1. Scope of this policy

Skhatsi-itstime (Pty) Ltd ("Skhatsi-itstime", "we", "us", "our") is committed to protecting the privacy of every person whose personal information we process. This policy explains what personal information we collect, why we collect it, who we share it with, and what rights you have in terms of the Protection of Personal Information Act, 2013 ("POPIA").

This policy applies to:

• visitors to www.skhatsi-itstime.co.za and any subdomain we operate, including our learner portal and Moodle learning management system;
• prospective learners who submit an enrolment, enquiry or Recognition of Prior Learning (RPL) application;
• registered learners enrolled on any of our programmes;
• employers, sponsors, funders and partner organisations who transact with us;
• suppliers, contractors and job applicants.

2. Personal information we collect

We collect only the information we need for the purposes set out in section 4. Depending on your relationship with us, this may include:

Category	Examples
Identity information	Full names, surname, South African ID number or passport number, date of birth, nationality, gender
Contact information	Physical and postal address, email address, mobile and landline numbers, next-of-kin details
Education and employment	Highest qualification, matric or equivalent results, prior certifications, CV, employment status, employer name, workplace details
Programme records	Enrolment records, attendance, formative and summative assessment results, portfolio of evidence, RPL evidence, certificates issued, learner portal and Moodle activity logs
Financial information	Invoicing details, proof of payment, bursary or sponsorship details, funding source
Technical information	IP address, browser type and version, device type, pages visited, date and time of access
Communications	Emails, contact form submissions, support tickets, and messages you send through the website chat assistant

3. Special personal information

Certain information is classified as "special personal information" under section 26 of POPIA and is subject to stricter controls. In our case this includes:

• Race or ethnic origin — which we are required to record for Broad-Based Black Economic Empowerment (B-BBEE) skills development reporting and for statutory reporting to Sector Education and Training Authorities (SETAs).
• Disability status — where you disclose it, so that we can provide reasonable accommodation during training and assessment.
• Health information — only where you voluntarily disclose it in support of an application for special assessment arrangements or deferral.

We process special personal information only where the law authorises or requires it, or where you have given us your express written consent. You may decline to provide this information, but doing so may prevent us from enrolling you on programmes that carry statutory reporting obligations.

4. Why we process your information

We process personal information for the following purposes and no others:

• to respond to your enquiry, quotation request or consultation booking;
• to register and enrol you on a programme, and to administer your learning;
• to conduct assessment, moderation, and Recognition of Prior Learning;
• to issue statements of results, certificates and credentials;
• to register you for external certification examinations with our examination partners;
• to meet statutory reporting obligations to the Quality Council for Trades and Occupations (QCTO), the relevant SETA, and other regulators;
• to report on learner outcomes to employers, funders and sponsors who fund your training, and to support their B-BBEE skills development reporting;
• to invoice you and process payments, and to comply with tax and accounting law;
• to maintain the security and integrity of our website, learner portal and learning management system;
• to send you information about programmes, intakes and events, where you have asked us to.

5. Our lawful basis for processing

We rely on one or more of the following justifications set out in section 11 of POPIA:

• Consent — for marketing communications, for the website chat assistant, and for processing special personal information beyond what statute requires.
• Performance of a contract — to deliver the training you have enrolled and paid for.
• Legal obligation — to meet reporting duties owed to the QCTO, SETAs, the South African Revenue Service and other authorities.
• Legitimate interests — to secure our systems, prevent fraud, and improve our programmes.

Where we rely on your consent, you may withdraw it at any time by writing to info@skhatsi-itstime.co.za. Withdrawal does not affect the lawfulness of processing carried out before withdrawal, and does not extend to records we are legally obliged to retain.

6. Who we share your information with

We do not sell your personal information. We share it only where necessary, and only with the following categories of recipient:

Recipient	What is shared and why
Quality Council for Trades and Occupations (QCTO) and the relevant SETA	Learner registration, achievement and certification data, as required by the National Qualifications Framework Act and applicable quality assurance policy
Certification and examination partners	Your name, ID or passport number and contact details, to register you for and administer external certification examinations
Employers, sponsors and funders	Attendance and progress reporting, but only where that party is funding your training and only to the extent agreed with you at enrolment
Technology service providers	Our website host, email provider, learning management system host and the provider of our website chat assistant, acting as operators on our written instruction
Professional advisers and authorities	Our accountants, auditors and legal advisers, and any authority to which we are legally compelled to disclose

Every operator that processes personal information on our behalf is bound by a written agreement requiring them to process it only on our instruction and to maintain appropriate security safeguards, as required by sections 20 and 21 of POPIA.

