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This document describes a set of principles governing the handling of your personal information and protecting your privacy as our employee.


This policy applies to all employees, including permanent employees, fixed term employees, consultants and trainees or temporary employees.

You start being our employee when you sign an employment contract with us. You stop being our employee when our employment contract with you terminates or is cancelled for whatever reason.

This policy will not apply outside of the employment relationship for example where we process your personal information in another capacity, such as a user of our website, or as a customer or supporter. The relevant user-facing or customer-facing privacy policy will apply in those circumstances, where applicable.


The acceptance of this policy is a condition of employment with this Company. We may change this policy at any time and will notify you of the changes in writing by electronic mail or otherwise. The changed policy applies to you if you continue to work for us following the notification.


We value our employees and appreciate the importance or treating personal information as confidential.

We require any directors, officers, managers and employees entrusted with your personal information, as part of their job responsibility, to treat the information as confidential and in accordance with the provisions of this policy.

We will also endeavour to ensure that any third party service providers we may use to administer our human resources functions, also deals with your personal information in a manner that is consistent with this policy.


Your personal information includes any information about you over the course of your employment with the Company, such as:

• Your Curriculum Vitae;
• Job application forms;
• References and interview notes;
• Photographs and videos;
• Offers and acceptances of employment;
• Your biographical information including your name, gender, date of birth, details of family members, nationality, fingerprints, etc.;
• Race and ethnicity information for the purposes of employment equity and transformation;
• Marital status;
• Your identification numbers, including government-issued identification number or passport information;
• Your performance information, including management metrics, appraisals, feedback;
• Policy acknowledgements or sign-off documents;
• Confirmations of employments and other disclosures;
• Trade union membership and political affiliation;
• Payroll information, including your salary details and bank account information;
• Communications and internet information like your correspondence and details of internet use held on or made through the Company’s systems;
• Information necessary to process any court orders regarding payment of debts (garnishee orders);
• Your contact information including your home and postal address, telephone number and email address;
• Benefit information (including pension fund or medical aid information);
• Beneficiary an emergency contact information;
• Information about severe allergies or health conditions that may require us to make special accommodations.


6.1 You consent to us collecting, using, disclosing, and storing your personal information for the purposes provided for in this policy and any other purposes set out or implied when you provide the relevant personal information to us, unless you inform us otherwise.
6.2 Where your consent is required for us to collect, use, disclose or store your personal information, you may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice.
6.3 We are not generally required to get your consent to collect, use, disclose or store your personal information. The law allows or requires us to collect, use, disclose or store your personal information without your knowledge or consent under certain circumstances.



7.1.1 We most often collect personal information about you directly from you and may ask you to provide us with your identifying information. We may also use other sources to assist in obtaining relevant personal information about you, subject to legislative restrictions, for example third parties to help to support recruitment, credit checks, reference and background checks, investigations of possible employee wrongdoing, etc. We will do our best to ensure that third parties have the right to give your personal information to us where we use them to provide us with your personal information.

7.1.2 We collect some of your personal information automatically when you use our IT equipment – including computers, printers and any other hardware necessary to do your work, IT infrastructure which includes the entire organised system of IT structures, facilities and components necessary for the operation of the Company, including data, computer networks and software and any employee portal, such as SCubed, where we interact with employees which may collect your IP address, browser details, and usage information to display the portal correctly, tract your activities on it or for other necessary purposes.


7.2.1 We will endeavour to collect only the minimum amount of personal information required to implement an employment agreement between you and the Company, to regulate your employment with the Company, and to comply with applicable employment and other relevant laws. Certain departments, for example the Finance Department, require personal information about you to function properly.

7.2.2 We will get your consent to collect your personal information as required in accordance with applicable law when you provide us with it.

7.2.3 We may process your personal information that you provide to us for the purposes that we indicated when we collected the information from you.



