PRIVACY POLICY
Protection of Personal Information Act 4 of 2013
MEDE RECRUIT (PTY) LTD SOUTH AFRICA
REGISTRATION NUMBER: 2023/576868/07
USERS: EXTERNAL AND INTERNAL
1. INTRODUCTION
1.1 MEDE RECRUIT (PTY) LTD (“MEDE RECRUIT (PTY) LTD, we, us, our”) is sensitive to the personal nature of the information you provide to us.
1.2 This privacy policy (“this Policy”) explains how we protect and use your Personal Information.
1.3 By providing us with your Personal Information, you –
1.3.1 agree to this Policy and authorize us to process, hold, use and disseminate such information as set out herein; and
1.3.2 authorize MedE Recruit (Pty) Ltd, our Associates, our Service Providers and other third parties to process your Personal Information for the purposes stated in this Policy.
1.4 We will not use your Personal Information for any other purpose than that set out in this Policy and will endeavor to protect your Personal Information that is in our possession from unauthorized alteration, loss, dissemination, disclosure or access.
1.5 Please note that we may review and update this Policy from time to time. The latest version of this Policy is available on request and will be updated on our website.
1.6 This Policy applies to all internal and external parties with whom we interact, including but not limited to individual clients, representatives of clients, client organizations, visitors to our offices, applicants and other users of our recruitment and related services. Defined terms used in this Policy are explained herein below, under the heading “Annexure A.”
2. COLLECTION OF PERSONAL INFORMATION
2.1 We may collect or obtain Personal Information about you –
2.1.1 directly from you;
2.1.2 in the course of our relationship with you;
2.1.3 in the course of providing recruitment and/or related services to you or your organization;
2.1.4 when you make your Personal Information public;
2.1.5 when you visit and/or interact with our website or our various social media platforms;
2.1.6 when you register to use any of our recruitment and related services including but not limited to newsletters, seminars and recruitment updates;
2.1.7 when you interact with any third-party content or advertising on our website and/or our various social media platforms; or
2.1.8 when you visit our offices.
2.2 We may also receive Personal Information about you from third parties (e.g., law enforcement authorities).
2.3 In addition to the above, we may create Personal Information about you such as records of your communications and interactions with us, including, but not limited to, your attendance at events or at interviews in the course of applying for a job with us and/or in the recruitment process for obtain employment with one of our client’s (if you are successful), subscription to our newsletters and other mailings and interactions with you during the course of our digital marketing campaigns in any form.
3. CATEGORIES OF PERSONAL INFORMATION WE MAY PROCESS
We may process the following categories of Personal Information about you –
3.1 personal details: name; and photograph;
3.2 demographic information: gender; date of birth / age; nationality; salutation; title; and language preferences;
3.3 identifier information: passport or national identity number; utility provider details; bank statements; tenancy agreements;
3.4 contact details: correspondence address; telephone number; email address; and details of your public social media profile(s);
3.5 instruction details: details of individuals instructing MedE Recruit (Pty) Ltd and personal information included in correspondence, documents, evidence or other materials that we process in the course of providing recruitment services;
3.6 attendance records: details of meetings and other events organized by or on behalf of MedE Recruit (Pty) Ltd that you may and/or may not have attended;
3.7 consent records: records of any consents you may have given, together with the date and time, means of consent and any related information;
3.8 payment details: billing address; payment method; bank account number or credit card number; invoice records, payment records; SWIFT details; IBAN details; payment amount; payment date; and records of cheques and EFT payments;
3.9 data relating to your visits to our website and or social media platforms, your device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a website and/or social media platform, and other technical communications information;
3.10 employer details: where you interact with us in your capacity as an employee of an organization, the name, address, telephone number and e-mail address of your employer, to the extent relevant; and
3.11 content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages displayed to you, and any interaction you may have had with such content or advertising (including, but not limited to, mouse hover, mouse clicks and any forms you complete).
4. SENSITIVE PERSONAL INFORMATION
Where we need to process your Sensitive Personal Information, we will do so in the ordinary course of our business, for a legitimate purpose, and in accordance with applicable law.
