Information Officer Van Den

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PROTECTION OF PERSONAL INFORMATION

POLICY MANUAL

AND

COMPLIANCE FRAMEWORK

Company Details

ManpowerGroup South Africa (Pty) Ltd

We lead in the creation and delivery of innovative workforce solutions and services that enable our clients to win in Powering the Future of Work. Owner of Policy: Lyndy van den Barselaar – Managing Director Introduction

We are committed to compliance with The Protection of Personal Information

(POPI) Act which requires us to:

1. Sufficiently inform candidates/applicants/work-seekers (data subjects), hereafter referred to as candidates, the purpose for which we will process their personal information;

2. Protect our Information assets from threats, whether internal or external, deliberate or accidental, to ensure business continuation, minimise business damage and maximise business opportunities. This policy and compliance framework establishes measures and standards for the protection and lawful processing of personal information within our organisation and provides principles regarding the right of individuals to privacy and to reasonable safeguarding of their personal information.

The Information Officer, is responsible for:

• Conducting a preliminary assessment;

• The development, implementation and monitoring of this policy and compliance framework;

• Ensuring that this policy is supported by appropriate documentation;

• Ensuring that documentation is relevant and kept up to date;

• Ensuring this policy and subsequent updates are communicated to relevant managers, representatives, staff and associates, where applicable. Page 2

All employees, subsidiaries, business units, departments and individuals directly associated with us are responsible for adhering to this policy and for reporting any security breaches or incidents to the Information Officer. Any Service Provider that provides Information Technology services, including data storage facilities, to our organisation must adhere the requirements of the POPI Act to ensure

Adequate protection of personal information held by them on our behalf. Written confirmation to this effect must be obtained from relevant service providers. Policy Principles

Principle 1: Accountability

We must take reasonable steps to ensure that personal information obtained from candidates is stored safely and securely.

This includes CV’s, Resumes, References, Qualifications, Integrity Checks and any other personal information that may be obtained for the purpose of candidate representation.

Principle 2: Processing Limitation

We will collect personal information directly from candidates.

Once in our possession we will only process or release candidate information with their consent, except where we are required to do so by law. In the latter case we will always inform the candidate.

Principle 3: Specific Purpose

We collect personal information from candidates to enable us to represent them to our clients for the purpose of recruitment. Principle 4: Limitation on Further Processing

Personal information may not be processed further in a way that is incompatible with the purpose for which the information was collected initially. We collect personal information for recruitment and it will only be used for that purpose.

Principle 5: Information Quality

We are responsible for ensuring that candidate information is complete, up to date and accurate before we use it. This means that it may be necessary to Page 3

request candidates, from time to time, to update their information and confirm that it is still relevant. If we are unable to reach a candidate for this purpose their information will be deleted from our records. Principle 6: Transparency/Openness

Where personal information is collected from a source other than directly from a candidate (eg. Social media, portals) we are responsible for ensuring that the candidate is aware:

o That their information is being collected;

o Who is collecting their information by giving them our details; o Of the specific reason that you are collecting their information. Principle 7: Security Safeguards

We will ensure technical and organisational measures to secure the integrity of personal information, and guard against the risk of loss, damage or destruction thereof. Personal information must also be protected against any unauthorised or unlawful access or processing. We are committed to ensuring that information is only used for legitimate purposes with candidate consent and only by authorised employees of our agency.

Principle 8: Participation of Individuals

• Candidates are entitled to know particulars of their personal information held by us, as well as the identity of any authorised employees of our agency that had access thereto. They are also entitled to correct any information held by us.

Operational Considerations

Monitoring

Management and the Information Officer are responsible for administering and overseeing the implementation of this policy and, as applicable, supporting guidelines, standard operating procedures, notices, consents and appropriate related documents and processes. All employees, subsidiaries, business units, departments and individuals directly associated with us are to be trained, according to their functions, in the regulatory requirements, policies and guidelines that govern the protection of personal information. We will conduct periodic reviews and audits, where appropriate, to ensure compliance with this policy and guidelines. Operating controls

We shall establish appropriate standard operating procedures that are consistent with this policy and regulatory requirements. This will include:

• Allocation of information security responsibilities. Page 4

• Incident reporting and management.

• User ID addition or removal.

• Information security training and education.

• Data backup.

Policy Compliance

Any breach/es of this policy may result in disciplinary action and possible termination of employment.

GDPR (EU General Data Protection Regulation)

GDPR and POPI (Protection of Private Information Act) are very similar in that they set out to protect personal information/data. The main difference is the mismatch of the dates when they become effective. GDPR was in May 2018. POPI could be end- 2019.

As far as GDPR is concerned, South African businesses will have to comply with these new EU data regulations when processing the data of EU subjects i.e.by providing services to or doing business with an EU partner (including UK, despite Brexit) or by holding personal information of an EU subject (candidate). Having said that, ManpowerGroupSA has already implemented a POPI “habit”. Our compliance with POPI in respect of the processing and safe-keeping (protection) of personal information, is in line with the GDPR. Ends…//26 February 2018

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