Privacy Policy

1. Scope and responsible party

This Privacy Policy applies to personal information processed through welcor.co.za, email, telephone and messaging communications, online forms, training, truth-verification testing, background screening, equipment transactions and WELCOR's other business activities.

For purposes of the Protection of Personal Information Act 4 of 2013 (POPIA), the responsible party is:

Information Officer: Chris Nel
Email: info@welcor.co.za
Telephone: 087 630 0911 / 057 630 0911

This policy should be read with any specific consent form, testing authorisation, application form, contract or notice supplied for a particular service.

2. Personal information we collect

The information we collect depends on your relationship with WELCOR and the service involved.

Identity and contact information

• Name, surname, date of birth or age;
• National identity, passport or similar identification information where required;
• Residential, business and postal addresses;
• Email address, telephone number and messaging contact details;
• Employer, institution, job title and other professional information.

Training and background-screening information

• Course selection, preferred location and date, experience, attendance and certification records;
• Employer or institution and intended area of operation;
• Government-employment and police, military or law-enforcement history;
• Criminal-record and Interpol watch-list information;
• Professional references, background-check results and information needed to assess course or software eligibility.

Testing and investigation information

• Information supplied by the client, test subject or another authorised source about the matter being examined;
• Pre-test and other interview information, test questions and answers;
• Voice samples, audio or other recordings where applicable;
• Polygraph charts, physiological measurements, voice-analysis data and related examination material;
• Test results, findings, reports, conclusions and supporting records;
• Information concerning alleged theft, fraud, misconduct, criminal behaviour, disputes, employment screening or security clearance.

Business, payment and technical information

• Quotations, invoices, payments, refunds and transaction records;
• Correspondence, enquiries, complaints and customer-support records;
• IP address, browser and device information, page activity, cookie choices and advertising or referral information generated when you use our website.

3. How we obtain information

We collect information directly from individuals wherever reasonably possible. We may receive it through our website, Google Forms, email, telephone, WhatsApp and other authorised messaging services, social media, in-person communication, contracts, consent forms and documents supplied for a service.

We may also receive information from an employer, client, attorney, investigator, government body, law-enforcement body, reference, screening provider or other person who is authorised or legally permitted to provide it. A client providing information about another person is responsible for having an appropriate lawful basis and for giving any required notice.

WELCOR does not purchase personal-information databases to obtain prospective clients.

4. Why and on what basis we process information

We process personal information only for a specific, lawful purpose and on a ground permitted by POPIA. Depending on the circumstances, we may rely on consent, a contract or steps requested before a contract, a legal obligation, protection of a legitimate interest, or the legitimate interests of WELCOR, a client or another person.

Our purposes include:

• Responding to enquiries, preparing quotations and communicating about services;
• Processing applications, assessing eligibility, conducting authorised background screening and registering students;
• Providing training, arranging course services, maintaining attendance records and issuing or verifying certificates;
• Preparing for, conducting, analysing and reporting on truth-verification examinations;
• Supplying agreed reports or results to authorised recipients;
• Managing client relationships, customer support, payments, invoices, refunds and accounting;
• Maintaining security, preventing misuse and investigating complaints, disputes or incidents;
• Complying with legal, regulatory, contractual and professional obligations;
• Marketing WELCOR's own services where permitted and measuring advertising performance.

If consent is the applicable ground, it may be withdrawn by contacting us. Withdrawal does not invalidate processing that was lawful before withdrawal and may affect our ability to continue the requested service.

5. Required and voluntary information

Unless a form or notice states otherwise, providing personal information is voluntary. Certain information is required to identify an applicant or test subject, assess eligibility, comply with legal or professional requirements, conduct a requested service, issue a certificate or report, or process payment.

Fields marked as required on an application form must be completed for the application to be assessed. If required information is withheld or cannot lawfully be processed, WELCOR may be unable to accept an application, conduct a test, issue a report or certificate, or provide another requested service.

6. Testing information and reports

Testing information can be confidential and may include special personal information. We use it only for legitimate purposes connected with the authorised examination, including preparation, interviewing, recording where applicable, analysis, quality control, reporting, dispute handling and required record keeping.

Where a client requests testing of another person, the client and WELCOR must handle the information in accordance with applicable law and the agreed service. The test subject will be informed about the process and asked to provide any required authorisation or consent.

Reports or results are provided only to the authorised client, the test subject where appropriate, or another recipient authorised or permitted by law. WELCOR does not sell test information and does not use test results, recordings or reports for advertising.

7. Training applications, APAVSA and background screening

The training application linked from this website is an APAVSA Training Application Form hosted through Google Forms within WELCOR's Google environment. The form identifies APAVSA and authorises APAVSA or its agents to conduct relevant background screening.

Information submitted through that form may be received and used by WELCOR, disclosed to APAVSA and authorised screening agents, and checked against relevant lawful sources for applicant vetting, course eligibility, software licensing, communication and training administration. Google processes form information as the technology provider under Google's terms and privacy practices.

Because the form requests identity and criminal-behaviour information, applicants should provide only accurate information and should not submit an application unless they understand and accept the stated screening authorisation. Any additional notice on the form applies together with this policy.

8. Who may receive personal information

WELCOR does not sell personal information. We may disclose information where necessary for the stated purpose or where disclosure is authorised or required by law. Recipients may include:

• The client who requested a service and the relevant applicant, student or test subject;
• APAVSA, approved instructors, screening agents and training partners;
• Authorised WELCOR employees, contractors and examiners;
• IT, hosting, email, communications, security, backup, software and technical providers;
• Google, Meta, LinkedIn, WhatsApp and other platforms used at your request or for disclosed business purposes;
• Payment providers, accountants, auditors, insurers and professional advisers;
• Attorneys, investigators, courts, regulators, government bodies or law-enforcement authorities where authorised or legally required;
• Another party authorised by the individual concerned.

Where a service provider processes information on our behalf, we take reasonable steps to require confidentiality, appropriate security and processing in accordance with our instructions and applicable law.

9. Information security and security compromises

Client information is stored primarily on a locally managed server operated and controlled by WELCOR. Safeguards include access controls, ESET security protection, firewall and network protection, router-level security and internal administrative controls. Network firewall services are hosted or supported through New Generations where applicable.

Access is limited to people who require the information for an authorised business purpose. No system can be guaranteed completely secure, so safeguards are reviewed and updated in response to relevant risks.

If there are reasonable grounds to believe that personal information has been accessed or acquired by an unauthorised person, WELCOR will investigate, contain and assess the incident. We will notify the Information Regulator and, where required, affected individuals as soon as reasonably possible in accordance with POPIA, subject to any lawful delay or exception.

10. Retention and deletion

WELCOR generally retains client and service-related information for five years after completion of the relevant service or the end of the applicable relationship. Records may be retained longer where required by law, contract, litigation, an investigation, a dispute, a professional requirement or another lawful business purpose.

Accounting and tax records are retained for the period required by applicable law. Certificate and attendance records may be retained for longer where reasonably required to verify qualifications. Information that is no longer required will be securely destroyed, deleted, de-identified or made permanently inaccessible.

11. International processing

WELCOR operates from South Africa and serves clients and students internationally. Google, Meta, LinkedIn, WhatsApp, email, software, payment and other technology providers may process information in countries outside South Africa.

Where personal information is transferred to a recipient outside South Africa, WELCOR will use a transfer ground permitted by POPIA. This may include an applicable law, binding agreement or corporate rules providing substantially similar protection; the individual's consent; performance of a relevant contract; or another ground allowed by section 72 of POPIA.

12. Information about children

WELCOR does not provide training to people under 18. Certain testing may involve a person under 18 where this is lawful and appropriate and the required consent of a parent or legal guardian has been obtained.

Children's information is processed only for the specific authorised purpose and with additional care. It is not used for unrelated marketing and is not knowingly uploaded to Google advertising customer lists or similar advertising audiences where prohibited.

13. Direct marketing

WELCOR may market its own services and courses through email, WhatsApp, telephone, Facebook, LinkedIn, Google and other permitted channels. Electronic direct marketing will be sent only where permitted by POPIA and other applicable law, including on the basis of appropriate consent or the applicable existing-customer exception.

Marketing communications will identify WELCOR and provide a practical way to object or unsubscribe. You may opt out at any time by following the communication's instructions or emailing info@welcor.co.za. Opting out of marketing does not stop service, safety, legal or transactional communications.

14. Cookies and online services

Our website uses browser storage to remember your privacy preference. With your permission, we load the Google Ads tag identified as AW-993609994 to measure advertising performance and support advertising features. Google may process the page URL, IP address, browser or device information, advertising identifiers and cookie data for these purposes.

The Google advertising and measurement tag is not loaded until you grant that optional permission through our banner. If you reject non-essential technologies, your preference is stored locally but the Google Ads tag is not loaded. You can change your choice at any time by selecting Cookie settings in the website footer.

The website also uses:

• Google Maps on the contact page. Loading or interacting with the embedded map may send technical and usage information to Google.
• Google Forms for the APAVSA training application. Information entered into the form is submitted to Google and the form recipients described above.
• Cloudflare cdnjs to deliver Font Awesome icon files. Requests may disclose ordinary technical information such as an IP address, browser type and requested resource.
• Facebook and LinkedIn links. If you follow them, the relevant platform's privacy policy and settings apply.

For more information about Google's processing, see How Google uses information from sites or apps that use its services and the Google Privacy Policy.

15. Your privacy rights

Subject to applicable law, you may:

• Ask whether WELCOR holds personal information about you and request access to it;
• Request correction or deletion of inaccurate, irrelevant, excessive, outdated, incomplete, misleading or unlawfully obtained information;
• Object to processing in circumstances permitted by POPIA;
• Object to direct marketing at any time;
• Withdraw consent where processing relies on consent;
• Ask about the purpose of processing and categories of recipients;
• Complain to WELCOR or the Information Regulator and pursue other remedies available under law.

We may need to verify your identity and request enough detail to locate the relevant record. Rights can be subject to lawful limitations, including confidentiality, another person's rights, legal privilege, record-retention duties or ongoing proceedings.

16. Requests and complaints

Send privacy requests, corrections, deletion requests, objections, marketing opt-outs or complaints to:

You may also lodge a POPIA complaint with:

17. Changes to this policy

We may update this policy when our services, technology, processing practices or legal obligations change. The latest version will be published on this page with its effective and last-updated dates. Material changes may also be communicated through an appropriate additional notice.

This policy is governed primarily by the laws of the Republic of South Africa. Additional privacy laws may apply where services are provided internationally.