QUALITY CONNECT STAFFING

Registration Number:

This manual has been prepared in terms of the section 51 of the Promotion of Access to Information Act 2/2000 and to address the requirements of the Protection of Personal Information Act 4/2014.

Date Compiled: 1 July 2021

Date Updated: 1 July 2021

Table of Contents

Definitions

• Introduction
• Purpose
• Policy principles
• Acceptable Channels of Forwarding Personal Information
• Direct Marketing
• Destruction of Personal Information
• Storage
• Breach
• Declaration and informed Consent

Indemnify

Acceptance

Conclusion

Definitions

1. “Biometrics” means a technique of personal identification that is based on physical, physiological behavioural characterisation including blood typing, fingerprinting, DNA analysis retinal scanning and voice recognition.

1. “Client” - refers to any natural or juristic person that received or receives services from the Company;

1. “Code of Conduct” means a code of conduct issued in terms of Chapter 7

1. “the Company” - shall mean Quality Connect staffing;

1. “Conditions for Lawful Processing” - the conditions for the lawful processing of Personal Information as fully set out in chapter 3 of POPI and in paragraph 11 of this Manual;

1. “Consent” means any voluntary, specific and informed expressions of will in terms of which permission is given for the processing of personal information.

1. “Data Subject” - as ascribed thereto in section 1 of POPI;

1. “Direct Marketing”- means to approach a data subject, either in person or by mail or electronic communication, for the direct or indirect purpose- Promoting or offering to supply in the ordinary course of business, any goods or services to the data subject.

1. “Electronic Communication” means any text, voice ,sound or image message sent over an electronic communication network which is stored in the network or in the recipient’s terminal equipment until it is collected by the recipient

1. Filling system - means any structured set of personal information, whether centralised, decentralised or dispersed on a functional or geographical basis, which is accessible according to specific criteria.

1. “Information Officer” - the duly authorised Head as defined in section 1 of PAIA;

1. “Manual” - this manual prepared in accordance with section 51 of PAIA and regulation 4(1) (d) of the POPI Regulations;

1. “PAIA” - the Promotion of Access to Information Act 2 of 2000;

1. “Personal Information” - as ascribed thereto in section 1 of POPI;

1. “Personnel” - any person who works for, or provides services to or on behalf of the Company, and receives or is entitled to receive remuneration and any other person who assists in carrying out or conducting the business of the Company, which includes, without limitation, directors (executive and non-executive), all permanent, temporary and part-time staff as well as contract workers;

1. “POPI” - the Protection of Personal Information Act 4 of 2013;

1. “POPI Regulations”- the regulations promulgated in terms of section 112(2) of POPI;

1. “Private Body” - as ascribed thereto in sections 1 of both PAIA and POPI;

1. “Processing” - as ascribed thereto in section 1 of POPI;

1. “Requestor” – as ascribed thereto in section 1 of PAIA;

1. “Request for Access” - as ascribed thereto in section 1 of PAIA;

Any other terms not described herein will have the meaning as ascribed to it in terms of PAIA or POPI.

Introduction

Quality Connect Staffing acknowledges the need to ensure that Personal Information is handled with care and is committed to ensuring compliance with the requirements of POPIA Act. This privacy policy sets out how Quality Connect Staffing uses and protects and processes any information that we collect from you or that you provide to us.

In terms of the POPIA, Quality Connect Staffing has a legal duty to process a “Data Subjects” Personal Information in a lawful, legitimate and responsible manner.

Should we ask you to provide certain information by which you can be identified when using our recruitment services, then you can be assured that it will only be used in accordance with this privacy policy?

We are a recruitment agency and recruitment business with a focus on Digital Marketing, Technology, Advertising and related fields. We collect the personal data of the following types of people to allow us to undertake our business;

• Prospective and placed candidates / clients for permanent or temporary roles;

• Prospective and live client contacts;

• Supplier contacts to support our services;

• Employees, consultants, temporary workers.

We collect information about you solely for the purposes of carrying out our core business and ancillary activities.

Purpose

The Information Officer, Starcha De Freitas is responsible for:

• The monitoring of this policy;
• Ensuring that this policy is supported by appropriate documentation;
• Ensuring that this policy and subsequent updates are communicated to relevant managers, representatives, staff, and associates, where applicable.

• All employees and individuals directly associated with business activities will be trained in the regulatory requirements governing the protection of Personal Information.