Your personal information may be used for the following employment-related purposes:

• To start, maintain and end your employment relationship with us;

• To contact you and manage our relationship with you, oversee compliance with policies and applicable law, assess performance, for promotions and appraisals and for training purposes;
• Decide whether you are eligible for another role or position in the Company;
• Verify your references and qualifications;
• To manage your benefits, including administering remuneration, insurance, payroll, pensions and other employee benefits and tax, including disclosure to third parties such as payroll providers, accountants, auditors, occupational health providers, insurers, pensions administrators, hosting service providers and legal advisors;
• Provide employee training;
• Gather evidence for disciplinary actions or dismissal;
• Compile next-of-kin contact information in the case of emergencies;
• Comply with policies, including in relation to claims, disciplinary actions or legal requirements and conducting investigations and incident response, including reviewing your communications in these situations in accordance with relevant internal policies and applicable laws;
• To store emails and documents generated by you on systems that the Company administer and/or own and make available for employment-related purposes, which may contain personal information;
• To comply with our legal obligations, we may disclose your personal information in connection with proceedings or investigations anywhere in the world to third parties, such as public authorities, law enforcement agencies, regulators and third-party litigants;
• Compile a directory of employees;
• For security purposes, for providing IT support and for employee authentication;
• To facilitate business travel, travel-related support including conference attendance and bookings;
• To conduct certain checks, such as anti-fraud checks. We and other organisations engaged by us may access and use your personal information to conduct credit checks and checks to prevent fraud and money laundering;
• To manage collective agreements for administering collective employee arrangements where these are in place;
• For statistical analysis and research purposes in the context of employment, including predictive modelling and people planning;
• Achieve anything else that we reasonably require.


We may use your personal information/identifying information to send you administrative and update messages about the Company or our current employment relationship with you.


9.1 Your personal information will be shared with third parties, including our contractors who help administer our employment relationship with you or third parties as required by law, for purposes of fulfilling our obligations to you, the government and other third parties.
9.2 We may disclose personal information to private or government authorities when we have determined that we are required to do so under applicable laws or to investigate suspected fraud or illegality, to anticipate or defend legal claims or where you have given us permission to do so.
9.3 We may disclose aggregate statistical information that we have derived from your and other employee’s personal information for analytical purposes.
9.4 We may disclose your personal information to our personnel to do their jobs, but will not do so unnecessarily.
9.5 We will require anyone that we share your personal information with, to honour this policy as far as reasonably possible.
9.6 Your personal information may be processed locally or in any other jurisdiction where we operate and/or compete, depending on the needs of the Company, to the extent necessary and as permitted by law.


10.1 Maintaining the security and integrity of your personal information is important to us and we endeavour to maintain appropriate administrative, technical, personnel and physical measures to safeguard personal information against loss, theft and unauthorised uses or modifications and to comply with applicable information security laws. We authorise access to personal information only for those employees who require it to fulfil their job responsibilities. We expect you to contribute to the security culture of the Company by following appropriate security policies and procedures and reporting suspected incidents promptly.
10.2 We endeavour to keep your personal information that we collect as accurate, complete and up to date as is necessary for the purposes defined in this policy.
10.3 We may ask you to update your personal information from time to time. We will take steps to verify your identity to prevent unauthorised access when doing so.
10.4 We will only keep your personal information for as long as is necessary to fulfil our obligations to you unless you have given us permission to keep it longer or we are otherwise legally allowed or required to do so.


11.1 We may subject you to surveillance and/or monitor your actions when you are using our IT equipment and infrastructure or any other devices or equipment supplied by or owned by the Company. You should therefore have no expectation of privacy with respect to your use of our equipment or infrastructure.
11.2 We may monitor your computer and email use.
11.3 Your work output belongs to the Company. We may monitor your work output and use of our IT equipment or infrastructure or any other devices or equipment or infrastructure to create that work output.
11.4 We may monitor your activities on our premises or with our property. For example, our premises have surveillance cameras to protect against intruders, theft, or vandalism. We may turn those records over to the appropriate authorities if we suspect any wrongdoing or use same in disciplinary actions.


12.1 You have the right to access your personal information within a reasonable time of your request or within the period prescribed by the law;
12.2 You may update your personal information by contacting the Company’s Information Officer.
12.3 We are not responsible for anyone else’s privacy policies or practices.
12.4 You can ask us to erase personal information in certain circumstances, recognising our legal obligation in respect of data retention in the field of employment.
12.5 You can ask us to provide you with a copy of your personal information.