Internal Reporting Policy for Users

The platform is implementing a simple, accessible, traceable, and multi-channel reporting system, inspired by best practices in responsiveness, referral to the appropriate agencies, and follow-up on cases. Recent public digital reporting systems in Benin demonstrate the value of a multimodal system featuring a web interface, an app, messaging, and internal follow-up.

Purpose

Enable any user to quickly report content, behavior, an offer, a business, an account, or data usage that is potentially illegal, misleading, abusive, or in violation of the platform's rules.

Reporting Channels

  • Online form: Click here,
  • Dedicated email address: dpo@job229.com
  • Offline channels or telephone support, as appropriate, to improve accessibility.

Eligible Categories

  • fraudulent offer;
  • identity theft;
  • discrimination in an offer or exchange;
  • attempted fraud or a request for an unjustified payment;
  • unauthorized data collection;
  • unauthorized disclosure of personal data;
  • fake recruiter profile;
  • harassment, threats, or illegal content;
  • security breach or unauthorized access;
  • Appeal of a moderation or suspension.

Minimum Required Information

  • the reporter's name or username;
  • contact information;
  • subject of the report;
  • link, screenshot, or reference;
  • description of the facts;
  • approximate date;
  • supporting documents;
  • privacy settings;
  • declaration of good faith.

Treatment Process

Step 1 – Receipt and Acknowledg
Every report is assigned a case number and receives an automated or manual acknowledgment of receipt within a target timeframe of 24 to 72 business hours.

Step 2 – Case Classification
The Reports Unit classifies the case: security, fraud, personal data, illegal content, discrimination, contractual dispute, technical error, or user abuse.

Step 3 – Precautionary Measures
Depending on the severity: account freeze, temporary removal of content, messaging restrictions, suspension of the service, preservation of logs, escalation to the compliance, security, or legal department.

Step 4 – Adversarial Proceedings
Unless required for security or investigative purposes, the person or entity in question is invited to submit their comments within a specified time frame. This step promotes transparency and fair treatment.

Step 5 – Decision
The platform issues a reasoned decision: classification, request for additional information, removal of content, warning, suspension, amicable resolution, referral to the competent authority, or initiation of an appeal process.

Step 6 – Notification and Archiving
The decision is notified to the declarant and, if applicable, to the person concerned. The file is archived along with the processing log.

Target Deadlines

  • Confirmation of receipt: within 72 business hours.
  • Initial certification: 5 business days.
  • Standard processing time: 15 business days.
  • Complex case: 30 business days, with interim updates.
  • Critical security/fraud incident: immediate priority handling.

Warranties

  • confidentiality of the reporting party;
  • prohibition of retaliation;
  • processing in good faith;
  • traceability;
  • preservation of evidence;
  • impartiality;
  • protection of the parties' data.

Report Form

Title:User Report Form

  • Last name / first name or username:
  • Email / Phone:
  • You are: a candidate / a recruiter / a visitor / a partner
  • Type of report:
  • URL or reference:
  • Detailed description:
  • Date of the incident:
  • Attachments:
  • Would you like to keep your identity confidential from the reported party? Yes/No
  • Statement: “I certify that I am reporting these facts in good faith and providing accurate information to the best of my knowledge.”
  • Electronic signature / validation:
  • Date:

Dispute

3-Step Written Appeal Process

The platform establishes a three-step process: informal complaint resolution, mediation, and appeal. This approach is consistent with best practices in complaint management and with Benin’s recognized interest in alternative dispute resolution methods, particularly mediation, which is valued for its confidentiality, flexibility, speed, and lower costs.

Field

The procedure applies, in particular, to the following cases:

  • account deletion;
  • refusal to publish an offer;
  • removal of content;
  • closure or restriction of access;
  • objection to data processing;
  • refusal or failure to adequately respond to a request to exercise rights;
  • dispute regarding an alert;
  • Contractual dispute related to the service.

Step 1 – Informal Claim

Subject
: To facilitate a prompt and documented resolution with the appropriate department before any escalation.

Submission
The complaint should be sent to dpo@job229.com or via the form…. It must include: your name, the subject of the complaint, the facts, supporting documents, a specific request, and the case number, if applicable.

