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Privacy Policy

1. INTRODUCTION
1.1 By virtue of the Company’s business, it naturally from time to time comes into possession of various items of personal information.

1.2 The Company undertakes to ensure that to ensure that its employees, directors, affiliates, partners and/or clients adhere to the strictest levels of confidentiality and respect individual’s right of privacy.
2. ACCOUNTABILITY
2.1 To the extent that the Company gathers personal information which it provides to a third party contracted to it, the Company acts in the capacity of an Operator as is defined in the Act.

2.2 To the extent that the Company can be considered to be the party processing personal information, it shall be acting in the capacity of being a Responsible Party in terms of the Act.

2.3 The Company shall at all material times comply with its obligations in terms of the Act depending on its capacity in which it is acting in the circumstances.

2.4 Should the Company process or store any personal information, it confirms that the processing or storage thereof shall be for the specific reason which it was processed or stored, which it deems to be adequate and relevant, and not excessive.

2.5 The Company shall record all personal information processed and maintain same to the extend required in terms of the law (as may be amended from time to time).
3. PURPOSE
3.1 The purpose of this policy is to outline the Company’s approach to the storage and processing of personal information in like with the Act. In this regard, the Company:

3.1.1 Strives to process personal information lawfully and reasonably, and without infringing on the privacy of the owner of the personal information;

3.1.2 Strives to ensure the protection of personal information and constitutional rights;

3.1.3 Shall establish conditions in accordance with applicable laws that prescribe minimum threshold requirements for the lawful processing and storage of personal information;

3.1.4 Comply with voluntary and compulsory measures, including those established by the Regulator in order to promote the protection of personal information rights;

3.1.5 Shall only use personal information collected for the purpose of which it was collected;

3.1.6 Shall not release data to the media or general public unless required to do so by law.
4. STORAGE OF DATA
4.1 All personal information received by the Company shall be stored, only where the Company in its opinion is of the view that it requires to store such personal information for the purpose of which it was collected.

4.2 All personal information stored by the Company shall be on-site and/or on the Company’s secure servers (whether hosted by the Company or a trusted third party) and secured using the Company’s reasonable measures and encryption.

4.3 Personal information will be retained for the period required by the Company and/or for the period required by law.

4.4 The Company may store data for a longer period of time should it be of the view that personal information may be required in the future for a specific purpose. Appropriate safeguards will be put in place in terms of the Act should the need arise.

4.5 Should the Company delete, erase or destroy data, such deletion/erasure/destruction shall be permanent.

4.6 Only specific, vetted, persons within the Company shall:

4.6.1 have the ability to access and review personal information provided on a “need to know basis”;

4.6.2 be entitled to share or distribute the personal information for its specific purpose or as may be required by law.

4.7 The persons within the Company who have access to personal information shall be bound by the Company’s confidentiality undertakings.

4.8 The Company will use its reasonably best endeavours to ensure that service providers it uses are trusted and reputable.
5. UNLAWFUL DISCLOSURE OF PERSONAL INFORMATION
5.1 Any unlawful or unintended disclosure of personal information or breach of the Act shall be immediately reported to the Regulator and dealt with in terms of the Act.

5.2 Affected persons shall be notified within a reasonable time after the Company has undertaken its own internal (and where necessary, external) investigations.
7. INFORMATION REGULATOR
7.1 In terms of the Act, the Information Regulator has been established and will be endowed with various power and authority once the Act is in effect.

7.2 The Information Regulator will, amongst other things, seek to provide education on the collection and use of personal information, monitor and enforce compliance with the Act, handle complaints, conduct research, assist with the preparation of sectoral codes of conduct and generally assist with the implementation of the Act and assist the general public on information related issues, where required

7.3 Any complaint in respect of any personal information processed by the Company and/or its related security companies may be referred to the Information Regulator in writing at inforeg@justice.gov.za
Additional information can be viewed at http://justice.gov.za/inforeg
6. PERSONS WISHING TO ACCESS PERSONAL INFORMATION
6.1 In the event that a third party wishes to access personal information stored by the Company, the third party shall request access in writing to the Company, who will act in accordance with the Act at all times.

6.2 If the Company cannot comply with the third party’s request, it shall provide written reasons where possible.

6.3 As a general rule, the Company will only disclose third party information where compelled by law (including the Promotion of Access to Information Act) or by court-authorised subpoena.
8. SEVERABILITY
Any clause which does not comply with legislation shall be considered as pro non scripto in so far that it cannot be rectified to comply with legislation.