Effective Date: 23rd February 2026

1. Introduction

Axis Human Capital Limited (“Axis”, “we”, “our”, or “us”) is committed to protecting the privacy, confidentiality, and security of personal and organizational information entrusted to us.

This Privacy Policy explains how we collect, use, process, store, disclose, and protect personal data in the course of delivering recruitment, training, consulting, organizational development, and related services.

Axis processes personal data in accordance with the Ghana Data Protection Act, 2012 (Act 843) and, where applicable, international data protection standards including the General Data Protection Regulation (GDPR). By using our website or engaging our services, you acknowledge that you have read and understood this Privacy Policy and, where required by applicable law, consent to the collection and processing of your personal data as described herein.

2. Scope of this Policy

This Policy applies to personal data collected through:

• Our website and online platforms
• Recruitment processes and job applications
• Training programs and workshops
• Consulting engagements
• Business communications
• Events and surveys

Any interaction with Axis as a client, vendor, candidate, partner, or employee. This Policy also applies to personal data relating to employees of Axis and employees of client organizations where such data is processed in the course of recruitment, OD consulting, training, or any advisory engagements. 

This Policy also applies to external business partners, including merchants, suppliers, contractors, vendors, and other service providers who receive, send, collect, access, or process Personal Data on behalf of Axis, whether by automated means or otherwise. It also applies to third-party Data Processors that process Personal Data provided by Axis.

This Policy does not apply to third-party websites or services that may be accessible through links on our website.

3. Definitions

Personal Data: Any information relating to an identifiable individual.
Sensitive Personal Data: Information relating to health, disability, religion, ethnicity, or other protected characteristics.
Data Subject: The individual to whom the personal data relates.
Data Controller: The entity that determines how and why personal data is processed.
Data Processor: An entity that processes data on behalf of a controller.

Processing – Any operation performed on personal data including collection, recording, organization, storage, retrieval, consultation, disclosure, or deletion. 

Consent – Any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which they signify agreement to the processing of personal data.

Data Breach – Any unauthorized access, disclosure, alteration, loss, or destruction of personal data

Axis may act as both a data controller and data processor depending on the nature of the engagement.

4. Information We Collect

We may collect the following categories of information:

4.1 Personal Identification Information

• Name
• Date of birth
• Gender
• Nationality
• Identification documents (where legally required)
• Contact details (email, phone, address)

4.2 Professional and Recruitment Information

• Curriculum vitae (CV)
• Educational background
• Professional and Employment history
• Skills and qualifications
• References, Background verification data and Criminal records check (where legally permissible and conducted with explicit consent)
• Interview notes and assessments
• Salary expectations
• Psychometric Assessment Results

4.3 Client and Business Information

• Company details
• Contact persons
• Contractual information
• Project data
• Payment and billing information

4.4 Training and Program Information

• Attendance records
• Assessment results
• Feedback responses
• Certification details

4.5 Technical and Website Information

When you visit our website, we may collect:

• IP address
• Browser type
• Device information
• Pages visited
• Date and time of access

4.6 Sensitive Personal Data

We only collect sensitive data where strictly necessary (e.g., workplace accommodations, health disclosures) and with explicit consent or legal authorization.

5. How We Collect Information

Information may be collected through:

• Direct submission (forms, applications, emails)
• Recruitment applications
• Training registrations
• Email and phone communications
• Interviews and assessments
• Website forms, interactions and cookies
• Client-provided data and contracts
• Publicly available professional sources
• Third-party service providers
• Cookies and analytics tools

6. Purpose of Processing

We process personal data for legitimate business purposes, including:

• Recruitment and Talent Placement Services
• Evaluation of Candidate Suitability
• Delivery of Training, workshops and Capacity Development programs
• Provision of HR Consulting, Advisory, and organizational development services
• Client Relationship Management
• Communication related to services and engagements 
• Compliance with legal and regulatory obligations
• Processing of Payments, Billing, and Contractual Administration.
• Website Functionality and Analytics 
• Research, Service improvement, and business development 
• Marketing communications (where consent has been provided)

7. Legal Basis for Processing

Axis processes personal data in accordance with the Data Protection Principles set out under the Data Protection Act, 2012 (Act 843), including accountability, lawfulness of processing, purpose specification, compatibility of further processing, data quality, openness, security safeguards, and data subject participation.

