POPIA and employee wellness data: what HR is allowed to see

The Protection of Personal Information Act treats health information as special personal information. You need a lawful basis, and for this kind of data that usually means explicit consent. “They work here” is not consent.

Collect less. A mood pulse does not need an ID number, a diagnosis, or a free-text box that invites a life story. If you do not need it, do not store it.

Separate the streams. Learning progress (who finished a course) is ordinary workplace administration. How someone felt on Thursday is not something a line manager gets to browse.

Aggregate before you report. HealthCafé hides pulse trends when the group is smaller than five, so a team of three cannot be reverse-engineered. Do not export the raw file “just in case”.

Tell people, in language they will read, what you collect, who sees it, and how to withdraw. Put that on the sign-up screen, not only in a policy nobody opens.

This article is a practical orientation, not legal advice. Your information officer should read the actual processing you do.