Leggett & Platt – Recruiting Privacy Notice, South Africa

July 2021

The privacy and protection of your Personal Data are of great importance to Leggett.

As part of our recruiting activities, L&P Springs SA (Pty) Ltd. (referred to as “Leggett,” “Company,” “we,” “our,” or “us”) collects and processes personal information (i.e., data that can be associated/attributed to an individual, hereinafter "Personal Data").

This Privacy Notice is intended to inform you, the applicant, and others involved in the recruitment process, about how and why we process your Personal Data during and after your job application, in accordance with the South African Protection of Personal Information Act, 2013 (POPIA) and its further amendments. It includes information about what is collected, with whom we share your Personal Data, how long we keep them, and what your rights are in regard to the processing.

1. Who is responsible for the processing of your Personal Data?

The Company is the responsible party or data controller, which means that it is the entity that collects your Personal Data and decides why and how to process them.

2. What Personal Data do we collect?

We collect the following types of Personal Data from our job applicants:

  • Personal information (e.g., first and last name, address, date of birth, gender, phone number, e-mail address)
  • Information related to education (e.g., your educational background, skills and relevant diplomas)
  • Information related to professional experience (e.g., your employment history and relevant experience)
  • Information related to legal status (e.g., your work or residence permit)
  • Information as a result of a visit to our office (e.g. dates and times of visit, image captured in our physical security system or picture captured on visitor badge)
  • Personal Data included by the applicant on a Resume or Curriculum Vitae or provided during the recruitment process such as references.

As a matter of practice, we do not otherwise collect sensitive Personal Data about applicants (e.g., data related to health, race, ethnic origin or political views.) If there is a need to process sensitive Personal Data for the purposes of our recruitment process, (e.g., if we need to learn about any special needs you may have in order to provide a proper work environment; in order to complete the hiring process of a final candidate), we will only process such sensitive Personal Data in strict compliance with the applicable data protection laws and regulations. Generally, we will collect the above-mentioned Personal Data directly from you (for example, when you provided this information as part of your application letter, your CV or during an interview). In certain scenarios, we will also obtain your Personal Data from other sources such as references supplied by former employers, information provided by professional and criminal background check service where legally applicable, or public information. If so, we will do this in strict compliance with applicable data protection laws and regulations.

3. For which purposes do we collect and process your Personal Data?

We collect and process your Personal Data for the following purposes:

  • To create and maintain your recruitment records, to manage and assess your application, and to communicate with you throughout the selection process (e.g., to evaluate and confirm your suitability for the position you applied for, to communicate with you the status of your application);
  • To document, analyze, and improve our recruitment process (e.g., maintaining recruitment statistics);
  • Meet legal obligations (e.g., financial, fiscal, and administrative obligations or verification of your employment eligibility);
  • Internal and external investigations when we need to assess, prevent or take action related to illegal activities, suspected fraud, cases involving potential threat to the safety of any individual or our assets; and
  • Establish, enforce or defend against legal claims.

4. Who has access to your Personal Data?

To manage your recruitment process, we will share your Personal Data internally with members of our Human Resources Department, interviewers involved in the recruitment process and managers in departments with a vacancy. We may also share your Personal Data within the group of Leggett & Platt, Incorporated companies (“Leggett Group”) who may be providing services to Company or otherwise involved in the recruitment or hiring process, such as corporate Human Resources, IT services, or management of the business unit or division. In each case, only if the access is necessary for the performance of their roles. In addition, and only when necessary to fulfil the purposes mentioned above, we will disclose your Personal Data to the following recipients or categories of recipients, as the case may be:

  • Third-party agents, service providers and counsellors (e.g. in relation to IT services, compliance verification, background check, medical examinations, payments, legal advice, or postal services);
  • Law enforcement, government authorities or courts when requested and necessary to comply with the applicable laws. We will not disclose your Personal Data to any parties who are not authorised to process them.

