Operator agreement
This agreement applies whenever Accolgo processes personal information on behalf of a customer organisation, and meets the written-agreement requirement in sections 20 and 21 of the Protection of Personal Information Act, 2013 (POPIA). The customer is the responsible party; Accolgo is the operator.
Subject matter and duration
Processing of onboarding check-in information (identities and contact details of starters, managers and buddies; worded check-in replies; optional notes; follow-up records) for the duration of the customer's subscription, and after that until Accolgo deletes it at the customer's request or, once automatic deletion is switched on, on the schedule in the retention policy.
Instructions
Accolgo processes personal information only to provide the service as documented, with the knowledge and authorisation of the responsible party, and never for its own purposes except anonymised aggregates as described in the terms. Accolgo treats all such information as confidential.
Sub-operators
| Provider | Purpose | Region |
|---|---|---|
| Supabase | Database, authentication, storage | UK (London) |
| Vercel | Application hosting | Application code runs in London (United Kingdom), the same place as the database. Vercel’s network passes requests through the nearest point of presence, and Vercel states its primary processing facilities are in the United States |
| Resend | Transactional email | US / per sending configuration |
| Sentry | Error monitoring | United States or EU |
| Anthropic | Powers the in-app help assistant, which picks help articles to show. Receives the question a signed-in user types | United States |
| Twilio | Will send the WhatsApp check-in message to a line manager or buddy who chooses WhatsApp, once WhatsApp check-ins start, which is coming soon. It will handle their mobile phone number and the message, which can name the new starter and holds a private check-in link. WhatsApp is only used when a line manager or buddy chooses it. | Not yet confirmed |
| Meta (WhatsApp Business) | Will provide the WhatsApp Business service that carries that message, once WhatsApp check-ins start, which is coming soon. It will handle the same mobile phone number and message. WhatsApp is only used when a line manager or buddy chooses it. | Not yet confirmed |
| Stripe | Takes subscription payments | United States (Stripe, LLC) and Stripe affiliates elsewhere. UK and EEA customers contract with Stripe Payments Europe, Limited |
We give notice before adding or replacing a sub-operator and flow down equivalent obligations, each under a written agreement.
Stripe acts as an independent controller for choosing payment networks, fraud prevention and legal compliance, under its own privacy notice, and never receives check-in answers or notes.
Security safeguards, confidentiality and personnel
As required by section 19 of POPIA, Accolgo secures the integrity and confidentiality of personal information through appropriate technical and organisational measures, described on the security page: encryption in transit, row-level security with zero anonymous table access, tokenised single-use check-in links, audit records, and least-privilege access. Everyone with access is bound by confidentiality.
The private word. A “private word” with someone senior who is not the starter's own manager is accessible only to the organisation's head of people (and owner), the roles every named senior contact on the account must hold. The person's manager is not told, unless the organisation has nobody senior besides the manager, in which case the starter is told this before sending. The words are stored in the database, encrypted at rest by our database provider but not separately encrypted by Accolgo, with the organisation's other check-in answers, and only Accolgo's own authorised technical staff with database administrator access, running the service, could technically read them.
Security compromises (breach notification)
Where there are reasonable grounds to believe personal information has been accessed or acquired by an unauthorised person, Accolgo notifies the responsible party without undue delay so that it can notify the Information Regulator and the affected data subjects as section 22 of POPIA requires, and assists with that notification.
Data subject participation and assistance
Accolgo assists the responsible party with requests for access, correction and deletion, including hard deletion and a copy of one person's data, both done by hand on request, and with impact assessments and audits.
A person’s information export includes the check-in answers their manager and buddy gave about their settling in. Managers and buddies should be told, when they are asked to take part, that their observations form part of the new starter’s record and can be disclosed to that person on request. The one exception is a private-word message, which belongs to the person who raised it, not to the starter it may concern.
Cross-border transfer (section 72)
Personal information is stored in the United Kingdom (Supabase, London). Some sub-operators process limited information in the United States: hosting (Vercel), transactional email (Resend), the in-app help assistant (Anthropic), payments (Stripe, the paying organisation's billing details only) and, where it does not use the EU, error monitoring (Sentry). Each such transfer outside South Africa is made on the basis section 72 of POPIA allows: the recipient is bound by a written agreement that upholds principles for the reasonable processing of the information substantially similar to POPIA, and the transfer is necessary for the performance of the service the responsible party has requested. The responsible party authorises these transfers by entering into this agreement.
Return and deletion
On termination the customer can ask Accolgo for a copy of all its information, and ask for it to be deleted. Until automatic deletion is switched on, Accolgo deletes it by hand when asked. Once it is on, Accolgo deletes it on the retention schedule. In both cases Accolgo keeps only what the law requires be kept.