Promotion of Access to Information Act

Trading name	Think Career™ RPO
Private body / registered entity	Think Career RPO (Pty) Ltd
Registration number	2023/660080/07
Website	https://thinkcareerrpo.com
Head / Information Officer	CIO
Approval	Managing Director

1. Acronyms and interpretation

PAIA	Promotion of Access to Information Act 2 of 2000
POPIA	Protection of Personal Information Act 4 of 2013
IO / DIO	Information Officer / Deputy Information Officer
Regulator	Information Regulator (South Africa)
Record	Recorded information held by or under the control of the private body, regardless of form

2. Purpose of this manual

This manual assists members of the public to identify records held by the private body, understand records available without a formal PAIA request, learn how to request access, and understand the personal information processing disclosures required under section 51 of PAIA. It does not guarantee access to every record: statutory grounds for refusal and third-party rights may apply.

3. Details of the private body and Information Officer

Legal name and registration	Think Career RPO (Pty) Ltd
Physical address	Blys Bridge Office Park, Centurion
Postal address	Blys Bridge Office Park, Centurion
Telephone	012 003 6663
General contact email	012 003 6663
PAIA requests email	legal@think-career.co.za
Information Officer	CIO
Deputy Information Officer (if applicable)	Managing Director

Requests should be sent to the verified PAIA contact above. The trading name is not necessarily the legal person responsible for records.

4. The Information Regulator’s guide on PAIA

The Information Regulator publishes a guide explaining how PAIA works, the rights of requesters and available remedies. The guide can be obtained from the Information Regulator’s official website and through its published contact channels. Official portal: https://eservices.inforegulator.org.za/paiamanuals/.

5. Records available without a formal PAIA request

Subject to availability and access controls, the following may be accessible directly from the website: published service descriptions, public vacancy advertisements, general website content, workforce insights, published policies, contact information and this PAIA Manual once approved. This does not mean candidate profiles, client agreements or internal records are publicly accessible.

6. Records available in terms of other legislation

The private body may hold records under legislation applicable to its actual operations, which may include the Companies Act 71 of 2008, Income Tax Act 58 of 1962, Tax Administration Act 28 of 2011, Basic Conditions of Employment Act 75 of 1997, Labour Relations Act 66 of 1995, Employment Equity Act 55 of 1998, Electronic Communications and Transactions Act 25 of 2002, POPIA and PAIA. This is an indicative list only; verify applicable legislation and recordkeeping duties before publication.

7. Subjects and categories of records held

Corporate and governance

Registration records, constitutional documents, governance resolutions, policies and compliance correspondence.

Financial and taxation

Invoices, quotations, accounting records, banking and tax-related records.

Clients and commercial services

Employer enquiries, proposals, signed service agreements, project documentation and client correspondence.

Recruitment and talent

Vacancy briefs, applications, CVs, Talent Profiles, recruitment correspondence, candidate evaluations and placement records.

Assessment and verification

Assessment administration, verification permissions, reports and results where lawfully held.

Human resources and suppliers

Personnel records, supplier contracts, service-provider correspondence and relevant compliance documents.

Technology and security

Platform account records, logs, technical documentation, access controls and incident records.

Marketing and intellectual property

Brand assets, publications, marketing materials, proprietary frameworks and commercial research.

The list describes possible record categories and must be reconciled against an actual records inventory. The existence of a category does not imply every listed record is currently held or automatically disclosable.

8. Processing of personal information under POPIA

8.1 Purposes of processing

Subject to verified practices, purposes may include candidate account administration, recruitment applications, employer services, candidate assessment and screening, Talent Network participation, client engagement, website security, statutory compliance and permitted communications.

8.2 Categories of data subjects and information

Candidates and Talent Network members	Identity/contact details, CVs, qualifications, work history, applications, preferences and assessment information where applicable.
Employer contacts	Names, business contact details, account credentials, vacancy briefs and correspondence.
Website visitors	Enquiries, device and usage data and cookie information where collected.
Employees, contractors and suppliers	Contact, contractual, payroll, payment and compliance records where applicable.

8.3 Recipients or categories of recipients

Depending on lawful purposes and verified data flows, recipients may include authorised employer clients, assessment and verification providers, IT and hosting operators, professional advisers, financial institutions and public authorities where lawfully required. Candidate information is not automatically open to all employers.

8.4 General description of information security measures

The private body should describe its actual technical and organisational safeguards, such as access management, confidentiality controls, secure storage, backups, supplier agreements, incident response and security testing.

9. How to request access to a record

A requester should complete the current prescribed PAIA request form for access to a record (Form 2 under the PAIA Regulations) and send it to the verified Information Officer contact. The requester should identify the record or category of records sufficiently, provide proof of identity or authority where required, specify the preferred form of access, and explain the right sought to be exercised or protected and why the record is required for that purpose, where required for a private-body request.

Requests on behalf of another person should include proof of authorisation. The Information Officer may request clarification or additional information as permitted by law. Applicable request and access fees, exemptions and procedural requirements are determined by current legislation and regulations, not by arbitrary website charges.

10. Decision-making, fees and remedies

The Information Officer will process requests within the time periods prescribed by PAIA, subject to any lawful extension and required third-party notification. Access may be granted in full, in part or refused on lawful grounds, including relevant privacy, confidentiality, commercial-information and safety protections. Requesters will be notified of the outcome and any applicable fees or remedies in the prescribed manner.

Where a requester is dissatisfied, the available complaint and court remedies depend on PAIA and the applicable procedures. Private bodies generally do not have the same internal appeal procedure as public bodies. The Information Regulator provides guidance and prescribed complaint forms.

11. Availability and updating of the manual

Once approved, this manual should be made available on the website and at the private body’s principal place of business, and through other channels required by applicable law. Language and accessibility requirements should be checked against current Information Regulator guidance. The manual must be updated when material particulars or processing activities change.

12. Related documents

Think Career™ RPO Privacy Policy & POPIA Notice (separate document).
Website & Platform Terms of Use (separate document).
Cookie Policy and candidate registration notices.
Internal records retention schedule, data-flow register and incident response procedure (not necessarily public).