top of page

June 2023 | Sticking to the rules.

Terms & Conditions.

What We Do

Apti (Pty) Ltd. offers the following services:

recruitment consultancy services, placing candidates for their SAICA training programme (“Recruitment Services”):

  • Assisting companies with their permanent recruitment and temporary recruitment through business process outsourcing services.

  • Providing consultancy and advisory services in various areas ("Consultancy Services").

  • Unless otherwise notified, Apti (Pty) Ltd. acts as a data controller when processing your personal data for our Recruitment Services and Consultancy Services. In the event that we share your personal data with our clients as part of our Recruitment Services or Consultancy Services, it is probable that our clients will process your personal data as data controllers. Please note that our clients may require additional personal data from you as part of their hiring processes.

If you are unsure about the entity acting as the data controller for your personal data, please contact us using the contact information provided in section 15 of this policy.

The purpose of this Privacy Policy ("policy") is to provide you with information on how we collect, use, and disclose your personal data. It is essential that you read this policy alongside any notices or statements concerning data, data protection, fair processing, and/or privacy that we may provide when collecting your personal data, where applicable in your jurisdiction. Please note that unless expressly stated otherwise by us in such policy, notice, or statement, they are not intended to supersede or override the provisions of this policy.

What information do we collect? 

Personal data refers to any information that relates to an identified or identifiable individual. We will only collect personal data in accordance with applicable laws and regulations. Provided below is a non-exhaustive list of the types of personal data we commonly collect.

Category of Data
Data Collected
Marketing data
Preferences in receiving marketing from our third parties and us, Communication preferences
Usage data
How you use and navigate around our websites, Browsing activities within our websites
Profile data
Usernames applicable to accessing our services, Interests applicable to the services we provide to you, Preferences and other insights gained from analysis and profiling
Technical data
Internet Protocol (IP) address, MAC address, Login data, Browser type and version, Time zone setting and location, Browser plug-in types and versions, Operating system and platform, Mobile phone location data, Other technology information from devices used to access our website and services
Diversity data
Racial or ethnic origin, Religious or similar beliefs, Physical or mental health information, including disability-related data
Verification data
Copy of driving license, passport, identity card, or other identification documents, referee details, matric certificate, university transcript and CV
Employment-related data
Current remuneration, pension and benefits, Desired role, Areas of work-related interest, Third-party references (if applicable), Interview and assessment feedback generated by us or our clients
Historical data
Educational history and credentials, Employment history, Criminal background history, Social media information, Skills and qualifications, Results from background checks
Contact data
Email address, Telephone numbers, Emergency contact details, Contact details history
Identity data
Title, First name, Last name, Date of birth, Gender, Photograph, National identification number, Nationality, Residency and citizenship information required to establish the right to work in a specific country

Sensitive or special category personal data

Throughout the recruitment process or in the provision of our services, it is possible that we may collect personal data that is considered sensitive or falls under special categories as defined by certain countries. In accordance with local privacy laws, explicit consent may be required for us to handle this type of personal data. If your express consent is necessary, you will be provided with a consent form. If you have not received a consent form but believe that we possess your sensitive or special category personal data, please contact us for further assistance.


Regarding candidates and users of the Apti website, we also handle the following types of data:

  • Aggregated Data: This includes statistical or demographic data that is used for various purposes. Aggregated Data may be derived from your personal data but does not reveal your identity directly or indirectly, making it not considered personal data under the law. For instance, we may use your usage data to calculate the percentage of users accessing a specific feature on our website. However, if we combine or link Aggregated Data with your personal data in a way that it can directly or indirectly identify you, we treat the combined data as personal data and handle it in accordance with this privacy policy.

  • Anonymised Data: This refers to data that has been created from your personal data after removing any identifiers, making it impossible to trace it back to you.

*Please note that we typically do not collect personal data relating to individuals under the age of 18.

How we collect personal data

At Apti, we primarily collect your personal data directly from you.

The following are examples of situations in which we collect your personal data:

  • When you engage with us in person, over the phone, via email, or through our websites.

  • When you register with us, such as at career fairs or recruitment events.

  • When you submit information to us, such as your CV or other relevant documents.

  • When you participate in psychometric assessments or other assessments as part of our evaluation process.

  • When you subscribe to receive emails from us.

  • When you subscribe to our publications.

  • When you attend an event organised by us.

  • When you participate in a competition, promotion, or survey conducted by us.