5. On which legal basis do we process your Personal Data?

We rely on the following legal basis for processing your Personal Data:

  • Your consent, to the extent you have provided the Personal Data as part of a voluntary application for employment (for example, on a Resume) and it is used solely for those purposes. You understand that you may decide at any time to not provide the Personal Data and withdraw your name from further consideration;
  • When the processing is necessary for us to decide whether we should establish an employment relationship with you or, once decided, to complete that employment relationship;
  • Compliance with the legal obligations to which we are subject (e.g. when we are legally bound to verify your work and residence permit);
  • For some positions, we are required to search for information regarding criminal convictions and violations. Should that be the case, we will only do what is necessary for compliance with our obligations and in order to exercise specific rights to employment; and
  • Our legitimate interests (such as to protect us from harm by preventing or detecting illegal activities; to establish, exercise or defend ourselves against legal actions; or to analyze and improve our recruitment process), unless we determine, in a case-by case assessment, that our interests are overridden by your interests or fundamental rights and freedoms, and the Personal Data processed is limited to what is strictly necessary for the intended purpose.

6. Where will my Personal Data be processed?

Your Personal Data may be processed inside and outside of South Africa by us, the Leggett Group, or the data processors working on our behalf. Please note that other countries have different laws regarding the protection of Personal Data. When your Personal Data are transferred from your own country to another country, the laws and regulations that protect your Personal Data in the country to which your information is being transferred may be different (or offer less protection) than those in your country of residence. For example, the circumstances in which law enforcement authorities can access your Personal Data may vary from country to country. If your Personal Data are transferred outside South Africa, we will ensure that it is done in compliance with applicable laws, with appropriate safeguards, and in compliance with your rights regarding your Personal Data noted below.

7. How do we protect your Personal Data?

The Company maintains appropriate technical and organizational safety measures to help protect your Personal Data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure, or use.

8. How long do we keep your Personal Data?

We will not retain your Personal Data for longer than necessary in order to meet the purposes for which the data had been collected, or to comply with our legal obligations. Afterwards, we will delete your Personal Data. If your application for employment is unsuccessful, we may retain your Personal Data on file for up to 6 months after you have been notified of our decision for legitimate interest purposes (e.g. to prove compliance with law if needed). If your application is unsuccessful and we wish to keep your Personal Data to match future job offerings, we will explicitly ask for your consent to retain your data for a period longer than 6 months. If your application for employment is successful, your Personal Data gathered during the recruitment process will be transferred to your personnel file and retained during your employment.

9. What are your rights with respect to your Personal Data?

To the extent permitted by the applicable data protection laws and regulations and using the prescribed form, you have the following rights regarding your Personal Data:

  • To request access to the Personal Data and confirmation of the existence of the processing;
  • To request deletion of your Personal Data if it is no longer necessary or excessive for the purposes mentioned above;
  • To request correction or deletion of incomplete, inaccurate, irrelevant, misleading, out-of-date, or Personal Data obtained unlawfully;
  • To object at any time to the processing of your Personal Data that is based on legitimate interest or done for purposes of direct marketing other than by means of unsolicited electronic communication, without affecting the legality of the prior processing activities;

You may exercise the aforementioned rights by sending a request to your recruiting contact or to contact indicated in Section 10 below and providing your name, your e-mail address and a description of your request. If you believe we have not complied with our obligations under applicable data protection laws and regulation, you may lodge a complaint to the Information Regulator by emailing complaints.IR@justice.gov.za or by writing to:

Information Regulator
PO Box 31533
Braamfontein, Johannesburg 2017

The Company is committed to cooperating with the Information Regulator to investigate and resolve unresolved privacy concerns.

10. How can you contact us?

If you have any questions about this Privacy Notice, the Company's privacy practices, or other data privacy questions, please contact your recruiting contact or the Company at privacy@leggett.com and provide details about your question. You may also visit our privacy and data protection site at http://privacy.leggett.com or write to:

L&P Springs SA (Pty) Ltd..
Attn: Information Officer
PO Box 958
Benoni, Gauteng 1500
South Africa

Or

Leggett & Platt, Incorporated
Attn: Associate General Counsel—Privacy & Data Protection
No. 1 Leggett Road
Carthage, Missouri 64836
USA