Job Applicants’ Privacy Notice

We collect personal data from the following sources:

1. directly from you through your CV, application form, cover letter, interviews, or communications with our Human Resources team; and
2. from third parties including referees you have identified, previous employers, recruitment platforms or agencies, and publicly available sources such as LinkedIn.

We collect and process your personal data for the purposes below:

PURPOSE OF PROCESSING	EXAMPLES OF PERSONAL DATA PROCESSED	LEGAL BASIS
Assessing suitability for the position	Application form, CV, cover letter, qualifications, interview notes	Legitimate interest (to recruit qualified and suitable candidates)
Communicating with you	Email address, phone number	Legitimate interest (to facilitate communication about your application)
Verifying qualifications and background	References, employment history, transcripts, copy of Identity Document	Legitimate interest (to confirm accuracy of information provided)
Conducting background checks (where applicable)	Identification, criminal, or financial history (if relevant)	Consent (conducted only with your explicit written consent and where relevant to the role)
Internal recruitment record-keeping	All application-related data	Legitimate interest (for audit, compliance, and legal defence)

Where we rely on legitimate interests, we ensure that the processing is necessary, proportionate, and does not unfairly impact your rights. Where required, we will obtain your explicit consent for specific processing activities, such as criminal background checks.

Some personal data requested during the recruitment process is required to assess your application, verify your qualifications, and meet pre-contractual requirements. If you do not provide this information, we may be unable to process your application or offer you employment.

We may share your personal data with:

1. recruitment and assessment platform providers, to manage applications and facilitate assessments, in line with our legitimate interest in streamlining and standardising recruitment operations using secure third-party tools; and
2. referees or previous employers, to verify your employment history, qualifications, and suitability for the role, in line with our legitimate interest in making informed hiring decisions based on accurate and reliable information.

In some cases, your personal data may be transferred to countries outside Botswana as part of the recruitment process. Where this occurs, we rely on adequacy decisions (where the destination country’s laws are recognised as providing a level of protection equivalent to Botswana’s). If no adequacy decision applies, we will implement appropriate safeguards or rely on specific derogations permitted under the Data Protection Act.

Personal data of unsuccessful applicants will be retained for up to two (2) years after the conclusion of the recruitment process. This is to allow us to respond to any legal claims, maintain recruitment records for audit purposes, and if you have consented, consider you for future opportunities. We may retain it longer if required by law.

Personal data of successful applicants will form part of their employee file and be processed in line with the Employee Privacy Notice.

You have the following rights under the Data Protection Act:

1. Right of access – request confirmation and a copy of your personal data
2. Right to rectification – correct incomplete or inaccurate data
3. Right to erasure – request deletion of your data in certain cases
4. Right to restriction – limit how we process your data in defined circumstances
5. Right to data portability – receive and transfer your data in structured format
6. Right to object – you have the right to object to processing based on our legitimate interests
7. Right to withdraw consent – where processing is based on consent, you may withdraw it at any time without affecting prior lawful processing

These rights may be limited depending on the legal basis of processing, or the rights of others. Please contact us to exercise your rights. You also have the right to lodge a complaint with the Information and Data Protection Commission.

We do not use automated decision-making or profiling in our recruitment process.

We may update this Privacy Notice from time to time to reflect legal or operational changes. The latest version will be available through our website.