Privacy Policy

1. Who We Are (Responsible Party)

SkillsPassport SA ("we", "us", or "our") is the Responsible Party as defined in POPIA. We determine the purpose and means of processing your personal information.

• Trading name: SkillsPassport SA
• Website: https://skillspassportsa.co.za
• Assessment portal: https://careers.skillspassportsa.co.za
• Information Officer: Dr. Lanette Hattingh
• Email: info@skillspassportsa.co.za
• Phone: +27 83 602 5227

2. Information We Collect

We collect personal information that you voluntarily provide and information generated through use of our services:

2.1 Registration and Assessment Data

• Full name, email address, and phone number
• Grade, school name, and province
• Date of birth (to verify eligibility and apply minor-protective provisions)
• Psychometric assessment responses and results (special category data — see section 4)
• Payment information processed securely via our payment gateway (we do not store card details)

2.2 Website Usage Data

• IP address, browser type, and device information
• Pages visited, time on site, and referral source (collected via cookies and analytics tools)
• Geographic region (province/country level only)

2.3 Communications

• Messages sent via contact forms or email
• School partnership enquiry details
• Newsletter subscription preference

3. Lawful Basis and Purpose of Processing

We only process personal information where we have a lawful basis under POPIA. The applicable bases and purposes are:

4. Special Categories of Personal Information (Minors and Psychometric Data)

Our services are primarily used by learners between the ages of 14 and 18. We treat the following categories with heightened protection:

• Children's personal information (section 35 of POPIA): Where a learner is under 18, we require consent from a parent or legal guardian before processing their personal information. Schools purchasing assessments on behalf of learners confirm they hold the necessary consents.
• Psychometric assessment results: Assessment responses and career guidance reports are treated as confidential. They are shared only with the registered account holder (learner or parent) and, where purchased through a school program, with the authorized educator.
• Health and wellbeing data: We do not collect medical or clinical health information. Our assessments measure cognitive aptitude only and are not diagnostic psychological tests.

5. Third-Party Processors

We share personal information with the following categories of third-party processors, who are contractually required to handle data in accordance with POPIA:

• Assessment platform (careers.skillspassportsa.co.za): Hosts and processes assessment data on our behalf.
• Payment gateway: Processes card transactions; we do not receive or store full payment card details.
• Email service provider: Used to deliver transactional emails (assessment results, receipts) and newsletters.
• Website analytics (Google Analytics): Collects anonymized usage data. IP addresses are anonymized. You may opt out via your browser's cookie settings.
• Hosting infrastructure: Our website is served via a South Africa-region server. We do not transfer personal data outside South Africa to countries that do not provide adequate protection unless appropriate safeguards are in place.

6. Data Retention

We retain personal information only for as long as necessary for the purposes described in this policy:

• Assessment data and results: Retained for 3 years from the date of assessment, then anonymized or securely deleted.
• Account information: Retained while your account is active and for 1 year after account closure.
• Payment records: Retained for 5 years to comply with financial record-keeping obligations under the Companies Act.
• Newsletter subscriptions: Retained until you unsubscribe.
• Contact form enquiries: Retained for 2 years from the date of the last communication.

7. Cookies

Our website uses the following types of cookies:

• Strictly necessary cookies: Required for the website to function (session management, security). Cannot be disabled.
• Analytics cookies (Google Analytics): Help us understand how visitors use the site. These cookies collect anonymized data and do not identify you personally. You may opt out by installing the Google Analytics opt-out browser add-on.
• Preference cookies: Remember your display settings (e.g., dark/light mode).

You can control cookies through your browser settings. Note that disabling certain cookies may affect website functionality.

8. Data Security

We implement appropriate technical and organisational measures to protect your personal information, including:

• HTTPS encryption on all web pages and the assessment portal
• Access controls limiting staff access to personal data on a need-to-know basis
• Secure password hashing (assessment portal accounts)
• Regular security assessments of our infrastructure

In the event of a data breach that is likely to harm you, we will notify the Information Regulator and affected individuals within 72 hours of becoming aware of the breach, as required by POPIA.

9. Your Rights Under POPIA

As a data subject, you have the following rights:

• Right of access: Request a copy of the personal information we hold about you (PAIA Form C).
• Right to correction: Request correction of inaccurate or incomplete personal information.
• Right to deletion: Request deletion of your personal information, subject to our legal retention obligations.
• Right to object: Object to the processing of your personal information where processing is based on legitimate interest.
• Right to withdraw consent: Where processing is based on consent (e.g., newsletters), you may withdraw consent at any time without affecting the lawfulness of prior processing.
• Right not to be subject to automated decisions: Our career guidance reports are generated algorithmically but reviewed within Dr. Hattingh's clinical framework — they do not constitute solely automated decisions that produce legal effects.

To exercise any of these rights, contact our Information Officer at info@skillspassportsa.co.za. We will respond within 30 days.

10. Complaints — Information Regulator

If you believe we have not complied with POPIA, you have the right to lodge a complaint with the Information Regulator of South Africa:

• Website: www.justice.gov.za/inforeg/
• Email: inforeg@justice.gov.za
• Physical address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001

We encourage you to contact us first so we can attempt to resolve your concern directly.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via a notice on our website or by email to registered users. Continued use of our services after the effective date constitutes acceptance of the updated policy.

12. Contact the Information Officer

For any privacy-related enquiry, access request, or complaint, contact our designated Information Officer: