Candidate Privacy Notice
This Privacy Notice governs job applicants using the October People platform under South Africa's POPIA framework. Your submitted information—including contact details, CV, and assessment notes—is used by the employing entity to evaluate your application, with AI tools assisting in initial candidate ranking subject to mandatory human review. Personal data is hosted securely (including on U.S. servers under POPIA-equivalent protections), retained for 12 months if you are not hired, and never shared with other employers without your explicit opt-in. You hold full rights under POPIA to access, correct, or delete your data, or lodge a complaint by reaching out to the employer's recruitment team or help@october.health.
Published
01Who this notice is for
This notice is for people who apply for a job using the October People platform.
If you are hired, a separate Employee Privacy Notice will apply to you from your start date.
02Who is responsible for your information
Two organisations are involved, and they are responsible for different things.
ORGANISATION
RESPONSIBLE FOR
Your application
Employing Entity
Deciding what to ask, who reviews your application, and whether to hire you
The platform
October Health Limited
Running the recruiting software, on the employer’s instructions only
Matching you with other employers
October Health Limited
This applies only if you tick the optional box described in section 7
03What we collect, and whether you have to give it
We collect:
- Your name and contact details
- Your CV, work history, education and qualifications
- Your answers to the application questions
- Interview notes and any assessment results
- A record of your application’s progress — when you applied and what stage you reached
We collect this from you. If you give us referees, we may also collect what they tell us about you.
Giving us this information is voluntary. But we cannot consider you for the role without it.
04Why we use your information, and on what legal basis
WHAT WE DO
OUR LEGAL BASIS UNDER POPIA
Assess your application and run the hiring process
Steps towards concluding an employment contract with you — section 11(1)(b)
Keep a record so we can respond to a query, complaint or claim about the hiring process
Our legitimate interests — section 11(1)(f)
Match you with other employers
Your consent — see section 7
We do not rely on your consent for the main application process. This means you cannot lose your place in the process by declining consent.
05AI-assisted evaluation
We use AI tools to help review applications. They are used to summarise applications and to help rank them against the requirements of the role.
No hiring decision is made by AI alone. A member of the hiring team reviews every AI-assisted evaluation before any decision about you is taken.
You can ask us:
- for an explanation of how the AI tools were used in your application
- to have a person reconsider any evaluation
- to make representations to us about a decision
October Health publishes information about how its AI systems are tested, including the models used and the results of fairness testing. This can be found on its website: october.health/ai.
06Who can see your information
- The hiring team and the managers involved in the role
- October People staff, only where needed to provide technical support, and under confidentiality obligations
- Service providers that operate the platform, such as cloud hosting and AI providers, under written contracts
- Regulators or law enforcement, where the law requires it
We do not sell your information, and we do not share it with other employers unless you ask us to under section 7.
07Optional: matching with other employers
When you apply, you can tick a box asking October to consider you for roles at other employers using October People. This is entirely optional.
- It will not affect this application in any way
- If you tick it, October Health Limited becomes responsible for your profile for this purpose, and may share it with other employers on the platform so they can consider you for roles
- You can withdraw at any time from your candidate profile, or by emailing privacy@october.health. Withdrawing does not affect anything done before you withdrew
08Information sent outside South Africa
Some of your information is processed outside South Africa by our cloud hosting and AI providers, in the United States.
Where this happens, we have written agreements in place requiring a level of protection that is substantially similar to the protection POPIA gives you, including limits on any onward transfer.
09How long we keep your information
SITUATION
HOW LONG
You are not hired
12 months from the date of the decision, then deleted
You are hired
Your records move to your employee file, and the Employee Privacy Notice applies
You ticked the matching box in section 7
Until you withdraw
10Security
Your information is encrypted in transit and at rest, access is restricted to people who need it for their role, and platform activity is logged. No system is completely secure, so if you think something has gone wrong, please tell us using the contact details below.
11Your rights
You have the right to:
- Access — ask for a copy of the information we hold about you
- Correction — ask us to correct information that is wrong or incomplete
- Deletion — ask us to delete information, unless we are required to keep it
- Object — object to processing we carry out on the basis of our legitimate interests
- Withdraw consent — for anything you consented to, such as section 7
- Complain — lodge a complaint with the Information Regulator
To exercise any of these rights, use the contact details below. We will respond within a reasonable time and will not charge you for a first request.
12Contact and complaints
WHAT YOU NEED
WHERE TO GO
About your application and the information in it
Reach out to the employer’s recruiting email address provided
About the October People platform
To complain to the regulator
Information Regulator (South Africa) — www.inforegulator.org.za. Complaint forms and current contact details are on their website.
13Changes to this notice
We may update this notice. The effective date at the top shows when it was last changed. If we make a material change that affects candidates, we will update the notice before we collect any further information under it.