Joint Prosperity (JP) is a vibrant people and business consulting company established in 2000. We believe that the effective execution of strategy is leadership and people related. Holding this premise, we partner with leaders and organisations to help improve the effectiveness and execution of their strategy by unleashing the power of their businesses through their people.
The Protection of Personal Information Act 4 of 2013 (“PoPIA”) requires JP to inform their clients as to how their Personal Information is used, disclosed and destroyed. An individual’s privacy is of the greatest importance to JP and its business practices and JP is committed to the confidentiality and protection of all such Personal Information collected.
JP, therefore, guarantees its commitment to protecting its client’s privacy and ensuring their Personal Information is used appropriately, transparently, and securely and will only be processed if – given the purpose for which it is processed – it is adequate, relevant and not excessive
This Policy sets out for what purpose Personal Information is collected, handled, used, stored and ulti-mately disposed of.
This Policy applies to any individual whose Personal Information is submitted and processed via the Joint Prosperity websites.
2. PURPOSE OF COLLECTING PERSONAL INFORMATION FROM DATA SUBJECTS
Personal Information about data subjects which includes Clients, Candidates and other users of the JP website, will be collected in the execution of our service offering as stipulated in our agreements with our clients, to ensure we meet our legitimate interests, and comply with legal obligations.
This Personal Information will be used to provide the information, products and services agreed to in any contractual relationship with our clients. This will include client administration such as contractual management, invoicing, reports and services as well as technical support and administration of products, services and sites.
Candidates’ Personal Information when participating in assessments as requested by practitioners and/or clients, will be used to administer assessments and generate reports derived from the candidate’s responses which include, but are not limited to, the web-based delivery platform.
Data is collected from the completion of assessments and is used for research purposes. This may include gender, age, racial or ethnic orientation, cultural background, qualifications, work experience, and employment details. Statistical research is legally required and must be included in technical manuals of all registered assessments. Providing written consent for use of Personal Information is voluntary and the candidate may decline the use of their information in the online form. The candidate will not be prejudiced by not giving consent for research purposes nor will this choice influence the assessment results. It must be noted however that aggregated data of the assessment responses is used only for research and product development. Such data is aggregated and anonymised for this purpose. No Personal Information will or can be disclosed since no person is identifiable from such data.
3. HOW PERSONAL INFORMATION IS COLLECTED FROM DATA SUBJECTS
Information is provided by candidates, clients, suppliers and others. Personal information may be collected by the completion of forms on the website, by telephone conversations, email or otherwise, or through any online assessments by an invitation from JP or authorised by our client via our website or a website you may be directed to in order to complete assessments. Registering on our website, reporting a problem on the website or submitting an information request or any other communication may provide JP with the Personal Information.
4. WHAT PERSONAL INFORMATION IS COLLECTED FROM DATA SUBJECTS
Personal Information will be collected from clients, suppliers, candidates, employees or other business associates for specific purposes as outlined in this policy. This can include various and different forms of information depending on the relationship and JP will limit the use of this information to tasks related to that relationship.
Information collected when completing online assessments on our website or third-party websites will include various categories of data. This can include “identification data” which refers to names and contact details. “Assessment data” includes responses to specific assessments. Unlike identification data, assessment data will require responses to some (if not all) the questions during the assessment as not providing these might prevent further completion and the candidate might be unable to proceed and may therefore affect the results of the assessment.
Occasionally a “special category” of data is collected while completing questionnaires. Collection of such special category data is optional and is only provided by the data subject themselves. Special category data will only be used in aggregated and anonymised form for research and product development purposes.
Technical data and usage data is automatically collected through the use of our Website. This is collected via cookies which could include the following Personal Information where available: your operating system, browser type for system administration name, IP address, and browsing history and may be stored by us for use by third parties.
Simply visiting the JP website(s) does not require you to reveal Personal Information, although some cookies recording session data will be collected. However, if you ask us for information, register with us, sign up to attend any of our events, receive our marketing material, otherwise express an interest in our products or services, or report a problem, we collect any Personal Information you may submit to us.
5. ENSURING PERSONAL INFORMATION SECURITY AND PROTECTION
Where Personal Information, is collected and stored, JP actively ensures security measures and that these are maintained at the highest level, meeting all regulatory and legal requirements. The security and integrity of Personal Information is ensured through physical safeguards, technical and organisational measures, as well as administrative means. These measures are regularly reviewed and amended to prevent the loss, unauthorised access, disclosure, alteration, misuse or destruction of Personal Information in our custody.
