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POPI Policy

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1. POLICY STATEMENT:

Global Digital Freight Surveyors (PTY) LTD processes personal information of its, employees, members, clients, and other data subjects from time to time. As such, it is obliged to comply with the Protection of Personal Information Act No. 4 of 2013 (“POPI”) as well as the Promotion of Access to Information Act No. 2 of 2000 (“PAIA”).

In line with this, Global Digital Freight Surveyors (PTY) LTD is committed to protecting its employees/members’/clients’/supplier’s/volunteers’ and other data subjects’ privacy and ensuring that their personal information is used appropriately, transparently, securely, and in accordance with applicable laws.

This Policy sets out the way Global Digital Freight Surveyors (PTY) LTD deals with such personal information and provides clarity on the general purpose for which the information is used, as well as how data subjects can participate in this process in relation to their personal information.

2. OBJECTIVES:

To ensure legislative compliance (POPI and PAIA Acts) in respect of all personal information that Global Digital Freight Surveyors (PTY) LTD collects and processes.

  • To inform clients as to how their personal information is used, disclosed, and destroyed.
  • To ensure that personal information is only used for the purpose for which it was collected.
  • To prevent unauthorized access and use of personal information.

3. COLLECTION OF PERSONAL INFORMATION:

Global Digital Freight Surveyors (PTY) LTD processes various information pertaining to its employees, members, clients, and suppliers. The information collected is based on need and it will be processed for that need/purpose only. Whenever possible, we will inform the relevant party of the information required (mandatory) and which information is deemed optional. (Voluntary)

The employees, members, or clients will be informed of the consequence/s of failing to provide such personal information and any prejudice which may be incurred due to non-disclosure. For example, Global Digital Freight Surveyors (PTY) LTD may not be able to employ or accept a volunteer, employee, member, or client without certain personal information relating to that individual or the organization may not be in a position to render services to a client in the absence of certain information which is required.

Global Digital Freight Surveyors (PTY) LTD will process information in a manner that is lawful and reasonable (i.e., will not infringe the privacy of the individual or company).

  • Where consent is required for the processing of information, such consent will be obtained.
  • Information will be processed under the following circumstances.
  • When carrying out actions for the conclusion or performance of a contract
  • When complying with an obligation imposed by law on the company
  • For the protection of a legitimate interest of the data subject
  • Where necessary, for pursuing the legitimate interests of the company or of an authorized third party to whom the information is supplied.

Examples of the personal information Global Digital Freight Surveyors (PTY) LTD collects includes, but is not limited to Information relating to the:

  • race,
  • gender
  • pregnancy
  • marital status
  • age
  • physical or mental health
  • well-being
  • disability
  • religion
  • culture
  • language of a volunteer.
  • Banking and account information.
  • Contact information.
  • Any identifying number, symbol, email address, telephone number, location information, online identifier, or another particular assignment to the volunteer, member, or client
  • The biometric information of the volunteer, member, client, or data subject
  • Global Digital Freight Surveyors (PTY) LTD shall not process special personal information without complying with the specific provisions of the POPI Act. Special information includes personal information concerning:
  • the religious or philosophical beliefs, race or ethnic origin, trade union membership, political persuasion, health, sex life, or biometric information of a data subject; or
  • the criminal behavior of a data subject, where such information relates to the alleged commission by a data subject of any offense committed or the disposal of such proceedings.

4. COLLECTION OF INFORMATION (Employee/ Member / Client/Supplier):

For purposes of this Policy, clients include potential, past, and existing members and clients. Suppliers include all vendors which contract with Global Digital Freight Surveyors (PTY) LTD whether once off or recurring, in respect of products and services. Global Digital Freight Surveyors (PTY) LTD collects and processes its members’, clients’, and suppliers’ personal information, such as that mentioned hereunder.