• All employees are responsible for adhering to this policy and for reporting any security breaches or incidents to the Information Officer.
• Service Providers that provide IT and/or on-site Data Storage services, to our organization must satisfy us that they provide adequate protection of data held by them on our behalf.

• Management and the Information Officer are responsible for ensuring adherence to Standard Operating Procedures.
• Periodic reviews and audits will be conducted, where appropriate, to ensure compliance with this policy and guidelines.

Policy Principles

Personal information collect from you

Quality Connect Staffing collects Personal Data directly from you (via email, website forms, phone, and email or otherwise) as well as from other available sources to the extent relevant and permitted under the POPI legislation. Subject to this applicable law we may collect the following information:

• Name, ID No and job title
• Contact information including phone number and email address
• We will collect personal information directly from Candidates/Clients.
• Personal Information from Social Networks and Job-seeker portals will be collected with the express consent of the Candidate/s .on the portals or cv’s emailed directly to us.
• Links to your professional profiles available in the public domain e.g. LinkedIn and/or corporate websites
• Your competences, skills, experience and education, e.g. your CV or resume, previous employments, educational details and qualifications, third party references
• Your preferences, e.g. preferred country of employment, areas of interest as well as your preferred ways to be contacted by Quality Connect Staffing
• Other information relevant to roles and relevant industry news
• Other information, such as information found from public sources as well as information depending on the position you are applying for, and where necessary for the recruitment activities. This will only be in the case of legitimate interest (please see our Legitimate Business Interests below)

We will only collect sensitive personal data about you when absolutely necessary for the recruitment process. We will only process this data if you have given your consent for us to do so.

Purposes of Obtaining Personal Information

• Find you employment and to this end, make your information available for searching and matching to job opportunities across the company with the intention of presenting you as a match to the client.
• Perform appropriate checks on job history, criminal record, educational/ skills qualifications/ registrations/ licences as well as credit history, where such is required and is permitted by the NCA.
• Refer you as a candidate for employment with client companies
• Perform its various recruitment, human resources and capital operations, as well as ensuring timeous and accurate payroll functions, and/ or the proper administration of your employment benefits such as healthcare and / or retirement funding.

Mandatory

• Comply with the applicable labour, tax and financial legislation;
• Conclude a contract with you;
• Keep records in accordance with the BCEA and other applicable laws;
• Report to government in terms of the applicable laws, including for example, the EEA, SDA, SDLA, LRA, B-BEEA, UIF, UIFLA and Income Tax Laws;
• Pay over Skills Development Levies as per the SDLA;
• Pay over contributions to the Unemployment Insurance Fund and Compensation Insurance Fund;
• Pay over PAYE and other related taxes to the Receiver of Revenue.

2

All Personal Information which you provide to the Company will only be used for the purposes for which it is collected.

• We will in some circumstances rely on consent to use your data and you will be asked for your express consent, if legally required.
• Consent will be required for processing and include permission to introduce you to a client (if you are a candidate).
• This will be obtained orally or in writing by email or by an online process for the specific activity that we require consent for and record your response on our system.
• Whenever necessary and subject to statutory record-keeping requirements, Quality Connect Staffing will delete and/or anonymise Personal Data that is no longer needed.
• If there has not been any recent activity between yourself and Quality Connect Staffing, we may delete your profile after a reasonable time.

Communicating with you, in context of recruitment activities, such as:

• To obtain additional information where necessary;
• To inform you of available vacancies and relevant industry news;
• To provide you with information relating to your application and to fulfil your requests.

Managing recruitment and resourcing activities, including activities related to organisational planning. In the course of recruitment activities, we may use your information:

• To set up and conduct interviews and assessments;
• To evaluate, select and recruit applicants;
• To conduct background and credit checks and assessments as required or permitted by applicable local law;
• To contact third party references provided by you to evaluate your previous performances.
• Or as otherwise necessary in context of recruitment activities.

Disclosing Personal Data

• Quality Connect Staffing will not sell, lease, rent or otherwise disclose your Personal Data unless you have given explicit consent. Quality Connect Staffing may share your Personal Data if you have given your informed consent for Quality Connect Staffing to do so.
• We do however use our systems to search and identify personal data in accordance with the parameters set by a person. A person will always be involved in the decision making process

Security and controlling your personal information

• We are committed to ensuring that your information is secure although unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.
• We take reasonable steps to keep the personal data we possess accurate and to delete incorrect or unnecessary personal data. With respect to the processing of your Personal Data, you will always have the rights as provided by applicable local law. In addition, this policy provides you the right to know what personal data we hold about you; to request incomplete, incorrect, unnecessary or outdated personal data deleted or updated as well as to object to Quality Connect Staffing’ processing of your Personal Data on compelling legitimate grounds. There may be certain categories of information prescribed by applicable local law that Quality Connect Staffing may lawfully withhold.
• We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about roles and market information which we think you may find interesting if you consent for Quality Connect Staffing to do so.