  • When you provide us with feedback.

In addition to collecting personal data directly from you, we may also collect your personal data through the following third-party channels:

  • Our clients and their third-party suppliers: In certain cases, our clients or their affiliated suppliers may provide us with personal data relevant to the recruitment or employment process.

  • Governmental and regulatory bodies: We may receive personal data from governmental and regulatory bodies, such as tax and social security authorities, as required by applicable laws and regulations.

  • Third-party suppliers: We may collaborate with other recruitment and employment agencies, job board providers, job aggregators, and managed service providers as part of our supply chain, who may share personal data with us.

  • Other recruitment agencies: We may receive personal data from other recruitment agencies with whom we collaborate or engage in partnerships.

  • Analytics providers: We utilize analytics providers, such as Google Analytics and various job boards, to gather statistical information and insights, which may include personal data.

  • Communication platforms: We may use communication platforms such as Adobe Marketo, Cision, and PR to manage our marketing and communication activities, which may involve the collection of personal data.


We ensure that any personal data collected through these third-party channels is done so in compliance with applicable data protection laws. By providing us with information, you consent to us using that to provide our Services


Furthermore, where permitted by applicable laws, we may collect your personal data from publicly available sources. This may include:

  • Your identity and historical data from social media platforms, such as LinkedIn, Twitter, and Facebook, to the extent allowed by the platform's terms and applicable privacy settings.

  • Your identity and contact data from company and commercial registers , as allowed by law and relevant regulations.

  • Your identity from qualification and membership lists of professional bodies, subject to the provisions and permissions of the respective professional organisations.

We offer the option for you to sign up or log in to an Apti account using your LinkedIn, Facebook, or Google account ("Social Media Account"). If you choose to utilise this feature, we will process your name and primary email address associated with your Social Media Account in accordance with this privacy policy.

Cookies are small text files stored on your computer or mobile device, created by the servers of the website you visit.


When you access the Apti website, we automatically collect your personal data through cookies, based on your browser's cookie settings. You can also visit to learn more about cookies in general.

How we use personal data

We will only use your personal data in accordance with applicable laws and regulations. The following outlines the purposes for which we may use your personal data:

For Candidates:

  • Provide careers, recruitment, and related intermediary services to or for you.

  • Match your details against job vacancies that we consider suitable for you, assessing your suitability for those positions.

  • Enable you to submit your CV, apply for specific jobs, or subscribe to our job alerts to receive notifications about relevant job vacancies.

  • Apply for jobs on your behalf by sharing your personal data with clients.

  • Facilitate the recruitment process if a client wishes to progress your application.

  • Fulfill our contractual obligations to our clients.

  • Inform you about relevant industry developments, events, promotions, competitions, and other pertinent information.

  • Respond to your inquiries or questions.

  • Conduct statistical analysis.

  • Monitor diversity.

  • Comply with regulatory commitments.

  • Pursue or defend a legal claim.

  • Conduct pre-employment screening.

  • Prevent or detect crime, as required by law.

  • Provide you with additional information about the employment market and opportunities that may be of interest to you.


Please note that the usage of your personal data will be subject to legal requirements 

For Website Users:

  • Improve our customer service and enhance the functionality of our websites to better meet your needs.

  • Inform you about our recruitment services across all areas of our business.

  • Send you communications based on your preferences, where you have indicated your willingness to receive such information or have purchased products or services from us. These communications may include:

    • E-newsletters

    • Emails regarding our services and new product launches.

    • Reminders when your products or services are due for renewal.

    • Opportunities to participate in market research.


Depending on the contact preferences you have selected, we will communicate with you through various channels, including telephone, SMS, email, and other electronic means, such as social media and digital platforms. We may use your usage data to personalize and ensure the relevance of these messages to you.


We will use your personal data purely for the purpose of conducting a reference check on a candidate.

Who your personal data is shared with

In compliance with regulations and applicable laws, we may disclose your personal data to the following entities:

  • Prospective employers or engagers who may be interested in considering you for job opportunities.

  • Other recruitment companies or intermediaries involved in managing the supply of personnel.

  • Data processors of Apti who assist us in carrying out our services and processing personal data on our behalf.

  • Pre-employment screening and background checking organizations that help us verify the accuracy and suitability of the information provided.

  • Your referees, who you have listed as contacts for reference checks.

  • Your past employers and relevant educational institutions, to verify your employment history and educational qualifications.