Children’s personal information and special personal information
We do not intentionally collect or use personal information of children (persons under the age of 18 years), unless with express consent of a parent or guardian and/or in the capacity as our client the guardian and/or parent of any such child / children or if the law otherwise allows or requires us to process such personal information.
5. PURPOSES OF PROCESSING AND LEGAL BASES FOR PROCESSING
5.1 We will process your Personal Information in the ordinary course of the business of providing recruitment and related services. We will primarily use your Personal Information only for the purpose for which it was originally or primarily collected.
We will use your Personal Information for a secondary purpose only if such purpose constitutes a legitimate interest and is closely related to the original or primary purpose for which the Personal Information was collected, such as a further application for employment on your behalf. We may subject your Personal Information to processing during the course of various activities, including, without limitation, the following: –
5.1.1 operating our business;
5.1.2 analysis, evaluation, review and collation of information in order to determine recruitment issues and potential disputes, provide recruitment advice, recruitment services and/or related services and prepare or comment on opinions, memoranda, agreements, correspondence, reports, publications, documents relating to recruitment processes and other documents and records (whether in electronic or any other medium whatsoever) –
5.1.3 compliance with applicable law and fraud prevention;
5.1.4 transfer of information to our Service Providers and other third parties or
5.1.5 recruitment.
5.2 We may process your Personal Information for relationship management and marketing purposes in relation to our services (including, but not limited to, Processing that is necessary for the development and improvement of our recruitment and related services), for accounts management, and for marketing activities in order to establish, maintain and/or improve our relationship with you and with our service providers. We may also analyze your Personal Information for statistical purposes.
5.3 We may process your Personal Information for internal management and management reporting purposes, including but not limited to: conducting internal audits, conducting internal investigations, implementing internal business controls, providing central processing facilities, for insurance purposes and for management reporting analysis.
5.4 We may process your Personal Information for safety and security purposes.
6. DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES
6.1 We may process your Personal Information to our Associates, Service Providers, client’s and/or any other person or body involved in the recruitment process for legitimate business purposes, in accordance with applicable law and subject to applicable professional and regulatory requirements regarding confidentiality. In addition, we may disclose your Personal Information –
6.1.1 if required by law;
6.1.2 legal and regulatory authorities, upon request, or for the purposes of reporting
any actual or suspected breach of applicable law or regulation;
6.1.3 third party Operators (including, but not limited to, data processors such as providers of data hosting services and document review technology and services), located anywhere in the world, subject to 6.2;
6.1.4 where it is necessary for the purposes of, or in connection with, actual or threatened legal proceedings or establishment, exercise or defense of legal rights and/or in the recruitment process or related activities;
6.1.5 to any relevant party for the purposes of the prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including, but not limited to, safeguarding against, and the prevention of threats to, public security;
6.1.6 to any relevant third-party acquirer(s), in the event that we sell or transfer all or any portion of our business or assets (including, but not limited to, in the event of a reorganization, dissolution or liquidation); and
6.1.7 to any relevant third-party provider, where our website and/or social media platforms use third party advertising, plugins or content.
6.2 If we engage a third-party Operator to process any of your Personal Information, we recognize that any Operator who is in a foreign country must be subject to a law, biding corporate rules or binding agreements which provide an adequate level of protection similar to POPIA. We will review our relationships with Operators we engage and, to the extent required by any applicable law if force, we will require such Operators to be bound by contractual obligations to –
6.2.1 only Process such Personal Information in accordance with our prior written instructions; and
6.2.2 use appropriate measures to protect the confidentiality and security of such Personal Information.
7. INTERNATIONAL (TRANS-BORDER) TRANSFER OF PERSONAL INFORMATION
7.1 We may transfer your Personal Information to recipients outside the Republic of South Africa.
7.2 Subject to 6.2, Personal Information may be transferred outside the Republic of South Africa provided that the country to which the data is transferred has adopted a law that provides for an adequate level of protection substantially similar to POPIA, the Operator / third party undertakes to protect the Personal Information in line with applicable data protection legislation and the transfer is necessary in order to provide the recruitment and other related services that are required by the client’s and/or applicants of MedE Recruit (Pty) Ltd.
