Privacy Policy – Employer Branding and Recruitment
Cosmopolitan Projects and Central Developments Property Group
Date of publication: 07 June 2024
Cosmopolitan Projects and Central Developments Property Group (“the Group”, “we”, “our”, or “us”) manages its employer branding and recruitment processes through our career site (“Career Site”) and related applicant tracking systems.
This Privacy Policy explains how we collect, use, store and protect your personal information when you interact with our recruitment platforms.
This policy applies if:
• You visit our Career Site (“Visitor”)
• You create a profile with us to receive updates about current or future vacancies (“Connecting Candidate”)
• You apply for a position via our Career Site or a third-party platform (“Applying Candidate”)
• We identify your profile from public platforms such as LinkedIn (“Sourced Candidate”)
• You are referred to us by an employee or partner (“Referred Candidate”)
• You are listed as a reference by a candidate (“Reference”)
In this policy, the term “Candidate” refers collectively to Connecting Candidates, Applying Candidates, Sourced Candidates and Referred Candidates unless stated otherwise.
Cosmopolitan Projects and Central Developments Property Group processes personal information in accordance with the Protection of Personal Information Act, 2013 (“POPIA”).
1. Processing of Personal Information
Personal information refers to any information that can identify a living individual, either directly or indirectly.
Examples include:
• Name and surname
• Email address
• Telephone number
• Identity number
• Employment history
• Education details
• Online identifiers such as IP addresses
Processing of personal information includes collecting, storing, organising, analysing, sharing and deleting such information.
Cosmopolitan Projects and Central Developments Property Group acts as the responsible party and determines how and why personal information is processed.
2. Personal Information We Collect
Information from all individuals
When you interact with our Career Site we may collect:
Device information
• IP address
• Browser type and version
• Operating system
• Screen resolution
• Language settings
• Geographic location
Technical and usage information
• Pages visited on the Career Site
• Interaction with content
• Traffic sources and user behaviour
Communication information
• Emails and messages sent to us
• Interview recordings where consent is provided
• Survey responses
Contact information
• Name
• Email address
• Telephone number
• Physical location
Candidate information
During the recruitment process we may collect:
Application information
• Curriculum vitae (CV)
• Cover letters
• Education and qualifications
• Work history
• Work samples
• Professional references
Recruitment process information
• Interview notes
• Assessment results
• Salary expectations
• Evaluation feedback
Public professional information
• Information available on public platforms such as LinkedIn
• Professional websites or employer websites
Reference information
• Information provided by referees listed by the candidate
• Information received from employees or recruitment partners
3. Sources of Personal Information
We may collect personal information from:
Directly from you
• When you apply for a role
• When you create a candidate profile
• When you communicate with us
• During interviews or assessments
Publicly available sources
• Professional networking platforms
• Public professional profiles
Referrals
• Employees
• Recruitment agencies
• Professional partners
References
• Individuals listed as references by candidates
4. Purpose of Processing Personal Information
We process personal information for the following purposes:
Recruitment and selection
• Reviewing applications
• Assessing candidate suitability
• Communicating with candidates
• Managing recruitment processes
Talent sourcing and future opportunities
• Identifying potential candidates
• Contacting individuals about future vacancies
Employer branding and communication
• Informing candidates about job opportunities
• Managing talent pools
System administration and security
• Maintaining the Career Site
• Ensuring platform security
• Monitoring site performance
Legal compliance
• Complying with legal obligations
• Protecting our rights and interests
• Handling potential legal claims
5. Sharing of Personal Information
Your personal information may be shared with:
Service providers
Third-party providers who assist with recruitment services, technology platforms, and system support.
Group companies
Companies within Cosmopolitan Projects and Central Developments Property Group that support recruitment or HR processes.
Authorities
Government authorities or regulators where disclosure is legally required.
Legal advisors
Where necessary to protect the legal rights of the Group.
Business transactions
In the event of a merger, acquisition or sale of business assets.
All third parties are required to process personal information in accordance with applicable data protection laws.
6. Legal Basis for Processing
Personal information is processed based on one or more of the following lawful grounds under POPIA:
• Your consent
• The legitimate interests of Cosmopolitan Projects and Central Developments Property Group in recruiting suitable candidates
• Compliance with legal obligations
• Protection of legitimate business interests
Certain activities, such as recording interviews, will only occur with your explicit consent.
7. International Data Transfers
Some of our technology service providers may process or store data outside South Africa.
Where this occurs, we ensure that appropriate safeguards are in place to protect personal information in accordance with applicable data protection laws.
8. Retention of Personal Information
Personal information will only be retained for as long as necessary to fulfil recruitment and legal purposes.
Visitors
Information relating to Career Site usage may be retained for up to 12 months for security and analytics purposes.
Candidates
If your application is unsuccessful, we may retain your information for up to 12 months to consider you for future opportunities unless you request deletion earlier.
Employees
If you are appointed, your personal information will become part of your employee record and will be retained in accordance with employment and legal requirements.
References
Reference information may be retained for as long as the related candidate information is retained.
9. Your Rights
Under the Protection of Personal Information Act, you have the right to:
Access your personal information
Request confirmation of whether we hold personal information about you.
Correct your information
Request correction of inaccurate or incomplete information.
Request deletion
Request deletion of personal information where it is no longer necessary.
Object to processing
Object to the processing of your personal information under certain circumstances.
Withdraw consent
Withdraw consent where processing is based on consent.
Lodge a complaint
You may lodge a complaint with the Information Regulator of South Africa if you believe your personal information has been processed unlawfully.
10. Contact Details
If you have questions regarding this Privacy Policy or wish to exercise your rights, please contact:
Cosmopolitan Projects and Central Developments Property Group
Human Capital Department
Email: recruitment@centraldev.co.za
11. Updates to This Policy
This Privacy Policy may be updated from time to time to reflect changes in legislation, recruitment processes or operational practices.
The latest version will always be available on our Career Site.
