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Privacy Notice
Contents
1. Organisation Details (‘we’ or ‘us)
Full name: [company name]
Registration number: [company registration number]
Physical address: [physical address]
Postal address: [postal address]
Directors: [Director initial and surname]
Phone number: [phone number]
Email address: [email address]
Information Officer
Full name: [information officer name]
Role in organisation: [role in company other than information officer]
Physical address: [physical address]
Postal address: [postal address]
Phone number: [phone number]
Email address: [email address]
Deputy Information Officer
Full name: [deputy information officer name]
Role in organisation: [role in company other than deputy information officer]
Physical address: [physical address]
Postal address: [postal address]
Phone number: [phone number]
Email address: [email address]
2. Introduction
This Privacy Notice deals with data protection and the Protection of Personal Information Act (“POPIA”), which comes into force on the 1st July 2021. The aim of POPIA is to protect personal information and privacy. This Privacy Notice outlines what we do with personal information and the rights of data subjects.
3. PAIA Manual
We have drafted a PAIA manual, which can be found here: [URL for PAIA manual].
4. Personal Information We Collect and What We Use It For
This list is an example only and depends on the purposes of processing personal information in your company – adapt as required.
Categories of Data SubjectsTypes of Personal Information CollectedSpecial Personal InformationPurposes for Processing Personal InformationRecipients or Categories of Recipients of Personal InformationTrans-border Information FlowNatural Person Customers
Names; contact details; physical and postal addresses; date of birth; ID number; Passport number; Tax-related information; nationality; gender; confidential correspondence
n/a
Concluding contracts, performing in terms of the contract, marketing to customers, debt recovery, compliance with legislation
Internal use for customer management; Data management company
Pseudonymised customer personal information quality managed in Israel
Juristic Person Customers
Names of contact persons; Name of Legal Entity; Physical and Postal address; contact details; Financial information; Registration Number; Founding documents; Tax-related information; authorised signatories; beneficiaries; ultimate beneficial owners.
n/a
Concluding contracts, performing in terms of the contract, marketing to customers, debt recovery, compliance with legislation
Internal use for customer management; Data management company
Pseudonymised customer personal information quality managed in Israel
Employees
Gender; Marital Status; Age; Home Language; Education information; Financial Information; Employment History; ID number; Physical and Postal address; contact details; Opinions.
Ethnicity; Criminal behaviour; Well-being.
Staff administration; Complying with tax laws and other legislation
Internal use; Human resources specialist services (South Africa)
n/a
Suppliers Natural Persons
Names; contact details; physical and postal addresses; date of birth; ID number; Passport number; Tax-related information; nationality; gender; confidential correspondence.
BBBEE status
Staff administration; Procurement of goods
Internal use; Compliance with laws
n/a
Suppliers Juristic Persons
Names of contact persons; Name of Legal Entity; Physical and Postal address; contact details; Financial information; Registration Number; Founding documents; Tax-related information; authorised signatories; beneficiaries; ultimate beneficial owners.
BBBEE status
Staff administration; Procurement of goods
Internal use; Compliance with laws
n/a
5. Children’s Personal Information
Choose the correct statement:
Our products and services are not designed to appeal to children (under the age of 18). As such, the products and services are not directed at children, nor do we knowingly collect or maintain information from children.
We may collect children's personal information from our employees, but only for the purposes of assisting employees with [name purposes] relating to their dependants.
We collect children's personal information for our goods and services. This information is collected for the following purposes: [name purposes].
6. Our Newsletter and Marketing
If you are an existing customer, you might receive our marketing material, provided that you can unsubscribe at any time. If you are a new customer, we will ask for your consent to send you the newsletter.
When you subscribe to receive our newsletter or marketing material, we will ask for the information necessary to process your request. You can unsubscribe from the newsletter at any time by clicking on the link at the bottom of the communication.
Each marketing email we send will contain instructions on how to unsubscribe. Please allow about [10 business days] for your unsubscribe request to be processed. If you opt out of promotional emails, we will still send service messages to enable you to use our services correctly.
7. Third Party Services and Use of Personal Information
If you access any other companies’ or partners’ services from a link on our website, any information you reveal in connection with such service is submitted to that company and is not subject to this Privacy Notice. Consult the privacy notice of the other party regarding their treatment of personal information.
8. Job Seekers
We will use the personal information that job seekers submit and will retain the information for the time required by applicable law or our standard practice, whichever is longer.
We will not release information submitted by online job seekers to third parties except to appropriate governmental entities and/or our service providers as necessary. We require our service providers to keep your personal information confidential.
9. Transferring Personal Information to Third Parties and Overseas
If we transfer your personal information outside of South Africa, we apply necessary safeguards, which include either: [details of safeguards]. Details may be obtained by contacting us directly.
10. How to Update, Correct, Delete and Object to Our Using Your Personal Information
If you are a data subject, you have the right to access personal information, object to its use, and request deletion or correction. Use the forms at the end of this document:
Form 1: Request access to personal information
Form 2: Object to processing of personal information
Form 3: Request to correct, update, or delete personal information
We are required to authenticate you before processing your request, which will vary depending on the sensitivity of your request and our internal security procedures.
11. Business Transfers
In the event our company, or part of it, is bought or sold, your personal information may be included in the business assets, provided that this Privacy Notice or a similar notice will continue to apply.
12. Security Breach
We have an existing security policy and continually update our systems. We have developed procedures to follow in case of a security breach as defined in section 22 of POPIA. We will notify you as soon as possible and inform you of steps you can take to protect yourself.
13. How to Complain to the Information Regulator
Our use of personal information is governed by PAIA and POPIA, and the Information Regulator ensures compliance. Complaints can be lodged with the Information Regulator. Their details are:
Physical address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
Complaints email: POPIAComplaints.IR@justice.gov.za and PAIAComplaints.IR@justice.gov.za
General enquiries email: inforeg@justice.gov.za
Website: https://www.justice.gov.za/inforeg/index.html
14. Changes to This Privacy Notice
We may change this Privacy Notice from time to time by posting a new version here, effective from the date set out in the new Privacy Notice.
15. Form 1: Request for Access to a Record in Terms of PAIA
Request for access to a record of private body (Section 53 (1) of the Promotion of Access to Information Act, 2000)
A. Details of Responsible Party
Deputy Privacy & Information Officer: [company information officer]
Deputy I/O Chief Officer: [company deputy information officer]
Physical address: [company address]
Telephone number: [company telephone number]
Email address: [company email address]
B. Particulars of Person Requesting Access
Full names and surname: _______________________________________________________
Identity number: __________________________________________________________________
Postal address:___________________________________________________________________
Fax number: ______________________________________________________________________
Telephone number: __