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Legal

Privacy Policy

Last updated: [[PLACEHOLDER: publication date]]

Draft pending legal review. This policy describes how the ScoutX platform actually handles personal information today. It has not yet been reviewed by a South African attorney.

1. Who we are

ScoutX is operated by [[PLACEHOLDER: registered legal entity name]] (registration number [[PLACEHOLDER: company registration number]]), of [[PLACEHOLDER: registered physical address]] ("ScoutX", "we", "us").

Our Information Officer is [[PLACEHOLDER: Information Officer full name]], reachable at [[PLACEHOLDER: Information Officer email address]].

2. Two different roles

The Protection of Personal Information Act 4 of 2013 ("POPIA") distinguishes between a responsible party (who decides why and how personal information is processed) and an operator (who processes it on the responsible party's behalf).

  • Recruitment agencies that use ScoutX are the responsible party for the candidate, client and job information they load into the platform. ScoutX processes that information as their operator, only to provide the service and on their instructions.
  • ScoutX is the responsible party for information collected through this website (contact and demo requests), for the login accounts of agency staff, and for service-security and billing records.

If you are a candidate and want to see, correct or delete your information, the fastest route is the agency that holds your profile. You may also contact us (section 11) and we will pass your request to the right agency.

3. What we collect

WhoInformationSource
CandidatesName, email, phone, job title, location, industry, skills, years of experience, salary expectations, notice period, work authorisation, remote-work preference, document types and expiry dates, pipeline stage per job, screening-interview transcripts and assessments, and messages sent to you through the platform. Optionally, employment-equity details (race, gender, disability) that the candidate or agency chooses to record.The agency, or the candidate through the candidate portal
Agency staffName, work email, role, hashed password, and an audit trail of actions taken in the platform.The user, or their agency administrator
Website visitorsWhatever you type into the contact or demo form. These forms open your own email application with a pre-filled message; nothing is sent to our servers until you send that email.You
EveryoneTechnical data needed to run the service, such as IP address in server and security logs.Your browser

Special personal information. Employment-equity fields (race, gender, disability) are special personal information under POPIA. They are only recorded where the candidate or the agency provides them, and are used for the agency's employment-equity reporting rather than for matching or ranking candidates.

4. Why we use it

  • To run the recruitment platform: candidate records, job pipelines, matching, screening interviews, document-expiry reminders, campaigns and invoicing for the agency.
  • To keep accounts and data secure, including login, audit trails and abuse prevention.
  • To respond to enquiries and demo requests.
  • To meet legal obligations, including bookkeeping.

We do not sell personal information and we do not use candidate information for advertising.

5. Artificial intelligence

ScoutX uses AI models from Anthropic to help recruiters. Features include drafting job adverts, summarising and parsing CVs, suggesting screening questions, producing a structured assessment of a screening interview, and drafting outreach emails.

  • AI features are run by recruiters. A candidate does not talk to an AI system directly, and the AI does not make hiring decisions. Its output is a suggestion that a person reviews.
  • When an AI feature is used, the relevant text (for example a CV, a job description or an interview transcript) is sent to Anthropic's API for processing. Scanned PDF CVs are sent to Anthropic as documents so their text can be read.
  • Under Anthropic's commercial API terms, content sent through the API is not used to train its models. Those terms are set by Anthropic and may change.
  • We record who used an AI feature, when, and how many tokens it used, to enforce fair-use limits. We do not store a copy of the content in that usage log.

If you object to AI processing of your information, tell the agency that holds your profile, or contact us.

6. Who we share it with

We use a small number of service providers to operate ScoutX:

  • Railway: application hosting and the PostgreSQL database.
  • Anthropic: AI processing (section 5).
  • Resend: sending email on the agency's behalf (invitations, password resets, campaigns, reminders).
  • Google Fonts and cdnjs (Cloudflare): fonts and open-source libraries loaded by your browser, which means those providers see your IP address when a page loads.

Other than these providers, we only disclose information where the law requires it or with your consent. Within an agency, information is visible only to that agency's users; agencies cannot see each other's data.

7. Where it is stored

The platform database is hosted by Railway in [[PLACEHOLDER: hosting region]]. Anthropic and Resend process information in other countries, including the United States. Where personal information leaves South Africa, we rely on the provider's contractual commitments to protect it to a standard comparable to POPIA (section 72 of POPIA).

8. How long we keep it

  • Candidates who withdraw consent: erased 30 days after withdrawal.
  • Inactive candidate profiles: erased after 24 months without profile updates, pipeline activity or interviews. A candidate on a running contract is never erased for inactivity.
  • Expired invitations and password-reset tokens: deleted automatically.
  • AI usage records: kept for 12 months.
  • Audit trail: kept for 36 months. Erasing a candidate removes their name and email from audit entries.
  • Invoices and contractor records: kept in anonymised form where bookkeeping requires it.
  • Email suppression list: when someone unsubscribes or an address bounces, the address is kept on a suppression list so we do not email it again. This list is retained even after erasure of a candidate profile, for that purpose only.

Retention periods are the platform defaults and can be adjusted. Erasure by an agency or on request happens immediately and also scrubs copies held in campaign emails and login records.

9. Security

We protect information with encrypted connections, hashed passwords, role-based access, per-agency data separation, signed session cookies, rate limiting, and an audit trail of changes. No system is perfectly secure. If a breach affecting personal information occurs, we will notify the affected agencies, the Information Regulator and, where required, the individuals concerned, as POPIA requires.

10. Cookies and local storage

We use one essential cookie (scoutx_session) to keep you signed in, and your browser's local storage for interface preferences. We do not use advertising or analytics cookies.

11. Your rights

Under POPIA you may ask to:

  • access the personal information held about you (agencies can download a candidate's full record as a file);
  • correct or delete it;
  • object to its processing, or withdraw consent you have given;
  • lodge a complaint with the Information Regulator.

Contact our Information Officer at [[PLACEHOLDER: Information Officer email address]]. The Information Regulator can be reached at [email protected] or inforegulator.org.za.

12. Children

ScoutX is a business tool and is not intended for people under 18.

13. Changes

We will update this policy when our practices change and show the date at the top. For material changes we will notify agency administrators.

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