7. Cross-border transfers

Some of our service providers process information on servers outside South Africa. This includes our email and productivity platform, our certification partners, and the provider of our website chat assistant.

Where personal information is transferred outside the Republic, we do so in accordance with section 72 of POPIA — that is, where the recipient is subject to a law, binding agreement or corporate rules that provide an adequate level of protection substantially similar to POPIA, or where the transfer is necessary to perform a contract with you.

8. Our AI assistant and website chat

9. Cookies and website analytics

Our website uses cookies and similar technologies to keep you signed in to the learner portal, to remember your preferences, and to understand how the site is used. Cookies fall into these categories:

• Strictly necessary — session and authentication cookies required for the learner portal and learning management system to function. These cannot be disabled.
• Functional — cookies set by the chat assistant to maintain the conversation while you browse.
• Analytics — cookies that help us count visits and see which pages are useful.

You can block or delete cookies through your browser settings. If you block strictly necessary cookies, the learner portal will not work.

Our pages also load resources from third-party content delivery networks, and our consultation booking link is hosted by a third-party scheduling platform. Those providers may log your IP address as a technical consequence of serving the content.

10. How long we keep your information

We keep personal information only for as long as we need it, or for as long as the law requires, whichever is longer:

• Enquiries that do not lead to enrolment — up to 12 months from last contact.
• Learner and assessment records — for the period prescribed by the QCTO and the relevant SETA for accredited programmes, so that your achievement can be verified and re-issued.
• Financial and tax records — five years from the end of the relevant tax period, in terms of the Tax Administration Act, 2011.
• Company records — seven years, in terms of the Companies Act, 2008.
• Marketing consents — until you withdraw consent.

When a retention period ends, we securely destroy, delete or de-identify the information.

11. How we protect your information

We apply appropriate, reasonable technical and organisational measures as required by section 19 of POPIA, including:

• encryption of data in transit using TLS across our website, learner portal and learning management system;
• hashed storage of all account passwords — we never store passwords in readable form;
• role-based access control, so that staff can access only the records they need;
• storage of uploaded documents outside the public web root, so they cannot be reached directly by URL;
• regular backups, held separately from the live system;
• multi-factor authentication on administrative and email accounts.

If a security compromise occurs that creates a reasonable belief that your personal information has been accessed or acquired by an unauthorised person, we will notify you and the Information Regulator as soon as reasonably possible, in terms of section 22 of POPIA.

12. Your rights as a data subject

Under POPIA you have the right to:

• be told whether we hold personal information about you, and to request a copy of it;
• request that we correct or delete information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or unlawfully obtained;
• object, on reasonable grounds, to our processing of your information;
• withdraw consent where our processing relies on consent;
• refuse to receive direct marketing, and to be given a means of opting out of every marketing message we send;
• not be subject to a decision based solely on automated processing that has legal consequences for you;
• complain to the Information Regulator, and to seek relief from a court.

To exercise any of these rights, write to our Information Officer at info@skhatsi-itstime.co.za. Requests for access to records must be made on Form 2 prescribed under the Promotion of Access to Information Act, 2000, and requests for correction or deletion on Form 3 prescribed under the POPIA Regulations. We will respond within the periods prescribed by law. We may need to verify your identity before acting on a request, and a prescribed fee may apply to access requests.

13. How to lodge a complaint

Please raise any concern with our Information Officer first — most matters can be resolved directly and quickly. If you are not satisfied with our response, you may complain to:

The Information Regulator (South Africa)
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
General enquiries: enquiries@inforegulator.org.za
POPIA complaints: POPIAComplaints@inforegulator.org.za
Website: inforegulator.org.za

14. Children and learners under 18

Some of our programmes are open to learners under the age of 18. Where a prospective learner is a child as defined in POPIA, we will process their personal information only with the prior consent of a competent person — ordinarily a parent or legal guardian — unless another ground in section 35 of POPIA applies. We will ask for written proof of that consent before enrolment is confirmed.

15. Changes to this policy

We may update this policy from time to time to reflect changes in our operations or in the law. The version number and effective date at the top of this page will always tell you which version applies. Material changes will be communicated to registered learners by email.

Contact us

Skhatsi-itstime (Pty) Ltd
Regus, Promenade Mall, Mbombela, Mpumalanga
Email: info@skhatsi-itstime.co.za
Telephone: 072 305 5533

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