In the event of a data breach, where such an incident might pose a risk to the individuals whose data is involved and may result in a risk to the rights and freedoms of individuals, the individual will be promptly informed. The legal authority will be informed of such a breach as is required by law and in accordance with any contractual terms.
Assessment Data Security: Data collected through online services is restricted to qualified users and requires an ID and password. Registration of JP Clients or their designated administrators is rigorous with defined qualification user levels.
All JP data (including administrator and test user information, test data, including responses to test items, and report text) are stored in an industry standard secure database.
6. DURATION OF RETENTION OF PERSONAL INFORMATION
To determine the appropriate retention periods for Personal Information, consideration is given to the amount, nature, and sensitivity of the data, the potential harm from unauthorised use or disclosure, and the purposes for which we process the Personal Information obtained.
Assessment related Personal Information is retained only to provide results for the Intervention contracted, purposes of processing and/or for a period of time that is required of us by applicable law. Specifically, the South African legislation (The Health Professions Act No. 56 of 1974) requires that the retention of psychological test data for five to seven years.
Thereafter it will be archived. The information can be anonymised at the request of the Client or the Candidate. In the event that a Candidate requests their data to be anonymised, the relevant requesting Client will be requested to confirm that they have concluded their use of the information for the purposes for which it was requested.
Clients’ Personal Information is retained for the duration of the relationship with Clients, and then for as long as is necessary in order to assist with any contractual obligations, queries, requests or complaints regarding the Assessments and/or the Services, to commence or defend legal claims, and to comply with our regulatory obligations (including record retention obligations).
7. TRANSFER AND SHARING OF PERSONAL INFORMATION
Where required sharing of Personal Information may be needed. Such instances include third parties, some of whom may be located outside South Africa, for processing purposes. Such processing functions are managed by national and international companies that comply to PoPIA (nationally) and GDPR legislation (internationally). JP shall ensure that such third parties provide sufficient guarantees in respect of the technical and organisational security measures. Reasonable steps will be taken to assess their compliance with those measures in order to ensure all Personal Information is adequately protected in accordance with applicable Data Protection Laws. JP remains vigilant that such compliance remains.
Personal Information of candidates will be shared with Client through reports, solely for the purposes for which the assessments were requested. Authorised parties covered in the business agreement may also need access to such Personal Information (e.g., 360-degree assessments).
Personal Information may also be passed to other assessment providers, suppliers and the suppliers of our assessment providers from time to time. Administrative, email, technological support, and other professional services may also require such Personal Information in order to support JP’s offerings and services. Any third parties with whom such Personal Information is shared are or will be contractually obligated to implement appropriate information and data protection and security measures to protect Personal Information and are not or will not be permitted to use Personal Information for any purpose other than the purpose for which they are provided with or given access to Personal Information.
Personal Information will only be shared with appropriately qualified practitioners who are trained to work with assessment data and who have made such a request. They are obliged to provide appropriate feedback on the assessment results as contracted with the client. Qualified practitioners are professional and legally bound to work with such information in a confidential, ethical, and legally compliant manner.
8. PERSONAL INFORMATION RIGHTS
Persons for whom the information has been gathered have the right to request to update, anonymise or correct your Personal Information. Local law dependent, you may also have the right to:
• object to the use of their Personal Information
• restrict the use of or delete their Personal Information
• request further information about the Personal Information collected, the purposes for which it has been collected and how it is protected;
• to verify information Personal Information;
• to anonymize their assessment data;
• to restrict the use of their Personal Information;
• to receive their Personal Information in a usable electronic format and transmit it to a third party (right to data portability),
Assessment Data may not be altered as this would undermine the accuracy and value of the Assessment reports.
An update of Personal Information may be needed from time to time. In the event that a candidate would like to have information updated, corrected, or deleted, a copy of the candidate’s Identity Document or similar identification will be required to confirm identity before changes to Personal Information will be made. To make requests to update, correct, or delete Personal Information, an email should be forwarded to firstname.lastname@example.org
If JP has not been compliant with the applicable privacy law in the collection and processing of Personal Information, a complaint can be lodged at the Information Regulator.
Amendments to This Policy
Amendments to this Policy will take place on an ad hoc basis or at least once a year. Clients are advised to check the JP website periodically to inform themselves of any changes. Where material changes take place, clients will be notified directly.
9. CONTACT INFORMATION
The details of Joint Prosperity’s Information Officer and Head Office are as follows:
Karen Rae Harmse
Telephone Number: +27 11 782 – 7007
Email Address: email@example.com
Head Office Details
Telephone Number: +27 11 782 – 7007
Physical Address: 67, 9th Street, Linden, Johannesburg
Email Address: firstname.lastname@example.org