Confirmation of Receipt
The platform will confirm receipt within a maximum of 3 business days.

Instruction
The competent department reviews the facts, consults the relevant records and documents, and may request additional information.

Response
A detailed response is provided within a target timeframe of 15 business days, which may be extended once by 15 days in complex cases, with the complainant being notified.

Possible outcomes

transfer to mediation.

immediate correction;

reasoned denial;

settlement proposal;

reopening of the case;

Any user who believes that a decision, processing activity, or content concerning them infringes upon their rights may file a preliminary informal complaint. The platform is committed to reviewing it diligently, impartially, and in a transparent manner.

Step 2 – Mediation


Principle In the absence of an amicable resolution, the parties are encouraged to seek mediation—whether internal or external—before initiating any formal proceedings, except in cases of emergency, serious violation, or where otherwise required by law. Mediation is encouraged as a confidential, flexible, and expeditious means of dispute resolution.

Selection of the Mediator

  • an internal mediator who is separate from the team that handled the complaint; or
  • an external mediator agreed upon by the parties; or
  • the appropriate mediation or conciliation center, if applicable.

Procedure

  • written consent of the parties;
  • submission of a summary report;
  • remote or in-person session;
  • proposed solution within 15 to 30 days;
  • Memorandum of Understanding signed if an agreement is reached.


Effects: Mediation suspends non-urgent internal escalations for the duration of the process, except for interim measures related to security or compliance. If the amicable resolution of the complaint fails, the parties agree to prioritize seeking a negotiated solution through mediation, in a spirit of confidentiality, procedural fairness, and expediency.

Step 3 – Appeals


Principle If mediation fails or no agreement is reached, the user may seek redress depending on the nature of the dispute. For data protection issues, the data subject may file a complaint with the APDP, which handles complaints and grievances regarding the collection and processing of personal data.

Possible paths

  • final internal appeal to the Compliance Officer or senior management;
  • referral to the APDP for disputes related to personal data;
  • referral to the competent public authority or agency, depending on the matter;
  • a lawsuit before the competent court, in accordance with applicable law.

Recommended internal deadline
The final internal appeal must be filed within 30 days of the mediation decision or the determination that mediation has failed. If no agreement is reached during mediation, the user may file a final internal appeal and then, depending on the nature of the dispute, refer the matter to the APDP or any competent court. External remedies remain available in accordance with applicable law.

Internal Non-Discrimination Policy

The platform prohibits any discriminatory job postings, messages, filters, or practices that violate the law, recruitment ethics, or internal rules. The moderation teams are trained to identify potentially problematic language and to require that it be corrected before publication.

Recruiter Verification

The platform implements proportionate screening of recruiters to reduce fake accounts, scams, and identity theft. Data minimization remains in effect, so that only the evidence necessary for verification is requested.

Possible parts

proof of authorization, if necessary.

representative's identity;

commercial register or equivalent document;

business address;

professional email domain;

Transparency in Moderation Decisions

Any significant adverse decision taken against a user must be supported by a clear and understandable explanation, unless otherwise required by law or for security reasons. The notification must specify, at a minimum, the nature of the action, the general reason for it, the effective date, and the available appeal process.

Relations with the APDP

The platform retains evidence of its compliance and cooperates with the APDP in the event of an audit, request for information, complaint, or preliminary procedure. The APDP is the competent authority in Benin for receiving requests, formalities, claims, petitions, and complaints relating to personal data.

Training and Awareness

All employees receive initial training upon hire, followed by an annual refresher course on:

  • data protection principles;
  • confidentiality;
  • reports;
  • digital security;
  • managing user requests;
  • the steps toward compliance.

Audit and Continuous Improvement

An internal compliance audit is conducted at least once a year. It covers the registry, disclosure statements, retention periods, security, subcontractors, reporting statistics, and the quality of responses to complaints.

Internal Sanctions

Any violation of this manual may result in:

  • reminder;
  • revocation of access;
  • mandatory remedial training;
  • disciplinary action;
  • termination of the service provider's contract;
  • reporting to the appropriate authority if necessary.

Referral to the APDP

Without prejudice to the internal remedies provided for in this procedure, any affected individual may file a complaint with the Personal Data Protection Authority (APDP) regarding the collection or processing of their personal data.

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