POPIA / Candidate Data Privacy Policy

1. Purpose

This policy explains how Vettam Talent collects, uses, stores, shares, protects, and deletes candidate personal information. Vettam handles candidate information as a serious business asset and legal responsibility. Candidate data must only be used for legitimate recruitment, staffing, verification, compliance, and workforce management purposes.

2. Legal Basis

This policy is aligned with and operates under South African law, including:

• Protection of Personal Information Act 4 of 2013 (POPIA)
• Employment Services Act 4 of 2014
• Employment Equity Act 55 of 1998
• Labour Relations Act 66 of 1995
• Basic Conditions of Employment Act 75 of 1997, where employment records apply

3. Personal Information Vettam May Collect

Vettam Talent may collect and process:

• Name, surname, South African ID number, passport number, nationality, and contact details (email, phone, physical location).
• Curriculum Vitae (CV), employment history, qualifications, trade test certificates, licences (e.g. Code 14), Red Seal papers, and nominated references.
• Skills evaluations, assessment outcomes, screening results, interview notes, availability, salary/wage expectations, and preferred working locations.
• Identification documents, work permits, medical fitness certificates, safety records, and site access clearances where required for lawful placement.
• Photographs, strictly where required for candidate profile cards, client site access, identity matching, or agreed verification workflows.
• Criminal record, credit, qualification, reference, and prior employment verification checks only where lawful, relevant to the role, and explicitly consented to.

4. Collection Rules

In accordance with POPIA condition principles, Vettam Talent will:

• Collect only personal information directly needed for recruitment, staffing, competency verification, or statutory compliance.
• Clearly inform candidates why their information is being collected and how it will be processed.
• Collect special personal information only when strictly required for a lawful, relevant recruitment or statutory purpose.
• Avoid collecting excessive or unnecessary personal information.
• Maintain candidate records as accurate, complete, and up-to-date as reasonably possible.

5. Use of Candidate Information

Candidate personal information may be used to:

• Assess technical suitability, qualifications, and operational fit for artisan and industrial roles.
• Match candidate trade profiles against client job specifications and active vacancies.
• Conduct lawful background screening, reference checks, and credential verifications.
• Communicate directly with candidates regarding job opportunities, technical assessments, interviews, onboarding, or site placements.
• Prepare anonymised or detailed candidate profile summaries for client review.
• Administer temporary employment and payroll records if Vettam employs the contractor or worker directly.
• Comply with South African tax, labour, bargaining council, occupational health, safety, and client site statutory requirements.

6. Sharing Candidate Information

Vettam Talent may share candidate information with:

• Prospective Employers / Clients: Authorised clients considering the candidate for an open placement, only after candidate consent has been obtained.
• Verification & Screening Partners: Accredited background check and qualification verification agencies, strictly where necessary and consented to.
• Professional Services: Payroll, human resources, legal, accounting, insurance, occupational health, or statutory compliance providers where relevant.
• Statutory Bodies: Regulators, bargaining councils, dispute resolution bodies, the Information Regulator, or law enforcement authorities where required by South African law.

Vettam will not transmit an unredacted CV, identification document, trade certificates, reference notes, or background screening results to third parties without candidate consent and internal management authorisation.

7. Storage and Security

Candidate records are stored exclusively in approved enterprise environments, including Vettam's secure Thuto Stack database, authorised CRM systems, encrypted cloud infrastructure, Google Workspace, and access-controlled repositories.

Access is restricted strictly to authorised personnel requiring the data for recruitment, placement, payroll, or compliance duties. Candidate data is never stored on unapproved personal devices, unsecured personal email accounts, or public storage media.

8. Cross-Border Transfers

Candidate information will only be transferred outside the Republic of South Africa if:

• The transfer is necessary for cloud hosting, secure infrastructure, or recruitment software operations.
• The recipient is bound by data protection laws or binding corporate agreements providing an adequate level of protection substantially similar to POPIA.
• The transfer complies fully with Section 72 of POPIA.

9. Automated Processing and AI

Vettam Talent employs advanced recruitment matching systems (including Thuto Stack) and AI-assisted tools to assist in parsing CVs, categorising trade competencies, and surfacing relevant opportunities.

10. Data Retention and Deletion

Candidate information is retained only for as long as necessary to fulfil legitimate recruitment purposes, maintain active placement pools, or comply with South African statutory record-keeping periods (e.g. tax, labour, and employment records).

When personal information is no longer needed and there is no legal obligation to retain it, records will be securely destroyed, deleted, or de-identified.

11. Candidate Rights under POPIA

Under Chapter 3 of POPIA, all candidates have the legal right to:

• Access: Request confirmation of whether Vettam holds their personal information and request a copy of such records.
• Correction & Update: Request the correction, completion, or update of inaccurate or outdated information.
• Withdrawal of Consent: Withdraw consent to processing at any time, subject to statutory retention requirements.
• Object: Object on reasonable grounds to the processing of personal data.
• Erasure: Request the deletion or destruction of personal information where Vettam is no longer authorised to retain it.
• Complaint: Lodge a complaint with the South African Information Regulator (inforegulator.org.za).

12. Responsibilities & Enforcement

Vettam Talent management is responsible for policy oversight and compliance enforcement. Recruiters and operations staff are accountable for lawful collection and ethical handling. Any suspected security incident or data breach must be reported immediately to management for containment, assessment, and statutory notification.

13. Practical Operating Standard

Vettam Talent adheres to a fundamental operating principle: If we would not be comfortable explaining the data use directly to the candidate, the client, or the Information Regulator, the information will not be collected, processed, or shared.

14. Contact Vettam Regarding Privacy

To exercise your data privacy rights, request data updates, or make an enquiry, contact our Information Officer: