Nashua Job Applicant Privacy Notice

When you apply for a position at Nashua you share personal information with us. During the application process we also create personal information about you, such as interview notes or the results of job-related assessments. We have created this privacy notice to help you understand when we collect and use your personal information, and how we protect it.

If you have any questions, please contact Human Resources or send your questions to [email protected].

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    1. What this privacy notice is about

Who does this privacy notice apply to?

This notice affects every person who applies for a position at Nashua. This includes prospective employees, interns, learners and contractors. In terms of the Protection of Personal Information Act (‘POPIA’), you are the data subject.

Who are you sharing your information with?

You are sharing your information with Nashua (Pty) Ltd. (also referred to as ‘Nashua’).
Our registered address is:
Nashua Head Office,
Woodmead North Office Park
Maxwell Drive, Woodmead,
South Africa
In terms of POPIA, we are the responsible party.

What kind of information we collect and how we use it.

We collect personal information that helps us decide whether you are suitable for the position you applied for.
In most circumstances, the personal information we collect from you is mandatory. This means that we must collect it to comply with the law or because we need it to consider employing you.

When we collect personal information that is not mandatory, we always have a specific purpose for collecting that information.

Suppose you choose not to provide us with the personal information we need. In that case, it will limit our ability to complete the recruitment process and assess whether you are suitable for the position you applied for.

What personal information is.

Personal information is all information relating to a specific individual. This includes contact information, information relating to your race, gender, sex, pregnancy status, marital status, ethnic or national origin, sexual orientation, physical or mental health, disability, religion, belief, culture, language, education background, financial information, criminal behaviour, employment history, personal opinions, views or preferences, and private or confidential correspondence.

It does not matter whether the information is held on paper or in an electronic or other format – it is still personal information and must be protected.

From time to time, we will change how we work with personal information, and we will use this notice to tell you about it.

From time to time, we may have to change this privacy notice to accommodate changes in our business or changes to the law.

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    2. What Information We Collect

The position that you apply for will determine the type of information we collect about you.

The type of human resources data we collect and share depends on the nature of the position you apply for, the role this position fulfils at Nashua and any legal requirements.

We will collect information directly from you, or from third parties, such as your previous employer, or by doing background checks.

Most of the time we will collect your personal information directly from you (e.g., from your CV, the interview process, psychometric tests).

However, sometimes we will also collect information from other sources, such as recruiters, agencies, executive market mapping, previous employer(s) or by running background checks on you (e.g., your credit, academic qualifications and criminal history).

Here is a list of the personal information that we collect about you.

We collect, use and retain a lot of your personal information during the application process. This includes the information that we collect when:

• you complete the application and submit your CV, or when a recruiter or agency sends us your information;
• we do background checks and verify your criminal, credit, education and employment history;
• you are interviewed; and
• we conduct psychometric testing.

We also generate information about you in the form of records.

We generate records of:
• interview notes
• results of job-related assessments
• your CV in our format
• a shortlisting summary

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    3. Why We Collect and Process Your Personal Information

3.1 We process your personal information to conclude a contract with you and to meet our contractual obligations.

We need your personal information to manage the recruitment process and to run our business.

Personal information is essential when we recruit, hire and promote employees. Your personal information is used:
• during the recruitment and hiring process, such as when we assess whether you are suitable for the position that you applied for during the recruitment process;
• when we communicate with you to process your application; and
• to keep a database of contact details in case another position becomes available.

3.2 We process your personal information because it is in your or our legitimate interest to do so, because we are legally required to do so, or because you have given us permission.

We process some personal information because it is in our legitimate interest to do so.

When we monitor our premises via CCTV and other access control mechanisms (e.g., a visitors’ sign in register), to ensure the safety of all our property, employees, suppliers and customers.

We are legally required to process some personal information.

We will collect, use and retain your personal information to ensure that we comply with labour and other legislation. We will use your personal information during the recruitment and selection process.
Here are some of the pieces of legislation which have an effect on why your personal information is collected, used and retained:
• Employment Equity Act 55 of 1998
• Labour Relations Act 66 of 1995
• Basic Conditions of Employment Act 75 of 1997 (including sectoral determinations)
• Broad-based Black Economic Empowerment Act 53 of 2003 and Codes
• Immigration Act 13 of 2002
• Income Tax Act 58 of 1962
• Unemployment Insurance Act 63 of 2001
• Occupational Health and Safety Act 85 of 1993
• National Qualifications Framework Act 67 of 2008
• Compensation for Occupational Injuries and Diseases Act 130 of 1993
• Skills Development Act 97 of 1998
• Skills Development Levies Act 9 of 1999
• Consolidated Directions on Occupational Health and Safety measures in certain workplaces. Direction issued in terms of Regulation 4(10) of the Regulations issued under the Disaster Management Act 57 of 2002: Measures to address, prevent and combat the spread of Covid-19 in certain workplaces in RSA

We process some personal information with your consent.

Please note that if you do not provide us with your consent in these scenarios, it may limit our ability to assess your suitability for the position you have applied for.

We may ask you to complete a medical questionnaire and undergo a medical examination before employing you. If you indicate that you are disabled, we may ask for a supporting medical certificate.

When we verify your credit history, education history, identity number, driver’s licence or criminal record, we use third-party service providers to verify your personal credentials.

When we want to employ you in a position of trust and honesty that requires you to handle cash or finances or to prevent or detect fraud, we may collect your consumer credit information.

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    4. how We Share Your Information

We may share your personal information internally or with service providers to manage our business relationship with you and run our business day-to-day.

Here are some of the instances when we are required to share your information:
• your information may in certain cases, be shared with other companies in the Reunert group for everyday business purposes;
• in some instances, during your employment, we collect information on behalf of other companies such as the pension fund, medical aid and insurers. We do not retain this information (except to make the necessary deductions from your salary);
• sometimes we are required by legislation to share information with the government or a court (e.g., the Department of Labour, SARS, the Labour Court, the JSE or the Services SETA);
• from time-to-time parts of the business may be sold which could include a transfer of your information;
• we might share your information with companies who provide services on our behalf and with our instructions (e.g., payroll, tax, auditors, IT, accountants, labour consultants and other professional consultants);
• we may have to share your information if a judgment is awarded against you for a garnishee order; and
• we may share information about you if you have given the third party consent to obtain information from us. An example is when we share information with a future employer if you have selected us as your reference.

We only share the minimum amount of your personal information.

We only share the minimum amount of personal information that the service provider requires.

We only share your personal information with service providers we trust.

We require that service providers agree to keep your personal information secure and confidential and only use it for the purposes for which we shared it with them.

Some of the service providers that we use may be in other countries.

When we share information with service providers in other countries that may not have the same levels of protection of personal information as South Africa, they must undertake to protect your personal information to the same level that we do.

We provide for appropriate safeguards before we share.

We have appropriate safeguards in place in contracts between our local and foreign service providers and us.

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    5. How We Store Your Information

We retain your personal information for as long as it is reasonably necessary.

We retain your personal information for as long as we have a legitimate reason to keep it. These periods vary depending on the type of personal information, the reason why we originally collected it and if there is a specific retention period required by law.

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    6. How We Keep Your Information Secure

We have reasonable security measures in place to protect your personal information and to minimise the impact of a breach.

We base our security measures on the sensitivity of the personal information that we hold. Our security measures are in place to protect your personal information from:
• loss
• misuse
• unauthorised access
• being altered
• being destroyed

We regularly monitor our systems for possible vulnerabilities and attacks.

No system is perfect, and we cannot guarantee that we will never experience a breach of any of our physical, technical, or managerial safeguards, but we regularly monitor our systems for vulnerabilities.

We will let you know of any breaches that may affect your personal information.

If something should happen, we have taken steps to minimise the threat to your privacy, and we will let you know if your personal information has been compromised.

We will also let you know how you can help minimise the impact of the breach.

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    7. Your Personal Information Rights

You may ask us about your personal information.

You have the right to know when we collect and use your personal information, and to ask us what we know about you and what we do with that information.

You may access your personal information.

You may ask to access your own personal information by contacting [email protected]

We may take up to one month to respond to your request and may charge a fee in some circumstances. We will let you know if this is the case.

You have control over your personal information.

You may:
• ask that we update incorrect personal information, or complete personal information that may be incomplete;
• ask that we delete your personal information;
• ask to receive your personal information in a structured, commonly used and machine-readable format;
• ask that we reuse your personal information for your own purposes across different services;
• object to the processing of your personal information under certain circumstances;
• object to automated decision-making and profiling;
• ask that a human review any automated decisions that we make about you, express your point of view about it, and obtain an explanation of the decision. You may challenge any automated decision made about you; and
• ask that we restrict our use of your personal information.

You have the right to unsubscribe.

You have the right to unsubscribe from any direct marketing we send you.

You have the right to lodge a complaint with the Information Regulator.

You can contact the Information Regulator at [email protected].

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