Draft pending review by a South African attorney. Items marked [to be confirmed] still need information from 4Paths and must be completed before this page goes live.
1. Who we are
4Paths Recruitment (“we”, “us”) is a recruitment and placement business. We specialise in technology, finance, executive, creative and digital, and hospitality hiring. We are the “responsible party” for the personal information described in this policy.
- Registered name: [to be confirmed]
- Registration number: [to be confirmed]
- Physical address: [to be confirmed]
- Information Officer: [to be confirmed], registered with the Information Regulator
- Private employment agency registration number: [to be confirmed]
- Email: [email protected]
2. What this policy covers
This policy covers this website. Our client and candidate portal at portal.4pathsrecruitment.com is a separate system. It shows its own notice when you apply or sign in, and where it differs from this policy about portal data, the portal notice applies.
3. What we collect
When you send us the contact form we collect your name, company, email address and the role or hiring need you describe. You may also give your phone number, location, sector, preferred hiring route and a message. The required fields are marked on the form. We cannot reply without your name, email and a description of your need. Everything else is optional.
If you use the search bar on the home page, the role, location and department you choose are carried to the contact form to fill it in for you. Nothing is sent to us until you press “Send your brief”.
Automatically: this website does not use cookies, analytics or advertising trackers. Our hosting provider and the services in section 5 may record technical information such as your IP address, browser type and the pages requested, in ordinary server logs.
We do not knowingly collect information about children. Our services are for businesses and for adults looking for work.
Please do not put sensitive information, such as health, religion, race or criminal record, in the contact form. If we need that kind of information for a role, we will ask for it separately and explain why.
4. Why we use it, and our legal basis
We use your information for these purposes, on these grounds under the Protection of Personal Information Act (POPIA):
- Replying to your enquiry and agreeing how we can help: taking steps to enter into a contract with you, and our legitimate interest in running our business and answering business enquiries.
- Providing recruitment services you have asked for: performing a contract.
- Meeting our legal duties, such as the record keeping that employment services law requires: an obligation imposed by law.
- Sending you hiring news and insights by email: your consent, only if you tick the box on the form. You can withdraw it at any time.
- Keeping the website secure and working: our legitimate interests.
We do not sell your information. We do not use it to make decisions about you by automated means alone.
5. Who we share it with
We share personal information only with people who need it to help you, and under terms that require them to protect it:
- FormSubmit (formsubmit.co): receives what you type into the contact form and emails it to us. Its own terms and privacy policy apply while it handles the data.
- Google Fonts: loads our fonts, so Google receives your IP address and browser details when a page loads.
- Our hosting, domain and email providers (for example DigitalOcean, Cloudflare and Brevo) [to be confirmed] which apply to this website.
- Clients and candidates: if you become a client or candidate through the portal, information is shared as the portal notice explains.
- Authorities, where the law requires it.
6. Sending information outside South Africa
The services in section 5 may store or process information outside South Africa. Where that happens we rely on the recipient being bound by law, binding rules or an agreement that gives protection comparable to POPIA, or on your consent. The countries and safeguards are [to be confirmed].
7. How long we keep it
- Contact form enquiries: [to be confirmed] (proposed: 24 months after our last contact with you, then deleted).
- Clients and candidates: as the portal notice and our agreements say, and as the law requires.
- Your marketing opt-in: until you unsubscribe.
8. Keeping it safe
We use reasonable technical and organisational measures: encrypted connections (HTTPS), limited access, and private storage for documents. No system is perfectly secure. If personal information is compromised in a way that puts you at risk, we will tell the Information Regulator and you as soon as reasonably possible.
9. Marketing
We send marketing emails only if you tick the marketing box, or if you are an existing client who was given a chance to opt out when we collected your details. Every marketing email says who it is from and has an unsubscribe link. You can also unsubscribe by writing to [email protected].
10. Our recruitment practices
- We do not charge work seekers any fee for our employment services. [to be confirmed] against the Employment Services Act.
- We do not keep original identity documents or original qualification certificates of work seekers.
- We keep the registers that the Employment Services Act requires.
11. Your rights
You can ask us to:
- tell you whether we hold personal information about you and give you a copy;
- correct or delete it;
- stop using it, or object to how we use it;
- withdraw consent you gave us (this does not affect what we did before you withdrew).
Write to [email protected]. We may need to confirm who you are first. Our PAIA manual explains how to request records: [to be confirmed] (link to the PAIA manual).
12. Complaints
If you are unhappy with how we handled your information, please tell us first so we can put it right. You also have the right to complain to the Information Regulator (South Africa): JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001; [email protected]; www.inforegulator.org.za. [to be confirmed] (check these details on the Regulator’s website before publishing).
13. Changes to this policy
If we change how this website handles personal information, for example by adding analytics, we will update this page and its version date before the change starts.