Recruitment Matters Privacy Notice

Version: 1.0

Effective Date: 1 June 2025

Introduction

Recruitment Matters is committed to protecting the privacy and security of your personal information. This Privacy Notice outlines how we collect, use, process, and protect your personal information. We comply with relevant data protection legislation, including the South African Protection of Personal Information Act (POPI Act), the Zimbabwe Cyber and Data Protection Act [Chapter 12:07] and the Zambian Data Protection Act, No 3 of 2021. This privacy notice provides the framework and measures within our company regarding the protection of individuals’ privacy. All employees and external service providers managing information technology are required to adhere to the principles and measures contained herein.

1. What is Personal Information?

Personal information is broadly defined as any information relating to an identified or identifiable living individual. This definition is comprehensive and aligns with the types of information protected under POPI. Examples of personal information we may collect and process include, but are not limited to:

• Personal Identifiers: Name, address, and contact details (telephone number, email address).
• Demographic Data: Age, sex/gender, marital status, family status, race, national or ethnic origin, colour, religious or political beliefs or associations.
• Identifying numbers or symbols: National ID number, driver’s license number.
• Biometric Information: Fingerprints, inheritable characteristics (though we do not typically collect these for recruitment).
• History: Educational, financial, criminal, or employment history, healthcare history (including disabilities).
• Opinions: Opinions expressed about you or your personal views (unless about someone else).
• Online Identifiers: IP addresses, location data, and device information (may be collected when you use our website or interact with us online).
• Recruitment Specific Data: CVs, resumes, references, qualifications, background check results.

This includes any document you provide that falls under the definition of personal information.

2. What Personal Information Do We Collect?

In the course of providing our recruitment services, we may collect categories of your personal information similar to those defined above. Specifically, we collect personal information directly from candidates, which may include:

• Full names, email address, phone number, and physical address.
• Details from your CV/resume, such as employment history, educational background, skills, and qualifications.
• Information obtained from references you provide.
• Information gathered during background checks (criminal record, qualifications, credit history, etc.), where relevant and permissible.

• Demographic information like age and gender.

• Information collected when you interact with us online or use our website, including technical data like IP address, browser type, and device information.

• Information from social media platforms if you interact with our pages or posts, including aggregate data on followers and engagement data. If you use social media or third-party registration features, certain information like your IP address, email address, name, and profile picture may be collected.

• Other data such as preferences or feedback you provide.

Where personal information is collected from sources other than directly from you (such as job portals or social media), we are responsible for making you aware that your information is being collected, who is collecting it, and the specific reason for collection.

3. How We Use Your Personal Information (Purposes of Processing)

We process your personal information for the following purposes:

• To enable Recruitment Matters to refer you to a client for employment by sending your CV containing personal information. This is the primary purpose.

• To represent you to our clients for the purpose of finding and securing employment.

• To perform the required checks (reference checks, criminal record, qualifications, credit history etc.).

• To manage your profile and communicate with you regarding potential opportunities or updates to your information.

• To maintain and improve our recruitment services.

• To monitor the usage of our services and detect or prevent technical issues.

• To comply with legal and regulatory obligations.

Personal information will not be processed in a way that is incompatible with the purpose for which it was collected initially, unless you have provided consent.

4. Lawful Basis for Processing

The Act requires that we have a lawful basis for processing your personal information. Our processing activities are based on one or more of the following:

• Consent: Where you have freely given your explicit consent for a specific purpose, such as submitting your CV to be considered for employment and agreeing to its use for recruitment purposes. You voluntarily authorize us to process your personal information for recruitment purposes. We will contact you and obtain consent before sending your CV to a client for a specific position or purpose.

• Contract: Where processing is necessary for the performance of a contract with you, although the primary basis for candidate data processing is usually consent in the recruitment context.

• Legal Obligation: Where processing is necessary for compliance with a legal obligation that applies to us.

• Legitimate Interests: Where processing is necessary for our legitimate interests or the legitimate interests of a third party (e.g., potential employers), provided your interests and fundamental rights do not override those interests. This may include maintaining a database of candidates for future relevant opportunities, provided appropriate safeguards are in place and consent is considered.

• Other bases like Public Interest or Vital Interests are generally less common in the standard recruitment process.

Consequences of Withholding Consent or Personal Information: Recruitment Matters will not be able to assist you to find employment should you refuse to provide us with consent or withhold information necessary for the recruitment process.