Retention of your data

• We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so. Accordingly, we will re-assess our Interests Needs on a yearly basis and run data routines to remove data that we no longer have a legitimate business interest in maintaining.
• We segregate our data so that we keep different types of data for different time periods.
• Once in our possession, we will only process or further process Candidate/Client information with their consent, except where we are required to do so by law. In the latter case, we will always inform the Candidate/Client.
• We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our main system.

Information Quality

• We shall ensure that Candidate information is complete, up to date, and accurate before we use it. We will request Candidates, at least once annually, to update their information and confirm that we may continue to store/retain same. If we are unable to contact a Candidate their information will be deleted from our records.

Transparency/Openness

• Where personal information is collected from a source other than directly from a Candidate (Eg Social media, Job portals) we will make Candidates aware: (a) That their information is being collected and the specific reason; (b) Who is collecting their information by giving them our details.
• We will implement sufficient measures to guard against the risk of unlawful access, loss, damage, or destruction of personal information that is held:

Your rights

You may choose to restrict the collection or use of your personal information in the following ways:

• If you have previously agreed to Quality Connect Staffing using and or storing your personal information you may change your mind at any time by writing to or emailing us at: Careers@qcssa.co.za

• You may request us to correct your personal information that we hold about you.

• You may request us to delete your personal information. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing via email.

• Objection to process your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

• Request the transfer of your personal information to another party in certain formats, if practicable.

We also encourage you to contact us to ensure your data is accurate and complete.

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

Quality Connect Staffing may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 1 July 2021

Direct Marketing

The following provisions will apply with regards to direct marketing campaigns:

• Existing Clients – may market similar products and services.
• New Clients – obtain consent first.
• May only request consent once.
• Opt-in and Opt-out provisions must be in place.
• Opt-out opportunities must be provided when information is first collected and with each subsequent communication.

Acceptable Channels of Forwarding Personal Information

Personal information can be dispatched either:

• Physically – In which case it is to be hand-delivered in a sealed envelope and will require the signature of the relevant recipient.

• Emailed via our secured IT Platforms utilising MS Outlook and not through any 3rd party emailing software.

Storage

• Personal information collected is to be stored digitally on our system (that will be Password protected).
• Physical documentation containing personal information is to be filed immediately in secured filing cabinets with restricted access.

Destruction of Personal Information

All obsolete documentation will be shredded.

Breach

A Data Breach can happen for many reasons, which include:

• Loss or theft of data or equipment on which personal information is stored
• Inappropriate access controls allowing unauthorised use
• Equipment failure
• Human error
• Unforeseen circumstances, such as a fire, flood or breakin.
• Deliberate attacks on system, such as hacking, viruses or ,phishing scams- and /or
• Alteration of Personal Information without permission and loss of availability of Personal information.

Breach/es of this policy could result in disciplinary action and termination of employment.

Register and records

Must be directed to the Information Officer stated above

Declaration and Informed Consent

I declare that all Personal Information supplied to the Company for the purposes of recruitment and related legal and operational reasons is accurate, up-to-date, is not misleading and that it is complete in all respects.

I undertake to immediately advise the Company of any changes to my Personal Information should any of these details change.

I furthermore give the Company permission to process my Personal Information, as provided above, and acknowledge that I understand the purposes for which it is required and for which it will be used.

Indemnify

You indemnify Quality Connect Staffing Personnel Recruitment against all claims, actions, suits, liabilities, costs and expenses incurred on any count as a result of the listing your CV on the Companies data base.

Acceptance

The Company reserves the right to either reject or remove any CV from its database. You agree that while the Company makes every reasonable effort to find suitable employment for your candidates, we cannot offer any form of guarantee that we will be successful in doing so. You agree that you are not to contact any of the Companies client in your personal capacity. All correspondence is required to take place between the Company and the Client, unless otherwise agreed with by the Company in writing.

Conclusion

POPIA requires that Quality Connect staffing address any Data Breach in accordance with the terms of thereof.

Quality Connect Staffing will notify the Regulator and the affected Data subject in writing in the event that it experiences a Data Breach.