Bolt Talent Solutions is committed to fully complying with this act for our employees, candidates and clients who place their trust in us to act responsibly and ethically with their personal information. This act provides that everyone has the right to privacy and it includes a right to protection against the unlawful collection, retention, dissemination and use of personal information.

POPI has been promulgated to regulate, in harmony with international standards, the processing of personal information by public and private bodies in a manner that gives effect to the right to privacy subject to justifiable limitations that are aimed at protecting other rights and important interests.

We have appointed XXX as an information officer to encourage compliance with the conditions for the lawful processing of personal information. The 2018 Regulations set out additional responsibilities for Information Officers which is listed below: 

• The development, implementation, monitoring and maintenance of this policy.
• The development of terms in recruitment systems where candidates can request information.
• That documentation is relevant and kept up to date.
• Conduct personal information impact audit/assessment is done.
• Internal employee awareness sessions are conducted regarding POPI as well as general updates to be communicated to managers, staff and associates.

POPI covers all information that employers /recruiters might collect, retain or archive on any individual who might wish to work, work, or have worked for. This includes both personal and special personal information. Personal information is defined as information which is about a living identifiable person (a ‘data subject’) and affects that person’s privacy (whether in his/her personal or family life, business or professional capacity) in the sense that the information has the person as its focus or is otherwise biographical in nature and identifies a person, whether by itself, or together with other information in the organisation’s possession or that is likely to come into its possession.

Personal information may include and is not limited to; details of an employee/candidates’ salary, bank account information, e-mails about an incident, a supervisor’s notebook, an individual employee’s personnel file, leave records, performance reviews, a set of leave cards depending upon how they are kept and a set of completed application forms filed in a particular order.

Special personal information is information concerning an individual’s religious or philosophical beliefs, race or ethnic origin, trade union membership, political persuasion, health or sex life or biometric information, the criminal behaviour of a person subject to the extent that such information relates to the alleged commission by the employee of any offence or any proceedings in respect of any offence allegedly committed by an employee or about the disposal of such proceedings.

Special personal information processed by an employer/recruiter might typically be about an employee’s physical or mental health as a part of medical records, records obtained as part of a pre-employment medical questionnaire or examination, various drug or alcohol test results, pre-employment screening records relating to criminal convictions and any aspect of special personal information.

‘Data subjects’: who are they within an employment context? POPI refers to the persons to whom personal information relates, as “data subjects”. Within an employment context, this includes applicants and former applicants (successful or unsuccessful), former or current employees, Temporary Employment Services staff, casual staff, staff on secondment and those on work experience placements. The personal information of all of these people must be dealt with in accordance with POPI.

POPI applies to any personal information entered into any record by an employer, recruitment agency or third party vendor. Personal information about individuals that is kept on a computerised system in the employment/recruitment context.

POPI applies only to personal information and special personal information that is subject to ‘processing’ or ‘further processing’. The term ‘processing’ applies to a comprehensive range of activities. It includes the initial obtaining of personal information, the retention and use of it, access and disclosure and final disposal of the data. The processing of personal information in the workplace from recruitment to retirement is covered in this policy.

We commit to complying with the 8 conditions specified in POPI regulations. The eight conditions for the lawful processing of personal information are:

  1. Accountability
  2. Processing limitation
  3. Purpose specification
  4. Further processing limitation
  5. Information quality
  6. Transparency & Openness
  7. Security safeguards
  8. Data subject participation
  1. Accountability:
    We take reasonable steps to ensure that personal information obtained from candidates is stored safely and securely. This includes CV’s, Resumes, References, Qualifications, Integrity Checks and any other personal information that may be obtained for the purpose of candidate representation.

  2. Processing limitation:
    Personal information will be obtained directly from the applicant for employment or employee unless the information is derived from a public record or the employee has consented to the use of another source or has made the information public on for instance social media. The processing limitation is especially relevant to the verification of information furnished by applicants for positions when only relevant and adequate information should be sought and verified.

  3. Purpose specification:
    We collect personal information from candidates to enable us to represent them to our clients for the purpose of recruitment. We inform applicants or employees of this purpose through our applicant tracking system and social media sites. Without the consent of an employee, an employer may only retain records of personal information for as long as it is necessary to achieve the specific purpose for which the information was collected.

  4. Further processing limitation
    Personal information may not be processed further in a way that is incompatible with the purpose for which the information was collected initially. We collect personal information for recruitment and it will only be used for that purpose.

  5. Information quality:
    We take responsibility & take reasonably practical steps to ensure that personal information of candidates & employees is complete, accurate, not misleading and updated where necessary. Special care is required where information is collected from a source other than the employee personally.

  6. Transparency & Openness:
    Where personal information is collected from a source other than directly from a candidate (Example: Social media, Job Board Portals) we are responsible for ensuring that the candidate is aware:
    – That their information is being collected
    – Who is collecting their information by giving them our details
    – Of the specific reason, you are collecting their information.
  1. Security Safeguards:
    We secure the integrity and confidentiality of all personal information in our possession or under our control by taking appropriate, reasonable technical and organisational measures to prevent loss of or damage to or unauthorized destruction, unlawful access to or processing of personal information. We have invested significantly in Google for business as our operating system. Our website, recruitment system and video interviewing tool are cloud-based third-party solutions. The reasonable measures to protect the personal information include identification of possible security risks, establish and maintain safeguards against the risks, verify the safeguards from time to time and update those measures. Virus programmes, back-ups and off-site storage are paramount to securing our data. The measures must comply with generally accepted information security practices.

  2. Employee participation
    Candidates & employees are entitled to know particulars of their personal information held by us, as well as the identity of any authorised employees of our agency that had access thereto.

Operational Considerations

The Board/Management and Information Officer are responsible for administering and overseeing the implementation of this policy and, as applicable, supporting guidelines, standard operating procedures, notices, consents and appropriate related documents and processes.

All employees, subsidiaries, business units, departments and individuals directly associated with us are to be trained, according to their functions, in the regulatory requirements, policies and guidelines that govern the protection of personal information.

We will conduct periodic reviews and audits, where appropriate, to ensure compliance with this policy and guidelines.

Operating controls
We shall establish appropriate standard operating procedures that are consistent with this policy and regulatory requirements. This will include: 

– Allocation of information security responsibilities. 
– Incident reporting and management. 
– User ID addition or removal. 
– Information security training and education. 
– Data backup.

Policy Compliance
Any breach of this policy may result in disciplinary action and possible termination of employment.


Bolt Talent Solutions will collect your personal details and contact information.

  1. We’ll use your information to process your request for information about our video interviewing tool and solution.
  2. We’ll use your information to reach out to you about our recruitment services. 

By submitting this personal data and application, you (1) declare that you have read, understood and accepted the statements set out in this data protection clause; (2) are declaring that to the best of your knowledge the information given in the application is complete and true; (3) are giving your consent to the processing of the information contained in this application and any other personal data you may provide separately in the manner and to the extent described.

We retain your personal information for a period not exceeding 36 months and use the information held about you in the following ways: 1) To review your application in respect of the video interview solution for which you have applied. 

Bolt Talent Solutions is an equal opportunities employer and agency where we pride ourselves in complying with regulations and hiring best practice. Thank you for placing your trust in us in supporting you to develop your company and hiring process further.