Personal data is processed on one or more of the following lawful bases: consent of the data subject, performance of a contract, compliance with legal obligations, legitimate business interests, protection of vital interests, or any other lawful ground permitted under applicable data protection laws.

8. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to enhance user experience and analyze website usage and improve functionality. Users may disable cookies in their browser settings; however, some features may not function properly.

Cookies may be:

• Session cookies (temporary)
• Persistent cookies
• First-party cookies
• Third-party analytics cookies

You may manage or disable cookies through your browser settings; however, this may affect website functionality.

9. Disclosure of Personal Data

We may share personal data with:

• Clients seeking recruitment or consulting services
• Training partners and facilitators
• Background verification providers
• IT and cloud service providers
• Legal or regulatory authorities
• Professional advisers
• Payment processors

Axis ensures that all third parties receiving personal data enter into appropriate data processing or confidentiality agreements requiring them to maintain adequate security and confidentiality measures.

10. International Data Transfers

Where necessary, personal data may be transferred outside Ghana for service delivery or storage. In such cases, Axis ensures appropriate safeguards are in place to protect the data in accordance with applicable laws, including contractual safeguards, data processing agreements, or transfers to jurisdictions recognized as providing adequate levels of data protection.

11. Data Security

Axis implements technical and organizational safeguards, including:

• Restricted and role-based access controls
• Secure data storage systems
• Confidentiality obligations for employees
• Encryption and secure backups
• Regular security reviews and training

Despite these measures, no system can guarantee absolute security.

12. Data Retention

Axis retains personal data only for as long as necessary to fulfill the purposes for which it was collected, to comply with legal, regulatory, tax, and contractual obligations, or to resolve disputes.

Retention periods may vary depending on the nature of the data and the purpose of processing. In general:

• Recruitment candidate data (including CVs, assessments, and interview records): retained for up to five (5) years from the date of last interaction, unless earlier deletion is requested or required by law.
• Client engagement records (including contracts, invoices, and project documentation): retained for up to seven (7) years in line with financial and tax record requirements.
• Training records and certifications (including attendance logs, assessment results, and issued certificates): retained for up to five (5) years, or longer where verification services are required.
• Employee records: retained in accordance with employment laws and statutory requirements.
• Website analytics data: retained for a limited period consistent with analytics provider settings.

Upon completion of engagements:

• Data may be securely archived in accordance with Axis’ internal retention policies.
• Personal data will be securely deleted, anonymized, or destroyed once it is no longer required, subject to legal or regulatory obligations.

Axis periodically reviews retained data to ensure it remains necessary, relevant, and proportionate.

13. Data Subject Rights

Individuals have the right to:

• Request access to their personal data
• Request correction of inaccurate data or updates
• Request deletion where applicable
• Withdraw consent
• Object to certain processing activities
• Request data portability (where applicable)
• Lodge complaints with Axis and, where necessary, escalate complaints to the Data Protection Commission of Ghana.
• Request restriction of processing where applicable. 

Requests may be submitted using the contact details below. Axis will respond to requests within a reasonable timeframe in accordance with applicable law.

14. Data Breach Notification

In the event of a data breach likely to affect individuals’ rights or freedoms, Axis will:

• Investigate promptly
• Notify affected clients and regulators within a reasonable timeframe and in accordance with applicable legal requirements 
• Take corrective measures to prevent recurrence

15. Children Privacy

We do not knowingly collect or process personal data relating to minors without appropriate authorization. Where personal data of minors is collected or processed, we ensure that valid consent is obtained from the minor’s parent, guardian, or legally authorized representative, in accordance with applicable laws and regulatory requirements. We are committed to safeguarding the privacy and rights of minors at all times. 

16. Changes to this Policy

Axis reserves the right to update this Policy periodically. Any changes will be published on our website with the updated effective date.

17. Contact Information

For questions, requests, or concerns regarding this Privacy Policy or your personal data, please contact:

Data Protection Officer / Supervisor
Axis Human Capital Limited
Email:data@axishcl.com || info@axishcl.com
Phone No: +233 (0)25 795 8110 || +233 (0)25 795 8099

Physical Address: #57 Norley Rd, North Dzorwulu, Accra (Behind fiesta Royale Hotel)