(This policy pertains to clients and other external data subjects of Remgro Limited, its services company, Remgro Management Services Limited (RMS) and RMS administered companies, hereinafter collectively referred to as “Remgro” or “We“)
WHAT IS THE PURPOSE OF THIS DOCUMENT?
|Remgro is committed to protecting the privacy and security of your personal information.
|Remgro is a “responsible party”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
|This notice applies to current and former clients, directors and independent contractors of Remgro (“Data Subjects”). We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practical.
|It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under POPIA.
|This policy should be read with our PAIA manual and any contract(s) we may have with you from time to time. Our PAIA manual is published on our website at www.remgro.com/paia/ or available on request from our Information Officer.
DATA PROTECTION CONDITIONS
|We will comply with POPIA. This says that the personal information we hold about you must be:
THE KIND OF INFORMATION WE HOLD ABOUT YOU
|Personal data, or personal information, means any information about an individual or a juristic person from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
|There are certain types of more sensitive or special personal data which require a higher level of protection, such as information about a person’s health or sexual orientation. Information about criminal convictions also warrants this higher level of protection.
|Depending on how you access and use websites, we may receive:
|We may receive additional information about you that is publicly or commercially available and combine that with the information we have collected or received about you in other ways.
|For a comprehensive list of personal information we may collect, store, and use about you, please refer to our PAIA manual.
HOW IS YOUR PERSONAL INFORMATION COLLECTED?
|We collect personal information about Data Subjects directly from such data subject. We may sometimes collect additional information from third parties, including former employers, credit reference agencies or bureaus or other background check agencies.
|We may also collect personal information from the trustees or managers of pension arrangements.
|We may collect information when you use websites by using cookies, web beacons and other technologies.
HOW WE WILL USE INFORMATION ABOUT YOU?
|We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
|Situations in which we will use your personal information
|We need all the categories of information in the list above primarily to allow us to perform/execute our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests, provided your interests and fundamental rights do not override those interests. Examples of specific situations in which we will process your personal information are listed below:
|Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
|If you fail to provide personal information
|If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure we comply with FICA requirements).
|Change of purpose
|We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
|Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION?
|“Special categories” of particularly sensitive personal information, such as information about your health, racial or ethnic origin, sexual orientation or trade union membership, require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:
|Less commonly, we may process this type of information where you have already made the information public.
|Situations in which we will use your special personal information
|In general, we will not process particularly sensitive personal information about you unless it is necessary for performing or exercising obligations or rights in connection with law or our contract with you.
|Do we need your consent?
|We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in terms of law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive personal information. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
|Information about criminal convictions
|We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so.
|Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
|You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
|We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
|We may have to share your data with third parties, including third-party service providers and other entities in the group. If we do, you can expect a similar degree of protection in respect of your personal information.
|We require third parties to respect the security of your data and to treat it in accordance with the law.
|Why might you share my personal information with third parties?
|We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
|Which third-party service providers process my personal information?
|“Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group.
Depending on the nature of the personal information, Remgro may supply information or records to the following categories of recipients:
|How secure is my information with third-party service providers and other entities in our group?
|We will share your personal information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data.
|Transferring information outside South Africa
|We might transfer your personal information to places outside of South Africa and store it there, where our suppliers might process it. If that happens, your personal information will only be transferred to and stored in a country that has equivalent, or better, data protection legislation than South Africa or with a service provider which is subject to an agreement requiring it to comply with data protection requirements equivalent or better than those applicable in South Africa.
|We have put in place measures to protect the security of your information.
|Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
|We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those Data Subjects, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from the RMS Information Officer.
|We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
|We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available in our retention schedule which is available from our Information Officer. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
|In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a client, director or independent contractor of the company we will retain and securely destroy your personal information in accordance with our data retention schedule and/or applicable laws and regulations.
RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
|Your duty to inform us of changes: it is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
|Your rights in connection with personal information: under certain circumstances, by law you have the right to:
|If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our Information Officer in writing or consult our PAIA manual available on our website.
|No fee usually required: you will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
|What we may need from you: We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
|Right to withdraw consent
|In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Information Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
|What are cookies and why do we use them?
The type of information collected by the cookies we use is not used to personally identify you.
|What kind of cookies do we use?
|We use the following categories of cookies:
Category 1: necessary cookies
Category 2: performance cookies
|How we manage cookies
|We don’t store cookie information. As soon as you log out of your browser session, these cookies are deleted.
|The Remgro website uses necessary, performance and functionality cookies only. We don’t store cookie information. As soon as you log out of your browser session, these cookies are deleted.
We only store personal data in e-mail format when you contact us via the website. We want to make sure that any data we hold about you is up to date. So, if you made contact with us via the website and think your personal information is inaccurate, you can ask us to correct or remove it.
|Links to other websites
|Our website may contain links to and from websites, mobile applications or services of third parties, advertisers or affiliates. Please note that we are not responsible for the privacy practices of such other parties and advise you to read the privacy statements of each website you visit which collects personal information.
|We have appointed an Information Officer to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Information Officer. You have the right to make a complaint at any time to the Information Regulator.
CONTACT DETAILS OF THE INFORMATION REGULATOR
CONTACT DETAILS OF THE INFORMATION OFFICER (IO)
|We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.