This notice is designed to provide you with information about the processing of your personal information by General Reinsurance Africa Limited and about your rights according to data protection law.
1 Responsible Party of the processing – Who are we?
General Reinsurance Africa Limited
(Reinsurer licensed to conduct composite insurance business)
2nd floor, South Wing, Granger Bay Court, Granger Bay, Victoria and Alfred Waterfront
Cape Town, 8001
Tel. +27 21 412 7700
You can contact our Information Officer at the above address.
2 What categories of data do we use and where do they come from?
The categories of personal information processed encompass all data that you provide to us in the course of the application process with your application documents (cover letter, curriculum vitae, references, letters of recommendation etc.), in questionnaires or discussions.
This includes, in particular, your data such as forename, surname, name affixes, citizenship, your contact details (private address, (mobile) phone number, e-mail address etc.), photo, your skills, qualifications and previous employment as well as salary expectations. In addition, special categories of Personal Information (such as degree of disability) may also be processed if you voluntarily provide these data to us in the application process.
Generally speaking, your Personal Information is collected directly from you in the context of the recruitment process. We may also have received data from third parties (such as a job placement service) to whom you provided your data for forwarding.
In addition, it may happen that we process Personal Information about you that we have permissibly obtained from publicly accessible sources (e.g. professional social networks).
3 For what purposes and on what legal basis do we process your personal information?
We process your Personal Information in compliance with the Protection of Personal Information Act 4 of 2013 (POPIA).
It is necessary to process your applicant data in order to be able to implement and complete the application process, to decide on the establishment of an employment relationship and for its preparation (e.g. drafting of the employment contract).
The primary legal basis here is s. 11(1)(b) POPIA. In addition, your separate consent pursuant to s.11(1)(a) POPIA may potentially be used as a basis for permission in data protection law (e.g. in order to obtain references from former employers or to keep your applicant data for future vacancies). Where necessary, we also process your data on the basis of s. 11(1)(f) POPIA in order to safeguard our legitimate interests or those of third parties (e.g. primary insurers, our parent companies in the EU and United States).
The processing of special categories of Personal Information (e.g. health data or race or ethnic origin) is based upon your consent pursuant to s. 27(1)(a) POPIA, unless circumstances exist in which permission is granted under relevant legislation (s. 27(1)(b), s. 29, s. 32 and s. 33 POPIA).
For some roles, the company is obliged to seek information about criminal convictions and offence and your credit history. Where the company seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment. We are also obliged to screen applicant data against various international sanctions lists (anti-terror lists) in order to prevent cash flows to persons named on these lists. The legal basis here is s. 33, s. 11(1)(c) and s. 11(1)(f) POPIA in conjunction with other relevant national laws.
4 Categories of recipients of Personal Information
4.1 Data processing and sharing within the Gen Re group of companies
Within our organisation your Personal Information are provided solely to those persons and offices who require them in order to implement the application process and take the recruitment decision as well as to fulfil our (pre-)contractual and statutory duties. This group of recipients includes, for example, human resources management and the employees in the human resources department responsible for recruitment, the managers and employees of the specialist unit participating in the recruitment decision. Insofar as we have received and process Personal Information from you (which may include special categories of data, e.g. health information) for the aforementioned purposes, these will in some cases also be processed by associated companies of General Reinsurance Africa outside South Africa, e.g. the EU, U.S. and AsiaPac. This happens as part of:
- Group-wide job and applicant management;
- general IT services provided by General Reinsurance Corporation and General Reinsurance AG for its subsidiary General Reinsurance Africa;
- internal auditing.
4.2 External service providers
We use the following categories of external service providers in order to meet some of our contractual and statutory obligations:
- personnel service providers (temporary employment agencies and recruitment agencies);
- translators for the translation of application documents;
- IT service providers for the maintenance, operation and backup of systems and applications; data recovery and data media destruction;
- data management service providers for the storage and destruction of files;
- audit service providers for conducting internal audits and IT security audits.
- verification agencies for due diligence checks
4.3 Additional recipients
Furthermore, it might be necessary to share your data with public authorities in order to fulfil statutory reporting obligations.
5 What rights do you have in respect of your Personal Information?
5.1 We must notify you
- when any of your Personal Information is being processed by us, or a third party, unless we are exempted from giving notification.
- when your Personal Information has been accessed or taken by an unauthorised person.
5.2 Right to access, rectification and erasure
You can submit an access request to the above-mentioned address to obtain information about the data that we store on your person and the identity of all third parties, or categories of third parties, who have, or have had access to your personal information. You may also have a right to receive the Personal Information that you have provided to us in an understandable, structured and commonly used format. Furthermore, in certain circumstances you have the right to have your Personal Information rectified or erased.
5.3 Right to object to processing
If we process your data in order to safeguard legitimate interests you have the right to object to such processing if your particular situation gives rise to reasons that oppose the processing of your Personal Information.
5.4 Right to lodge a complaint
You have the option to lodge a complaint with the aforementioned Information Officer or the Information Regulator.
Details of the Information Regulator
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
P.O Box 31533, Braamfontein, Johannesburg, 2017
Complaints email: complaints.IR@justice.gov.za
General enquiries email: email@example.com
5.5 Right to withdraw your consent
If we process your Personal Information on the basis of your consent, you have the right to withdraw this consent at any time. The withdrawal of your consent might impact the further processing of your Personal Information with regards to the purpose. More details on the consequences of a consent withdrawal are included in the information provided to you with the consent form.
6 Transfer of your Personal Information to a third country
Should we transfer Personal Information to recipients outside of the Republic of South Africa this transfer only occurs if the recipient is subject to a law, binding corporate rules or binding company agreement which provide an adequate level of data protection. Detailed information on this and on the data protection level of recipients in third countries can be requested through the above-mentioned contact details.
7 Retention and erasure of your Personal Information
We retain your Personal Information for as long as is necessary for the purpose(s) set out above, or for as long as is required by law. We erase your Personal Information as soon as they are no longer required for the aforementioned purpose(s). It may be the case that Personal Information is stored until no further claims may be asserted against our company.
In general, if your application for employment is unsuccessful, the company will hold your applicant data on file for six months after the end of the relevant recruitment process. If your application for employment is successful, Personal Information gathered during the recruitment process will be transferred to your personnel file and retained during your employment.
If you have any questions about our processing of your personal information in terms of this Notice, please email us at InformationOfficer_SA@genre.com
Last updated 4 August 2021