscription and licence lookup on the billing dashboard, and for support tickets raised from within the platform. | Tenant and company identifiers, seat counts, requester name and email, ticket subject and description. |
4.Platform Module to Provider Mapping
| Platform area | Active providers |
|---|---|
| Authentication, SSO and MFA | Microsoft Entra ID, Google Workspace SSO, SAML identity providers, Amazon SES / Twilio (OTP delivery), MongoDB Atlas, platform-issued JWT |
| Core HR and employee records | MongoDB Atlas, Amazon S3, Amazon SES, OpenAI (data validation and field suggestions) |
| Employee Self-Service (ESS) portal | MongoDB Atlas, Amazon S3, Amazon SES, Twilio / Meta WhatsApp Cloud API, browser and device push services |
| Attendance and time (NTime) | Client biometric and attendance device APIs, Google Maps Platform (geofencing), MongoDB Atlas, Redis, scheduler service |
| Timesheets and project allocation | MongoDB Atlas, Amazon SES, Redis |
| Leave, WFH and TOIL | MongoDB Atlas, Amazon SES, Twilio / Meta WhatsApp Cloud API, scheduler service |
| Payroll, payslips and end of service | MongoDB Atlas, Amazon S3, Amazon SES, HMRC RTI / DPS (UK), client banking / WPS channel, OpenAI (payroll variance insights), in-process PDF and Excel generation |
| Claims and expenses | OpenAI (receipt interpretation), in-process OCR, Amazon S3, MongoDB Atlas, Amazon SES |
| Recruitment and ATS | OpenAI (CV parsing, screening, job descriptions, realtime AI interviews, Whisper transcription), Qdrant (job-description and CV search), Amazon S3, Amazon SES |
| Meet AI (meeting intelligence) | Microsoft Graph API (Teams meetings, recordings, transcripts), OpenAI (transcription and summarisation), Amazon S3, MongoDB Atlas |
| Learning & Development | OpenAI (course content, narration, voice assessment), Google Veo (video generation), Google Gemini, YouTube Data API, Pexels, Tavily, Amazon S3, Redis |
| AI Copilot and AI Assistant | OpenAI (default), Anthropic and Google Gemini (selectable), Tavily and Tavily MCP (web search), Qdrant (retrieval), Amazon S3 (document attachments), in-process PDF export |
| Performance, succession and feedback | OpenAI, MongoDB Atlas, Amazon SES |
| Announcements and internal communications | GIPHY, Amazon SES, Twilio / Meta WhatsApp Cloud API, browser and device push services, Microsoft Graph API (Teams) |
| Documents, letters and contracts | Amazon S3, DocuSign, OpenAI (drafting), in-process PDF and Word generation, MongoDB Atlas |
| Reports and BI analytics | OpenAI (narrative insights), MongoDB Atlas, Amazon S3, in-process PDF and Excel generation |
| Notifications and messaging | Amazon SES and SNS, Twilio, Meta WhatsApp Cloud API, SMSGlobal / Etisalat / client gateway, browser and device push services, Microsoft Graph API, notification microservice |
| Immigration and contract lifecycle (ICL) | DocuSign, government and immigration portals, OpenAI, Qdrant, Amazon S3 |
| Background jobs and scheduling | Redis (BullMQ), scheduler service, Amazon Web Services |
| Platform administration, billing and support | Nathan Digital CRM and Support Ticket API, MongoDB Atlas, AWS Secrets Manager, Amazon Web Services (CloudWatch) |
5.Notes
- Document generation is performed in-process. Payslips, letters, contracts, reports, WPS files and Word and Excel exports are produced on Nathan Digital-controlled infrastructure using open-source libraries, and receipt OCR runs locally. No external document-conversion or PDF-rendering service receives this data.
- Client-authorized integrations are enabled only at the client's instruction, using credentials the client supplies. Where the client directs the platform to use its own mail server, messaging account, identity provider, e-signature account or attendance hardware, that provider is not engaged by Nathan Digital as a sub processor.
- AI provider selection is configurable. OpenAI is the platform default; a tenant may supply its own API key, restrict which AI agents are enabled, and set per-agent model overrides. AI requests and token consumption are logged per company for usage accounting.
- AI providers are used on a zero-retention-for-training basis under their respective enterprise API terms. Prompt and completion content is not used to train the providers' models. See our AI Services Addendum.
- Hosting region — production infrastructure runs in AWS eu-central-1 (Frankfurt), with MongoDB Atlas clusters in the corresponding region. Tenant-specific residency arrangements are confirmed per contract.
- Changes to this schedule — Nathan Digital will notify customers of the addition or replacement of a core subprocessor in accordance with the Data Processing Agreement, giving the customer an opportunity to object.
- This schedule can be aligned to a specific Data Processing Agreement, GDPR Article 28 wording, or a UK/EU standard contractual clause annex on request. Transfer mechanisms, retention periods and security measures per provider are not enumerated here.