Effective date: 21 October 2026 | Responsible party: Think Career RPO (Pty) Ltd Registration number: 2023/660080/07
1. Identity, scope and accountability
Think Career™ RPO (Pty) Ltd is a specialist workforce acquisition platform within the Think Career™ Consulting Group ecosystem. The legal entity responsible for processing personal information through this website is Think Career RPO (Pty) Ltd registration number 2023/660080/07, at Blys Bridge Office Park, Centurion. “We” and “our” mean that responsible party.
This Notice applies to website visitors, applicants, registered candidates, Talent Network members, employer representatives, suppliers and business contacts. In some client engagements, roles as responsible party or operator may differ; those arrangements must be assessed and documented in the relevant agreements. Information Officer: CIO; privacy email: CIO@thinkcareer.co.za; telephone: 012 003 6663.
2. POPIA terminology and governing principles
“Personal information”, “data subject”, “responsible party”, “operator” and “processing” have the meanings assigned under the Protection of Personal Information Act 4 of 2013 (POPIA). We seek to process personal information lawfully and reasonably, for specific and explicitly defined purposes, with appropriate information quality, transparency, security and participation rights. This Notice does not replace any statutory right.
3. Whose information we process
Information may relate to prospective and current candidates, individuals referred by third parties, references, employer and supplier representatives, site visitors and account administrators. We do not intentionally design general recruitment registration for children; if an opportunity concerns a minor, additional legal requirements and appropriate authorisation must be assessed before processing.
4. Categories of information
We limit the collection of identity numbers, financial information, identification documents and other sensitive records to circumstances where such information is reasonably necessary for a specified, lawful purpose. Where additional information is required for verification, screening or employment-related processes, candidates will be informed of the purpose and any applicable authorisation requirements.
5. Sources and collection
We receive information directly through registrations, applications, uploads, enquiries and communications. We may also obtain relevant professional information from employer clients, referees, authorised sourcing activities, professional platforms, assessment providers or other lawful sources. When information is not collected directly, we will assess and fulfil applicable notification requirements and any exceptions under POPIA. Public availability does not by itself authorise unrestricted collection or reuse.
6. Purposes and lawful justification
We use information to register and authenticate accounts; operate Talent Profiles; administer applications; communicate about roles; identify, screen and present candidates for legitimate vacancies; deliver executive search, specialist recruitment, RPO, WaaS, talent pipeline and assessment services; administer employer relationships; prevent fraud; support security; comply with law; handle complaints and requests; and send optional communications where permitted. Processing may be justified by consent, contractual necessity, legal obligation, protection of a legitimate interest of the data subject, or legitimate interests pursued by the responsible party or recipient, as applicable under POPIA section 11. We assess the applicable ground for each purpose rather than relying on blanket consent.
7. Mandatory versus optional information
Required fields should be identified at collection, together with consequences of not providing them. Candidates may choose not to provide optional information, but an incomplete application may limit consideration where information is reasonably needed to assess the vacancy. Marketing participation must not be a condition of submitting a job application.
8. Specific applications and Talent Network
Applying for a specific vacancy is distinct from joining an ongoing Talent Network. We may process application data for the vacancy and necessary recruitment administration. Ongoing consideration for unrelated future opportunities must be supported by an appropriate lawful basis, clear notice and a documented retention approach. Where Talent Network participation is offered on a consent basis, it must be optional, granular, recorded and withdrawable. Withdrawal does not automatically erase records that must lawfully be retained.
9. Candidate profile visibility
Profile visibility depends on the live website configuration. Candidate profiles are private, not searchable by unauthorized persons/employers, visible only to administrators, and are subject to candidate approval. Before enabling employer searches, candidates must receive an accurate explanation of which fields are visible, to whom, for what purposes and what controls are available. Sensitive attachments and contact details should not be exposed beyond justified authorised access.
10. Recruitment decisions and candidate submissions
Candidate information may be shared with authorised employer decision-makers where appropriate for a recruitment opportunity, subject to lawful processing, confidentiality and relevant disclosures. Candidates should be informed where appropriate before their details are introduced to an employer, particularly where discretion is material. We do not guarantee interviews, offers or placement. Employer hiring decisions remain subject to applicable employment laws and contractual responsibilities.
11. Assessments, checks and sensitive information
Psychometric, technical, reference, qualification, professional-registration, employment and background checks may be used where appropriate and legally permitted. Candidates will receive relevant notices and any additional permissions or authorisations required. Special personal information and information concerning criminal behaviour require specific legal justification and safeguards; they are not automatically covered by general platform registration. Assessment reports should be restricted to authorised personnel, handled under provider conditions and retained only for justified periods. Automated decision-making, if introduced, requires a separate legal and operational assessment.
