This notice explains how Profile Corporate Services (Pty) Ltd (“Profile”, “we” or “us”) handles your personal information when you use our employee services, including eClocker. It explains what information is collected, why it is used, who can access it and how you can exercise your rights. 

Your employer usually decides why and how your employment information is used. This makes your employer the “responsible party” under the Protection of Personal Information Act 4 of 2013 (POPIA). Profile provides the service and processes this information on your employer’s documented instructions as an “operator”. 

For questions about your employment records or your employer’s monitoring requirements, contact your  employer directly. 

What We Collect 

• Your name, employee number and relevant contact details. 

• Your assigned workplace, roster and clock-in and clock-out records. 

• The unique identifier of the device used to access the application to associate clocking and location records with your employee account. 

• Location information, where the relevant feature is enabled, as explained below. 

• Your photograph, used by your employer to visually verify your identity.  

• Information you provide when requesting support. 

We receive information from your employer, directly from you when you use the service or contact us, and automatically from your device when the relevant app features operate. We process only the information needed for the services and purposes explained in this notice. When acting as your employer’s operator, we process that information on its documented instructions. 

When you enrol on eClocker, the app captures your photograph using your phone’s camera. It is stored securely on Profile’s server and used by your employer to visually verify your identity when you clock. 

Why We Use It 

We use your information to provide the services your employer has selected, including recording attendance, managing rosters, preparing timesheets and providing payslips. We also use relevant information to resolve support requests, secure the service and meet applicable legal obligations. 

Your employer must identify an applicable legal reason for processing your information. Depending on the purpose, this may include meeting a legal obligation, performing a contract with you, pursuing a legitimate interest or obtaining your consent. Your employer will explain the reason that applies to location monitoring. 

eClocker Location Monitoring 

Before monitoring begins, your employer will explain its specific purpose, the lawful basis relied upon, whether it is required for your role, the consequences of declining and any available alternative attendance arrangements. 

Where your employer enables location monitoring, it acts as the responsible party under POPIA. Profile processes the information as an operator on your employer’s documented instructions. 

eClocker collects your device’s location coordinates, timestamps and unique device identifier to verify attendance at assigned locations or supervise mobile work. 

Shift monitoring starts only when you are clocked in and your rostered shift has begun. It stops when you clock out or reach the scheduled shift end, whichever happens first. If your employer authorises and records a shift extension in the system, the updated end time applies. Monitoring continues during breaks within that shift. 

Separately from shift monitoring, eClocker records your location when you clock in or out to verify the clocking location. When you clock in or out offline, the app stores the clocking record on your device and automatically syncs it with Profile when connectivity is restored. 

While shift monitoring is active, eClocker attempts to record your location every 15 minutes. Device settings, connectivity and operating-system restrictions may delay or prevent records. Location may be collected in the background, including while you use other apps or your screen is locked, subject to your device permissions and operating-system restrictions. 

You may decline or change location permissions in your device settings. This limits or prevents location collection but does not delete existing records. Employer activation cannot override your device permissions. Granting device permissions does not, by itself, establish consent under POPIA or replace your employer’s obligations. 

If you believe a location or attendance record is incorrect, contact your employer or submit an eClocker support ticket. 

You may submit a privacy request through an eClocker support ticket, contact your employer, or contact Profile’s Information Officer using the details below. You do not need access to the app to make a request. 

Where Profile holds information on your employer’s behalf, we will help direct your request to your employer and assist it in responding. 

Who Can Access It? 

Information is accessible to authorised personnel at your employer and to Profile personnel who need it to provide, secure or support the service. We also use hosting and technical-support providers, subject to appropriate confidentiality and security obligations. We disclose information to public authorities only where lawfully required. 

How We Protect Your Information 

We take reasonable technical and organisational measures to protect personal information against loss, unlawful access and unauthorised use or disclosure. Access is limited to people who need the information for their work. 

How Long We Keep It 

We retain attendance and payroll records for the periods required by applicable law and your employer’s lawful retention schedule, including after employment ends where necessary. You can request details of the retention periods applicable to your records from your employer. 

Identification photographs are retained while needed to verify your identity during employment. Detailed location records are retained for the period specified in your employer’s retention schedule, which must be justified by the purpose of collection. 

Relevant records may be retained longer where lawfully necessary for a specific dispute or legal obligation. When retention is no longer justified, records are securely deleted or de-identified. 

Your Rights 

You may ask whether personal information about you is held and request access to it, subject to applicable legal requirements. You may also ask who has received it. 

You may request correction or deletion of information that is inaccurate, irrelevant, excessive, outdated, incomplete, misleading or unlawfully obtained, or that may no longer lawfully be retained. 

Where processing relies on consent, you may withdraw that consent at any time. Withdrawal does not make earlier lawful processing unlawful or prevent processing supported by another applicable lawful ground. 

Where POPIA allows, you may object to processing on reasonable grounds relating to your particular circumstances. 

Contact your employer  or Profile’s Information Officer to make a request. We may need to verify your identity and will help you follow the applicable procedure. 

Data Breach Notification 

Where there are reasonable grounds to believe that information processed for your employer has been accessed or acquired by an unauthorised person, Profile will notify your employer immediately and assist its response.  

Where POPIA requires notification to affected employees, your employer will arrange that notification, with Profile’s assistance. Where Profile is the responsible party for the affected information, Profile will make the required notifications. 

Cross Border Information Transfers 

Your information is stored and accessed in South Africa and is not transferred outside South Africa by Profile. 

Complaints 

You may complain directly to the Information Regulator through https://inforegulator.org.za/complaints/ 

which explains how to submit a complaint through its eServices portal.  

For general enquiries, call 010 023 5200 or email enquiries@inforegulator.org.za 

Contact Information  

Our appointed Information Officer is David Brown, Director. For any queries regarding the processing of your personal information or to exercise your rights, please contact him at david.brown@profilecs.com or 011 477 9620.