  • Professional bodies to which you belong or are affiliated with, as required for certification or membership verification.

  • Government and regulatory bodies, such as tax and social security authorities, as mandated by applicable laws and regulations.

  • Third-party suppliers, including other recruitment and employment agencies, job board providers, job aggregators, and managed service providers within our supply chain, who assist us in delivering our services.

  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or assets. In such cases, your personal data may be transferred as part of the business transaction or integration. Any new owners will be required to handle your personal data in accordance with this privacy policy.


We do not permit our third-party service providers to use your personal data for their own purposes. They are authorised to process your personal data solely for specific purposes and in accordance with our instructions, which include compliance with this privacy policy.


Legal grounds

In certain countries, where we act as data controllers, we are required to establish legal grounds in accordance with applicable laws to process your personal data. Depending on our relationship with you, if necessary, we will rely on one or more of the following legal grounds:

  • Consent: We may process your personal data based on your consent for one or more specific purposes. Examples include when you create a website account with us, when explicit consent is required by law to process your personal data, or when you provide us with your consent voluntarily.

  • Legal or Regulatory Obligation: We may process your personal data to comply with a legal or regulatory obligation. For instance, this includes performing background checks as required by law, fulfilling tax and financial compliance obligations, cooperating with regulators and public authorities, and meeting other obligations under applicable rules and laws.

  • Contractual Necessity: We may process your personal data when it is necessary for the performance of a contract we have entered into or are about to enter into with you. This applies, for example, when employing or engaging you for a vacancy or when entering into an agreement as a supplier or external adviser.

  • Legitimate Interests: We may process your personal data when it is necessary for the pursuit of our legitimate business interests, provided that your interests and fundamental rights do not override those interests. Examples include offering and providing recruitment services, assessing your skills against our vacancies, providing marketing material to aid your job search, managing complaints and legal claims, conducting appropriate background checks, sharing personal data with our third-party service providers, and sharing personal data with potential employers and clients.


If you would like to know the specific legal grounds we rely upon to process your personal data, please contact us using the contact details provided in section 15 of this policy.



We will retain your personal data only for as long as necessary to fulfill the purposes for which we collected it, including meeting any legal, accounting, or reporting requirements. We consider our relationship with you as one that supports your career through various roles and assignments. Consequently, we may retain your data for a duration that extends beyond a single placement if we reasonably anticipate an ongoing relationship with you.

When your personal data is no longer needed, we will securely and appropriately dispose of it. In determining the appropriate retention period for personal data, we will take into account the following factors:

  • The quantity and nature of the personal data.

  • The sensitivity of the personal data.

  • The potential risks associated with unauthorized use or disclosure of the personal data.

  • The purposes for which we handle your personal data.

  • Whether we can achieve those purposes through alternative means.

  • Applicable legal requirements.


By considering these factors, we aim to ensure that we retain your personal data only for as long as necessary and appropriate for the intended purposes. If you have any questions about our data retention practices, please reach out to us using the contact details provided in section 15 of this policy.


Your rights 

Your rights regarding your personal data may vary depending on the country you are located in and the applicable privacy laws. These rights may include:

  • Right to be informed: You have the right to be informed about your personal data, including how it is handled and processed.

  • Right of access: You have the right to access your personal data and obtain information about how we handle and process it.

  • Right to rectification: If your personal data is inaccurate or incomplete, you have the right to have it corrected or completed.

  • Right to erasure: You have the right to request the erasure of your personal data, also known as the "right to be forgotten." However, please note that we do not delete personal data from our backup files created for disaster recovery purposes that are not easily accessible.

  • Right to restriction of processing: You have the right to request the restriction of handling and processing of your personal data, including asking us to suppress your personal data file.

  • Right to data portability: You have the right to request the movement, copying, or transfer of your personal data to another organisation, known as "data portability."

  • Right to object: You have the right to object to the handling and processing of your personal data for certain purposes, including direct marketing and personal data processed based on legitimate interests.

  • Right to withdraw consent: If you have provided consent for the handling and processing of your personal data, such as for electronic marketing purposes, you have the right to withdraw that consent.

  • Rights in relation to automated decision making: If automated decision making has a legal or significant effect on you, you have rights related to such decisions.

  • Right to lodge a complaint: You have the right to lodge a complaint with us regarding the handling of your personal data or with the relevant regulatory body responsible for data protection in your jurisdiction.