12. Employer clients and authorised recipients
We may disclose relevant information to employer clients, their authorised representatives, assessment and verification providers, hosting and communication operators, professional advisers and lawful authorities where necessary and permitted. Each disclosure must be limited to its legitimate purpose. Employer users may not scrape, sell, distribute or reuse candidate records for unrelated purposes. Contractual safeguards and role-based access should support these requirements. We do not sell or rent candidate personal information as a data product.
13. Operators and service providers
Operators acting on our instructions should be subject to appropriate written obligations covering confidentiality, security, incident reporting, subcontracting and return or deletion of information. Third-party providers acting as independent responsible parties may have their own notices; relevant arrangements must be disclosed accurately.
14. Cross-border transfers
Cross-Border Transfers of Personal Information
Where necessary for legitimate recruitment operations, Think Career™ RPO may transfer personal information to authorised service providers or recruiting organisations located outside South Africa. Such transfers will be undertaken in accordance with section 72 of the Protection of Personal Information Act, 2013 (POPIA), including the application of appropriate safeguards or another lawful basis for the transfer. We take reasonable steps to ensure that personal information transferred internationally receives appropriate protection.
15. Security safeguards
We are required to take appropriate, reasonable technical and organisational measures to protect information against loss, unauthorised access and unlawful processing. The measures implemented must be confirmed by technical review, including role permissions, secure authentication, updates, encryption where appropriate, backups, access logging, vendor oversight and incident response. We cannot guarantee absolute security, and this statement does not reduce statutory obligations.
16. Security incidents and notification
Where there are reasonable grounds to believe that personal information has been accessed or acquired by an unauthorised person, we will investigate, contain and assess the incident and notify the Information Regulator and affected data subjects as required by POPIA section 22, as soon as reasonably possible, subject to statutory qualifications. Users should report suspected account compromise to legal@thinkcareer.co.za. Internal escalation and evidence preservation procedures must be established.
17. Retention and disposal
Information is kept only as long as needed for lawful purposes, applicable agreements, legal duties or other permitted retention grounds. We will establish and document separate retention rules for unsuccessful applications, active Talent Profiles, withdrawn members, assessment records, employer accounts, communications, backups and legal records. On expiry, records should be securely deleted, destroyed or de-identified as appropriate. Account closure does not necessarily mean immediate deletion of every legally required record.
18. Information quality and updates
We take reasonably practicable steps to keep information accurate, complete and updated where needed for its purpose. Candidates should update their Talent Profiles and can request correction of inaccurate records. We may verify relevant professional information where justified.
19. Direct marketing and recruitment communications
Messages about a submitted application or requested recruitment service are distinct from promotional communications. Unsolicited electronic direct marketing is subject to POPIA section 69 and applicable guidance, including consent or the limited existing-customer exception where its conditions are satisfied. Marketing consent must be recorded separately where required, and each marketing message should provide an appropriate opt-out. Joining the Talent Network must not automatically enrol a candidate in unrelated commercial marketing.
20. Cookies and similar technologies
The website may use essential authentication and security cookies and, if configured, analytics, preference or advertising technologies. Our separate Cookie Policy will describe actual categories, purposes, providers and controls. Non-essential tracking and consent settings must be implemented in line with applicable requirements and the website’s true technical behaviour.
21. Rights of data subjects
Subject to legal conditions, individuals may seek confirmation of whether we hold their personal information, request access, ask for correction or deletion, object to certain processing, withdraw consent where relied upon and complain to the Information Regulator. We may need to verify identity and assess exemptions or competing legal duties before responding. Requests relating to personal information may be directed to our Information Officer at CIO@thinkcareer.co.za. We will provide guidance on the applicable request process and any statutory forms where relevant.
22. PAIA and access to records
Requests for records under the Promotion of Access to Information Act 2 of 2000 (PAIA) are handled through the applicable PAIA process. Our PAIA Manual, where required, is a separate document and should be accessible via PAIA MANUAL. Privacy requests and PAIA access requests may overlap but are not identical.
23. Information Regulator and complaints
Individuals are encouraged to contact our Information Officer first to resolve concerns. They may also contact the Information Regulator (South Africa) using the current contact and complaint channels published at https://inforegulator.org.za/. We will not represent internal complaint handling as a prerequisite that removes statutory rights.
24. Third-party sites and recruitment fraud
Our website may link to third-party services with their own privacy practices. We encourage users to verify genuine recruitment communications and never disclose passwords, banking PINs or one-time passwords. Candidates should report suspicious vacancies or impersonation through our official channels. We will not ask candidates to pay for an employment offer through our platform.
25. Changes and contact
We may revise this Notice as our services, technology or law change. The effective date and material changes will be communicated where appropriate. Responsible party: Think Career RPO (Pty) Ltd ; registration number: 2023/660080/07; Information Officer and Privacy Policy: CIO; address: Blys Bridge Office Park ; effective date: 21 October 2026.