5. Who We Share Your Personal Information With (Recipients)

We may share your personal information with the following categories of recipients:

• Our employees and authorized personnel for lawful and legitimate purposes relating to recruitment.
• Clients (potential employers) to whom we refer you for employment opportunities, always with your consent for a specific position or purpose.
• Third-party service providers who assist us in delivering our services, such as providers performing background checks or hosting our database. These third parties have access to your Personal Data only to perform tasks on our behalf and are obligated not to disclose or use it for any other purpose.
• Legal authorities or regulatory bodies when required by law.
• We are committed to ensuring that information is only used for legitimate purposes with candidate consent and only by authorized employees of our agency.

6. Transfer of Personal Information Outside the border

We may transfer your personal information to countries outside for purposes such as recruitment processes with international clients or potentially for hosting and backup services, depending on our infrastructure. We will ensure that such transfers comply with the Acts and regulations and that your personal information is adequately protected, for example, by ensuring that the companies with whom we share your information comply with relevant data privacy laws.

7. Your Rights Under 

As a data subject you have certain rights regarding your personal information. These rights are consistent with, and in some cases expand upon, the rights you have under the data protection laws in South Africa, Zimbabwe and Zambia:

• Right to be Informed: You have the right to be informed about the collection and use of your personal information. This Privacy Notice serves to fulfill this right.

• Right to Access: You have the right to request access to your personal information that we hold. You are permitted to know any particulars of your personal information held by us, as well as the identity of any authorized employees that had access thereto.

• Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal information we hold about you. We endeavor to keep your information up to date and request that you notify us of any changes.

• Right to Erasure (Right to be Forgotten): You have the right to request the deletion of your personal information under certain circumstances.

• Right to Restriction of Processing: You have the right to request that we restrict the processing of your personal information in certain situations.

• Right to Data Portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that data to another controller without hindrance.

• Right to Object: You have the right to object to the processing of your personal information in certain circumstances.

• Right to Revoke Consent: You may revoke your consent given to us in terms of this form at any time. Your revocation should be in writing. Note that revoking consent is not backdated and will not affect use of your information already made.

• Rights Related to Automated Decision-Making including Profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, unless there is a lawful basis for such processing.

8. How to Exercise Your Rights

To exercise any of your rights under the relevant Acts, please contact us using the details provided in the “Contact Us” section below.

You may specifically:

• Access, correct, or delete your data unless the data is required by law.
• Restrict processing or object to processing.
• Request data portability

• Withdraw consent.

We may require you to provide proof of your identity before we can respond to your request. We will respond to requests regarding your rights within 30 days.

9. Data Security

We have implemented appropriate technical and organizational measures to safeguard your personal information against unauthorized access, use, disclosure, alteration, or destruction. We ensure our internal measures are secure to protect the integrity of personal information and guard against risk of loss, damage, or destruction thereof. Personal information must also be protected against any unauthorized or unlawful access or processing. The security of your data is important to us, though remember that no method of transmission over the Internet or electronic storage is 100% secure.

We have established appropriate standard operating procedures consistent with this policy, including allocation of information security responsibilities, incident reporting and management, user ID addition or removal, information security training and education, and data backup. We are committed to ensuring that information is only used for legitimate purposes with candidate consent and only by authorized employees of our agency.

10. Data Retention

We will retain your personal information for as long as necessary to fulfill the purposes for which it was collected and to comply with our legal and regulatory obligations. All personal information provided to Recruitment Matters will be held and/or stored securely for the purpose of recruitment or re-recruitment. Once this information is no longer required, such personal information will be safely and securely archived for a period of 5 years, as per the requirements of the Companies Act, 71 of 2008. Thereafter, all your personal information will be permanently destroyed.

11. Changes to this Privacy Notice

We may update this Privacy Notice from time to time to reflect changes in our practices or legal requirements. We will notify you of any material changes by posting the updated notice on our website or through other appropriate communication channels. The version number and date at the top of the privacy notice will indicate when it was last updated. The current version shall supersede and replace all previous versions of this policy unless otherwise stated. You are advised to review this Privacy Notice periodically for any changes.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Notice or our data protection practices, please contact our data protection office DPO:

Zimbabwe: +263 242 746340 / 348 / 349

Email:  [email protected]

South Africa: +27 21 203 0700

Zambia: +260 96 451 4175 / +260 95 424 0012

13. Disclaimer: 

This Privacy Notice is intended to provide general information about how we handle personal data. It is not a substitute for legal advice and may be updated as required by law or operational needs.