If you wish to exercise any of these rights, please contact us using the contact details provided in section 15 of this policy. We will respond to your requests in accordance with applicable laws and regulations.



We are committed to using your personal data in a fair and transparent manner. In some instances, we may utilize technological filters to streamline the processing of job applications and match candidates to specific job vacancies. If we extensively rely on technological tools in assessing your job application, we will inform you accordingly. We encourage you to inform us if there are any additional factors or considerations that you believe should be taken into account as part of your job application.

Data security

We prioritise the security of your personal data and maintain secure computer storage facilities for that purpose. We have implemented appropriate technical and organizational measures to ensure a level of security that aligns with the potential risks associated with unauthorized or unlawful processing, accidental or unlawful loss, destruction or alteration, unauthorized access or disclosure, or damage to your personal data. Such measures include firewalls, passwords, limited access, and other methods.

Access to your personal data is limited to employees, agents, contractors, and other third parties who have a legitimate business need to access it.

When sharing your personal data with third parties, we have established security-related measures to ensure that they handle your personal data in a manner consistent with our safeguards.

If you suspect any misuse, loss, or unauthorized access to your personal data, please contact us immediately using the contact details provided in section 15 of this policy. We take such incidents seriously and will address them promptly


What are your privacy rights


As a data subject, POPIA provides you with a number of rights in relation to how your personal information is used and processed. In terms of POPIA, you are entitled, in the prescribed manner and form, to:


  • Request a copy of the personal information that we hold about you (subject to and in accordance with the provisions of the Promotion of Access to Information Act);

  • Update the personal information you have given to us, in the event that the personal information is inaccurate or outdated;

  • Request the correction, destruction or deletion of personal information we hold about you (where legally permissible and subject to our right not to correct or delete the personal information record in certain circumstances);

  • Object to your personal information being processed by us (on reasonable and lawful grounds), in instances where you have a legitimate reason to believe that we are not processing your personal information in accordance with the provisions of POPIA; and to

  • Object to any processing of your personal information for the purpose of direct marketing by electronic communication, in the prescribed manner and form, or to unsubscribe from receiving any marketing or communication emails received from us 


We will make commercially reasonable efforts to provide you reasonable access to any of your personal or other account information that we process and/or retain. In certain circumstances, such as when we are required to retain or withhold the disclosure of certain personal information by law, we may not be able to provide you with access to all your personal information or we may not be able to change, rectify or delete your personal information at your request. In these circumstances, we will provide you with reasons as to why your request cannot be complied with.


If you have a complaint about how we are processing your personal information, or if you wish to object to us processing your personal information or request the correction, deletion or destruction of any of the personal information records we hold about you please contact our Information Officer at (Attention: Information Officer), in the first instance, so that we can resolve the complaint or attend to your request.


All requests need to be submitted on the prescribed forms, as set out in the POPIA Regulations.

In terms of POPIA, you are also entitled to direct a complaint to the Office of the Information Regulator, South Africa, if you feel that your complaint has not been adequately addressed directly with us. Complaints to be addressed to the Information Regulator must be completed in the prescribed manner and form (on prescribed Form 5 Part II, as set out in the POPIA Regulations).


The Office of the Information Regulator may be contacted at (general enquiries) or  (complaints). | Their website is:


Privacy policies of third parties

This policy outlines how Apti handles your personal data. However, we also recommend that you review the privacy policies of the social media platforms and third-party websites through which you access the Apti website. Prior to providing your personal data to these platforms or websites, we encourage you to read and understand their respective privacy policies. This will help you familiarise yourself with their practices and ensure that you are comfortable with how they handle your personal data.

Changes to this policy


We reserve the right to modify this policy periodically. Any changes will be communicated on our website seven days prior to their implementation. In emergency circumstances, such as when required to comply with legal or regulatory obligations, we may need to make immediate changes to this policy without prior notice.

It is recommended that you review this policy regularly to stay informed about how we handle your personal data. By continuing to use our services after any updates or modifications to this policy, you acknowledge and agree to the revised terms.


Laws applicable to these Terms and Conditions


This Privacy Notice is governed by the laws of the Republic of South Africa, and you hereby consent to the jurisdiction of the South African courts in respect of any dispute which may arise out of or in connection with the formation, interpretation, substance or application of this Privacy Notice.

How to contact us


If you have questions or comments about our privacy practices, or if you would like to submit a request exercising your privacy rights, please contact us.

Information Officer

Rorke Lilford

bottom of page