8. DATA SECURITY
8.1 We implement appropriate technical and organizational security measures to protect your Personal Information that is in our possession against accidental or unlawful destruction, loss, altercation, unauthorized disclosure, unauthorized access, in accordance with applicable law. We utilize the services of electronic data protection specialists to ensure, to the best of our ability, that all personal information data that is stored in electronic form is safeguarded against unlawful access. We utilize the services of electronic data protection specialists to ensure, to the best of our ability, that all personal information data that is stored in electronic form is safeguarded against unlawful access. We utilize the services of an armed response security company to protect unlawful access to our offices where data in electronic form and in tangible form is stored. We also store data in hard copy, tangible form, off site (as the need arises and if required).
8.2 Where there are reasonable grounds to believe that your Personal Information that is in our possession has been unlawfully accessed or acquired by any unauthorized person, we will notify the relevant Regulator and you, as soon as such unlawful access is discovered and / or brought to our attention, unless a public body responsible for detection, prevention or investigation of offences or the relevant regulator informs us that notifying you will impede a criminal investigation.
8.3 Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Information that is in our possession, we cannot guarantee the security of any information transmitted using the internet and we cannot be held liable for any loss of privacy occurring during the course of such transmission.
9. DATA ACCURACY
The Personal Information provided to MedE Recruit (Pty) Ltd should be accurate, complete and up to date. Should Personal Information change, the onus is on the provider of such data to notify MedE Recruit (Pty) Ltd of the change and provide MedE Recruit (Pty) Ltd with the accurate data.
10. DATA MINIMISATION
MedE Recruit (Pty) Ltd will restrict its processing of Personal Information to data which is sufficient for the fulfillment of the primary purpose and applicable legitimate purpose for which it was collected.
11. DATA RETENTION
MedE Recruit (Pty) Ltd shall only retain and store Personal Information for the period for which that data is required to serve its primary purpose or a legitimate interest of for the period required to comply with an applicable legal requirement, whichever is longer or upon an agreement between MedE Recruit (Pty) Ltd and the person/client and/or applicant.
12. YOUR LEGAL RIGHTS
You may have rights under the South African and other laws to have access to your Personal Information and to ask us to rectify, erase, and restrict use of your Personal Information. You may also have the right to object to your Personal Information being used, to ask for the transfer of Personal Information you have made available to us and to withdraw consent to the use of your Personal Information. You may, therefore, on responsible grounds, object to us using your Personal Information. If you object, we will stop using your Personal Information, except if the law allows its use and will not be able to provide the recruitment and/or related services.
Lodging a complaint
If you believe we are using your Personal Information unlawfully, please inform us first at:
Attention: Information and Data Protection Officer: Mrs. Erika Maria Myburgh.
erika@3.76.35.35 or, Landline: +27(0) 12 880 2762
Physical address: 7 Sundown Estate, Gariep Street, Pretoria, 0181, Gauteng Province. Republic of South Africa.
Postal address: 7 Sundown Estate, Gariep Street, Pretoria, 0181, Gauteng Province. Republic of South Africa.
You may lodge a complaint to the Information Regulator (South Africa) with the following contact details:
Complaints email:
POPIAComplaints.IR@justice.gov.za
PAIAComplaints.IR.@justice.gov.za
General enquiries email: inforeg@justice.gov.za.
Website: https://www.justice.gov.za.inforeg/index.html.
Physical address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
P.O Box 31533, Braamfontein, Johannesburg, 2017
Website: https://www.justice.gov.za/inforeg/index.html.
If you are in the European Union or the United Kingdom, the following details may be used for the relevant regulatory authority: –
GDPR: – In accordance with the General Data Protection Regulations: –
The European Commission Online Complaint Procedure:
Address: European Commission, Secretary-General, B-1049 Brussels, BELGIUM.
The independent Data Protection Authority (“DPA”) per member state – Website listing all DPA’s per member state:
https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
Data Protection Act, 1998 (UK): – The Information Commissioner’s Office: Website:
https://ico.org.uk/global/contact-us/
13. COOKIES AND SIMILAR TECHNOLOGIES POLICY
13.1 We may Process your Personal Information by our use of Cookies and similar technologies in future.
13.2 When you visit our website and / or social media platforms we may, in future, place Cookies onto your device, or read Cookies already on your device, subject always in accordance with applicable law. We may, in future, use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We may, in future, process your Personal Information through Cookies and similar technologies, in accordance with our Cookie Policy, which Policy we shall make available via our websites and/or social media platforms if, and when applicable.
