PRIVACY POLICY

1. Who We Are (The Responsible Party)

Custom Line Manufacturing (Pty) Ltd ("CLM", "we", "us") is a B2B commercial fit-out and manufacturing company based in Gauteng, South Africa. CLM is the Responsible Party for personal information collected through this pre-employment screening and skills assessment platform.

Registered address and contact details for privacy matters are listed in Section 10 below.

2. What Personal Information We Collect

During your application, we may collect the following categories of personal information:

• Identification: Full name, South African ID number
• Contact details: Phone number, email address, residential area, province
• Eligibility information: Citizenship status, work permit status, driver's licence type
• Employment background: Current employment status, salary expectation
• Health information: Any pre-existing medical conditions or physical limitations that may affect the role (disclosed voluntarily)
• Criminal history: Self-disclosed criminal record information
• Assessment responses: Your answers to all skills assessment and work-style questionnaire questions
• Technical data: Assessment start time, completion time, submission reference number

We do not collect biometric data, banking details, or sensitive personal information beyond what is listed above.

3. Purpose of Collection

We collect and process your personal information solely for the following purposes:

• Evaluating your suitability for employment at Custom Line Manufacturing
• Assessing your skills, experience, and trade proficiency for department placement
• Conducting background, reference, and criminal record verification checks if you are shortlisted
• Contacting you regarding your application status
• Maintaining records required by law or for legitimate business operations

We will not use your personal information for marketing, profiling, or any purpose unrelated to your recruitment application without your explicit separate consent.

4. Lawful Basis for Processing

Processing of your personal information is based on:

• Your consent — given when you submit your application and accept the declaration
• Pre-contractual necessity — to assess your application before potentially entering into an employment contract
• Legal obligation — compliance with South African labour law and related regulations
• Legitimate interest — ensuring the safety, integrity, and quality of our workforce

5. Special / Sensitive Information

Health information and criminal record information are considered sensitive under POPIA. This information is:

• Collected only where directly relevant to the nature of the work (manual labour, working at heights, power tool use)
• Processed with your explicit consent, given via the declaration checkbox in the application
• Accessible only to authorised CLM personnel involved in the recruitment process
• Never shared with third parties except where required by law or with your written consent

6. Who Has Access to Your Information

Your personal information and assessment results are accessible to:

• Authorised CLM management and HR personnel involved in recruitment decisions
• Background screening providers (only if you are shortlisted and only information necessary for the check)
• Professional advisors (lawyers, auditors) under confidentiality obligations
• Government or regulatory authorities where legally required

We do not sell, rent, or share your personal information with third parties for commercial purposes.

7. Data Retention

• Unsuccessful applicants: Records retained for a maximum of 12 months from submission date, after which they are securely deleted.
• Shortlisted candidates: Records retained for the duration of the recruitment process plus 12 months.
• Employed candidates: Information is transferred to your personnel file and governed by CLM's employee data retention policy.
• Records may be retained for longer if required by applicable law.

8. Security of Your Information

We take reasonable technical and organisational measures to protect your personal information against loss, unauthorised access, disclosure, or destruction. These include:

• Password-protected access to the recruitment management system
• HTTPS encryption for data in transit
• Server-side access controls limiting visibility to authorised personnel
• Results data not exposed publicly via any URL or interface

Despite these measures, no electronic transmission or storage system is 100% secure. You submit information at your own risk and we are not liable for any breach that is beyond our reasonable control.

9. Your Rights Under POPIA

As a data subject, you have the following rights:

• Right to access: Request confirmation of what personal information we hold about you
• Right to correction: Request correction of inaccurate or incomplete information
• Right to deletion: Request deletion of your personal information, subject to any legal retention obligations
• Right to object: Object to the processing of your personal information on legitimate grounds
• Right to withdraw consent: Withdraw your consent at any time (this will not affect processing that already occurred)
• Right to complain: Lodge a complaint with the Information Regulator of South Africa if you believe your rights have been violated

To exercise any of these rights, contact us using the details in Section 10.

10. Contact & Information Officer

For privacy-related queries, access requests, or complaints, contact our Information Officer:

11. Cookies and Local Storage

This assessment platform uses your browser's localStorage to auto-save your application progress during the session. This data:

• Is stored locally on your device only
• Is automatically deleted upon successful submission
• Is not transmitted to third parties
• Does not constitute a "cookie" for the purposes of POPIA or GDPR

12. Changes to This Policy

We may update this Privacy Policy from time to time. The effective date at the top of this page reflects the most recent update. Continued use of this platform after changes constitutes acceptance of the updated policy.

13. Governing Law

This Privacy Policy is governed by the laws of the Republic of South Africa, including POPIA (Act 4 of 2013). Any disputes will be resolved in South African courts.