This Privacy & POPIA Notice ("Notice") explains how Elite Talent (Pty) Ltd ("Elite Talent", "we", "us", "our") collects, uses, shares and protects Personal Information in connection with our talent introduction and placement services at www.elitetalent.africa (the "Site" and, together with our services, the "Services").
This Notice is drafted in accordance with the Protection of Personal Information Act, 2013 (POPIA) and the Electronic Communications and Transactions Act, 2002. Privacy is not a compliance afterthought in our model; confidentiality and consent are how the service works. Candidate profiles are anonymised by default, and no candidate is ever identified to an employer without that candidate's explicit consent.
Contents
- 1. Definitions
- 2. Who this Notice covers
- 3. Information we collect
- 4. How we use candidate information
- 5. From the Vault and anonymisation
- 6. Introductions and consent
- 7. Employer and subscriber information
- 8. Legal bases for processing
- 9. Sharing and disclosure
- 10. Elite CV and related services
- 11. Cross-border transfers
- 12. Retention
- 13. Security safeguards
- 14. Your rights
- 15. Direct marketing
- 16. Cookies
- 17. Minors
- 18. Third-party links
- 19. Changes to this Notice
- 20. Information Officer and contact
1.Definitions
Terms defined in POPIA ("Personal Information", "Processing", "Data Subject", "Responsible Party", "Operator") have those meanings here. In addition: "Candidate" means an individual who is, or is applying to become, Elite Talent (our vetted talent community, whose Profiles are held in the "Vault"); "Employer" means a company or person using our Services to receive profiles or introductions; "Profile" means an anonymised summary of a Candidate's experience and availability; "Introduction" means the disclosure of a Candidate's identity to an Employer; and "From the Vault" means our curated email publication of Profiles.
2.Who this Notice covers
This Notice applies to: Candidates and applicants; Employers, From the Vault subscribers and Talent Partner members; and visitors to the Site. It does not apply to Processing carried out independently by an Employer after receiving Candidate information through an Introduction; from that point the Employer is a Responsible Party in its own right under POPIA (see section 9).
3.Information we collect
3.1 From Candidates
- Identity and contact details (name, email, phone, location);
- Career information: CVs, employment history, qualifications, professional registrations (e.g. CA(SA)), skills, achievements, portfolios and references;
- Engagement preferences: availability, engagement types (full-time, fractional, interim, board), remuneration expectations and location preferences;
- Vetting information: interview notes, reference outcomes, skills assessment results and, where relevant and consented to, qualification or registration verification;
- Consent records: what you agreed to, when, and for which opportunities.
3.2 From Employers and subscribers
- Business contact details of representatives (name, role, work email, phone);
- Company information, briefs, role requirements and package bands;
- Billing details and transaction records (payments are processed by third-party payment providers; we do not store full card numbers).
3.3 Collected automatically
- IP address, browser and device information, and usage data on the Site;
- Email engagement data for From the Vault (delivery, opens, clicks) via our email service provider.
4.How we use candidate information
- To assess applications against our vetting criteria;
- To prepare anonymised Profiles;
- To match Candidates to briefs, including with the assistance of AI-based matching tools operating over our own database (all shortlisting decisions are reviewed by a person; no Introduction is ever made by automated decision alone);
- To administer role-appropriate skills assessments, with your consent, and to share the outcome with the Employer concerned as part of an Introduction;
- To make Introductions, with your consent per opportunity;
- To communicate with you about opportunities, availability and administration;
- To provide interview preparation and placement support;
- To maintain records required by law or for the establishment or defence of legal claims.
5.From the Vault and anonymisation
5.1 Profiles published in From the Vault or shown in the Vault (our members-only database) are anonymised: they exclude your name, current employer name, photograph and any detail that we reasonably consider could identify you. You may review your Profile before first publication and request changes.
5.2 Anonymisation at senior levels has limits; a sufficiently specific combination of industry, role and achievement may narrow the field. We mitigate this by generalising identifying details, and you may instruct us to exclude specific facts from your Profile, to withhold your Profile from specific companies or sectors, or to stay out of From the Vault entirely and be considered only for direct briefs.
6.Introductions and consent
6.1 Your identity is disclosed to an Employer only after we have told you who the Employer is and the nature of the opportunity, and you have given explicit consent for that specific Introduction.