13.3 Cookies are information that is used to track visitor use of a website and to compile statistical reports on website activity. If you wish to restrict or block cookies, you can do this through your browser settings.
Social Plugins
We may use social plugins of social networks such as Facebook, YouTube, LinkedIn, Google+ and Twitter.
Please note that we have no influence on or control over the extent of the data retrieved by the social networks’ interfaces and we can accordingly not to be held responsible or liable for any processing or use of personal information transmitted via these social plugins. For information on the purpose and extent of the data retrieval by the social network concerned, and about the rights and settings possibilities for the protection of your private sphere, please refer to the data protection information provided by the social network in question.
14. DIRECT MARKETING
14.1 We may Process your Personal Information for the purposes of providing you with information regarding services that may be of interest to you. You may unsubscribe for free at any time.
14.2 If you currently receive marketing information from us which you would prefer not to receive in the future, please email us at: erika@3.76.35.35
15. CONTACT DETAILS
You may contact us at –
The Data Protection Officer / Information Officer: MedE Recruit (Pty) Ltd / Attention:
Mrs. Erika Maria Myburgh
erika@3.76.35.35 or, Landline: +27 (0) 12 8802762 or Cellular 082 440 9654
Physical Address: 7 Sundown Estate, Gariep Street, Pretoria, 0181, Gauteng Province. Republic of South Africa.
Postal Address: 7 Sundown Estate, Gariep Street, Pretoria, 0181, Gauteng Province. Republic of South Africa.
ANNEXURE A – DEFINITIONS
“Associates” means and include MedE Recruit (Pty) Ltd and where applicable, partners, directors, employees and consultants of MedE Recruit (Pty) Ltd or of any of its subsidiaries, if and when applicable.
“Cookie” means a small file that is placed on your device when you visit a website. In this Policy, a reference to a “Cookie” includes analogous technologies such as web beacons and clear Graphic Interchange Format files (“GIFs”).
“Operator” means any person or entity that Processes Personal Information on behalf of the Responsible Party.
“Personal Information” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
Where we refer to “personal information,” it means “personal information” as defined in the Protection of Personal Information Act, 4 of 2013 as amended from time to time (“POPI”), and “personal data” as per the General Data Protection Regulation 2016/679 (“the GDPR”). Personal Information includes any information about a person that can be used to identify a person directly or indirectly. It includes information like a name, an identification number, location information, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person. POPI includes the personal information of juristic persons in its ambit – so we will protect the personal information of juristic persons in the same manner as any other person’s personal information.
“POPIA” means the Protection of Personal Information Act, 4 of 2013, as amended.
“Process,” ‘Processing” or “Processed” means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaption or alteration, retrieval, consolations disclosure by transmission, dissemination or otherwise making available alignment or combination, restriction, erasure or destruction.
“Responsible Part’ means the entity that decided how and why Personal Information is Processed – in this instance: The Head of the Private Body: Mrs. Erika Maria Myburgh, MedE Recruit (Pty) Ltd as per address and contact details stated herein above.
“Sensitive Personal Information” means Personal Information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that may be deemed to be sensitive under applicable law.
“Service Provider” – Third party providers of various services whom we engage, including, but not limited to, providers of information technology, communication, file storage, data storage, copying, printing, accounting or auditing services, counsel, experts, investigators, translators and our insurers and professional advisors.
“Website” means any website operated, or maintained, by us or on our behalf and includes all social media platforms – such as our website: http://3.76.35.35 and Facebook Business page: MedE Recruit and any other social media pages in the name of MedE Recruit and operated by MedE Recruit.
Where applicable, this Privacy Policy applies in addition to any other agreement that you enter into with us, including the letter of engagement that you agree to when you become a client and/or applicant of MedE Recruit (Pty) Ltd and issue us with instructions to perform services as requested by you on your behalf.
