Privacy Policy | Codehesion

Introduction
1. Codehesion (Pty) Ltd provide this Privacy Notice to inform applicants for jobs with us aware of our policy relating to the processing of personal information.
2. This Notice sets out the basis on which we will process your personal information. Please read the Notice carefully to understand our practices regarding your personal information and how we will use it.
About Us
1. Codehesion (Pty) Ltd is a company registered in South Africa under number 2016/126390/07.
2. Our Information Officer is Hector Beyers. His contact details are as follows:
  - Telephone: +27 82 079 7755
  - Post: Block D, Southdowns Office Park, Centurion, 6002, South Africa
    If you have any questions about this Privacy Notice or your information, or to exercise any of your rights as described in this Notice or under applicable data protection laws, you can contact the Information Officer.
Data Protection Conditions
1. Anyone processing personal information must comply with the conditions of processing personal information as set out below:
  - Accountability: the responsible party must ensure that the rest of the conditions are in place before processing data.
  - Processing Limitation: data must be collected directly from the data subject (except for in specific circumstances) and must be adequate, relevant and limited to what is necessary for the data processing purposes.
  - Purpose Specification: data must be collected for specified, explicit and legitimate purposes, and it must not be kept for longer than is necessary for these stated purposes.
  - Further Processing Limitation: data must be processed in a manner that is compatible with the purpose stated.
  - Information Quality: data must be accurate and, where necessary, kept up to date.
  - Openness: data must be processed lawfully, fairly and in a transparent manner.
  - Security Safeguards: data must be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage by using appropriate technical or organisational measures.
  - Data Subject Participation: data subjects must be informed of their rights and special categories of data may only be processed in limited circumstances, including when consent has been provided.
2. This Privacy Notice describes the personal information that we collect and explains how we comply with these conditions.
What Information We Collect
1. We ask for personal information from job applicants to assist with our recruitment processes and to monitor recruitment statistics. Information that we may collect includes, but is not limited to, the following:
  - your name; home address and contact details (such as telephone number and email address);
  - date of birth;
  - gender;
  - marital status;
  - details of your qualifications, skills, experience and employment history;
  - languages spoken and level of proficiency;
  - information about your current level of remuneration, including benefit entitlements;
  - whether or not you have a disability for which we need to make reasonable adjustments during the recruitment process;
  - where required by local law, information about your entitlement to work in the country where we are hiring;
  - copies of ID/passport, driving licence and similar documents;
  - other information given in your CV; and
  - data from building access controls including images from CCTV operating in and around our offices.
How We Collect Your Information
1. We may collect the information (as described in section ‎4) in a variety of ways. For example, data might be contained in the online application process, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.
2. We may collect personal information from third parties, such as references provided by former employees and by recruitment agencies with whom you have registered an interest. Such recruitment agencies support our recruitment processes under a duty of confidentiality.
3. We may also receive other information about you from organisations such as credit reference agencies, fraud prevention agencies and referees.
4. During the recruitment process we may also research information regarding your skills, experience or qualifications and comments and opinions made public on social networking sites such as LinkedIn, Facebook and Twitter.
Special Categories of ("Sensitive") Personal Data
1. You may also supply us with, or we may receive, sensitive personal data relating to your racial or ethnic origin, political opinions, religious or philosophical beliefs, or data concerning your health or data concerning your sex life or sexual orientation.
2. We will use this information for the purposes of carrying out our obligations as an employer including monitoring of equality of opportunity, to assess suitability for particular jobs and to consider whether adjustments may need to be made to accommodate an applicant with a disability.
Data Relating to Criminal Convictions & Offences
1. We may also collect, store and otherwise process personal data relating to criminal convictions and offences (including the alleged commission of offences).
2. This data is only processed where it is necessary for the purposes of:
  - the prevention or detection of an unlawful act;
  - or in connection with any legal proceedings (including prospective legal proceedings);
  - obtaining legal advice; or
  - establishing, exercising or defending legal rights.
What We Do With Your Information
1. Any information about you which is obtained by us during the application process (whether obtained directly from you or from third parties such as your referees) may be used by us for the following purposes:
  - to consider your suitability for employment;
  - to take up your references;
  - to conduct appropriate checks;
  - to comply with our legal and regulatory obligations and for other legal purposes; and
  - to negotiate and communicate with you in relation to your application.
2. Your information will not be used for other purposes without your permission, save as required by applicable law.
The Legal Basis For Our Processing
1. The legal basis for our processing of your personal information is based on the fact that you or an agent on your behalf (e.g. recruiter), have applied to us for a position and it is necessary for us to process your information in order to consider your application in line with our legitimate recruitment purposes.
2. The legal basis for our processing of any special categories of (sensitive) personal information is for the purposes of carrying out our obligations as an employer.
Sharing Your Information With Third Parties
1. When you apply for a role at Codehesion, this is via our careers page which is hosted in South Africa.
2. For the purposes set out in section 8 above, your information may be shared with our authorised staff (including recruitment team, interviewers, managers in the business area with a vacancy and IT staff if necessary).
3. We may disclose your information to departments other than the one to which you may have originally applied to work if we think it is appropriate to do so for the above purposes.
4. We may also disclose your personal information to third parties where there is a legitimate reason to do so including for the following reason:
  - if we are under a duty to disclose or share your personal information in order to comply with any legal obligation.
Security of Your Information
1. We store your information in hard copy and in electronic format. We use industry standard physical and procedural security measures to protect information. Hard copy information files are restricted to authorised individuals. We use, as appropriate, encryption, firewalls, access controls, policies and other procedures to protect information from unauthorised access.
2. Where appropriate, we use pseudonymisation and / or encryption to protect your information.
How Long We Keep Your Information
1. If your application is successful, and you subsequently become employed by us, the information will become part of your personnel file. The information contained in this will be kept secure and will only be used for purposes directly relevant to your employment and in accordance with our Employee Privacy Notice, a copy of which will be provided to you.
2. Once your employment with us has ended, we will retain the file for seven years in accordance with our data retention policy and then delete it.
3. Personal information about unsuccessful candidates will be held for 12 months after the recruitment exercise has been completed. It will then be destroyed or deleted. We may retain de-personalised statistical information about applicants to help inform our recruitment activities, but no individuals are identifiable from that data.
Your Rights
1. You have the following rights:
  - to obtain access to, and copies of, the personal information that we hold about you;
  - to require that we cease processing your personal information if the processing is causing you damage or distress;
  - to require us not to send you marketing communications (if applicable);
  - to require us to erase your personal information;
  - to require us to restrict our data processing activities;
  - to receive from us the personal information we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal information to another responsible party; and
  - to require us to correct the personal information we hold about you if it is incorrect.
2. Please note that the above rights are not absolute, and we may be entitled to refuse requests, wholly or partly, where exceptions under applicable law apply.
Exercising Your Rights
1. You can exercise any of your rights as described in this policy and under data protection laws by contacting our Information Officer.
2. Save as provided under applicable data protection laws, there is no charge for the exercise of your legal rights. However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either: (a) charge a reasonable fee (subject to any limits imposed by applicable law) taking into account the administrative costs of providing the information or taking the action requested; or (b) refuse to act on the request.
3. Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm your identity.
4. You are under no statutory or contractual obligation to provide information to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.
Complaints
1. You have the right to complain to the Information Regulator (https://www.justice.gov.za/inforeg/) in South Africa about our data processing activities in relation to your personal information if you think they infringe applicable data protection laws.
Updates to This Privacy Notice
1. We may amend this policy at any time. This Privacy Notice was last updated in January 2022.

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