6.2 You may decline any opportunity without giving reasons and without affecting your standing as Elite Talent.
6.3 You may withdraw consent, or withdraw entirely, at any time by written notice to us. Withdrawal does not affect Processing that occurred before withdrawal, and we may retain limited records as described in section 12.
7.Employer and subscriber information
We use Employer and subscriber information to deliver From the Vault, respond to briefs, make Introductions, administer Memberships, invoice for Services, and maintain our client records. Business contact information may be used for direct marketing of our own Services in accordance with section 15.
8.Legal bases for processing
- Consent: the primary basis for all Candidate profiling, publication and Introductions;
- Contractual necessity: to perform our obligations to Employers, members and Candidates;
- Legitimate interests: to operate, secure and improve the Services, and for proportionate business administration;
- Legal obligation: to comply with POPIA, tax and other applicable laws.
9.Sharing and disclosure
9.1 To Employers: anonymised Profiles are shared with subscribers and members; identified Candidate information is shared only under section 6. Employers receiving identified Candidate information become Responsible Parties for it and are contractually required to process it only for the recruitment purpose concerned, keep it confidential, and delete it on request if no placement occurs.
9.2 To Operators: we use service providers for email delivery, hosting, cloud storage, payment processing, accounting and analytics. All Operators are bound by written agreements requiring POPIA-equivalent protection and confidentiality.
9.3 Legal disclosures: we may disclose Personal Information where required by law, court order or regulatory authority, or to protect our rights or the safety of any person.
9.4 We do not sell Personal Information, and we do not share Candidate databases in bulk with any third party.
10.Elite CV and related services
Elite CV (elite-cv.com) is Elite Talent's sister company under common ownership. The two services maintain separate mandates: being a client of Elite CV does not make you Elite Talent, and your Elite CV information is not used for Elite Talent purposes unless you expressly opt in to become Elite Talent. Where you do opt in, the information you authorise is transferred into the Vault under this Notice.
11.Cross-border transfers
Where Personal Information is transferred outside South Africa (for example, to cloud or email providers, or to an Employer in another African jurisdiction), we ensure the recipient is subject to a law, binding corporate rules or a binding agreement providing an adequate level of protection substantially similar to POPIA, or we obtain your consent to the transfer.
12.Retention
We retain Personal Information only as long as necessary for the purposes described in this Notice, or as required by law. Vault profiles are reviewed periodically and archived when Candidates become unreachable or withdraw. On withdrawal, we delete your Profile from active systems and retain only the limited records needed to evidence past consents, completed placements, invoicing and legal compliance.
13.Security safeguards
We implement appropriate, generally accepted technical and organisational safeguards, including encryption in transit and at rest, access controls limiting Candidate data to those who need it, consent and disclosure logging, and Operator due diligence. In the event of a data breach likely to compromise Personal Information, we will notify the Information Regulator and affected Data Subjects as required by section 22 of POPIA.
14.Your rights
Under POPIA you may: request confirmation of whether we hold your Personal Information and access to it; request correction or deletion; object to Processing, including for direct marketing; withdraw consent at any time; and lodge a complaint with the Information Regulator of South Africa (inforegulator.org.za). Requests should be sent to our Information Officer (section 20). We respond within a reasonable time and in accordance with POPIA and, where applicable, the Promotion of Access to Information Act, 2000.
15.Direct marketing
We send From the Vault and other marketing only to subscribers who have opted in, or to existing clients in respect of similar services as permitted by POPIA and the Consumer Protection Act. Every marketing email contains an unsubscribe link, and opt-outs are honoured promptly.
16.Cookies
The Site uses cookies and similar technologies for essential functionality and privacy-respecting analytics. You can manage cookies through your browser settings; disabling non-essential cookies does not affect your ability to use the Site.
17.Minors
The Services are directed at experienced professionals and are not intended for persons under 18. We do not knowingly process the Personal Information of minors.
18.Third-party links
The Site may link to third-party websites, including elite-cv.com and social platforms. We are not responsible for the privacy practices of third parties, and their own notices apply.
19.Changes to this Notice
We may update this Notice from time to time. The "Last updated" date will be revised, and material changes affecting Elite Talent members or active subscribers will be notified by email. This version supersedes all previous privacy policies published on the Site, including those relating to the former marketplace platform.
20.Information Officer and contact
Elite Talent (Pty) Ltd
Information Officer: [name to be inserted upon registration with the Information Regulator]
Email: [email protected]
Website: www.elitetalent.africa