The type of information will depend on the need for which it is collected and will be processed for that purpose only. Further examples of personal information collected from clients include, but is not limited to:

  • The member/client/supplier’s identity number, name, surname, address, postal code
  • The member/client/supplier’s residential and postal address
  • Contact information
  • Banking details
  • Company registration number
  • Full name of the legal entity
  • Tax and/or VAT number
  • Global Digital Freight Surveyors (PTY) LTD also collects and processes member/clients’ personal information for marketing purposes in order to ensure that its products and services remain relevant to our clients and potential clients.

The member/client/supplier’s personal information will only be used for the purpose for which it was collected and as agreed. This may include, but not be limited to:

  • Providing products or services to members/clients
  • In connection with sending accounts and communication to a member/client in respect of services rendered.
  • Payment of suppliers and communication in respect of services rendered.
  • Referral to other service providers
  • Confirming, verifying, and updating member/client/supplier details
  • Conducting market or customer satisfaction research
  • For audit and record-keeping purposes
  • In connection with legal proceedings
  • In connection with and to comply with legal and regulatory requirements or when it is otherwise allowed by law.
  • Disclosure of personal information
  • Global Digital Freight Surveyors (PTY) LTD may share member/clients/suppliers’ personal information with authorized third parties as well as obtain information from such third parties for reasons set out above.
  • Global Digital Freight Surveyors (PTY) LTD may also disclose member/clients/suppliers’ information where there is a duty or a right to disclose in terms of applicable legislation, the law or where it may be necessary to protect the rights of the organization, or it is in the interests of the data subject.

5. SAFEGUARDING OF PERSONAL INFORMATION AND CONSENT:

Global Digital Freight Surveyors (PTY) LTD shall review its security controls and processes on a regular basis to ensure that personal information is secure. It will take appropriate, reasonable technical and organizational measures to prevent loss or damage or unauthorized destruction of personal information, and unlawful access to or processing of personal information.

This will be achieved by:

  • Identifying internal and external risks
  • Establishing and maintaining appropriate safeguards
  • Regularly verifying these safeguards and their implementation
  • Updating the safeguards
  • Implementing generally accepted information security practices and procedures.
  • Global Digital Freight Surveyors (PTY) LTD has appointed an Information Officer who is responsible for compliance with the conditions of the lawful processing of personal information and other provisions of POPI.

Information Officer details:

Name: Albert Venter
Email address: albert@globaldfs.com

The development, implementation, monitoring, and maintenance of a compliance framework.
undertaking of a personal information impact assessment to ensure that adequate measures and standards exist in order to comply with the conditions for the lawful processing of personal information.
The development, monitoring, and maintenance of a manual, as well as the making available thereof, as prescribed in section 51 of the Promotion of Access to Information Act, 2000 (Act No. 2 of 2000)
The development of internal measures, together with adequate systems to process requests for information or access thereto and
To ensure that compliance awareness sessions are conducted regarding the provisions of the Act, regulations made in terms of the Act, codes of conduct, or information obtained from the Regulator.
On an ongoing basis, all suppliers, insurers, and other third-party service providers are required to sign a service level agreement guaranteeing their commitment to the Protection of Personal Information.
Consent to process client/member/supplier information is obtained from clients/members/suppliers (or a person who has been given authorization from the client/member to provide the member/client’s personal information) and suppliers at sign-on/appointment/contracting.

6. DIRECT MARKETING:

Global Digital Freight Surveyors (PTY) LTD shall ensure that:
It does not process any personal information for the purpose of direct marketing (by means of any form of electronic communication, including automatic calling machines, SMS’s or e-mail) unless the data subject has given his, her or its consent to the processing or is an existing customer who has completed a continuous consent form.
It will only approach data subjects, whose consent is required and who have not previously withheld such consent, once in order to request the consent. This will be done in the prescribed manner and form.

The data subjects will only be approached for the purpose of direct marketing of Global Digital Freight Surveyors (PTY) LTD own similar products or services. In all instances, the data subject shall be given a reasonable opportunity to object, free of charge and in a manner free of unnecessary formality, to such use of his, her, or its electronic details at the time when the information is collected.
Any communication for the purpose of direct marketing will contain details of the identity of the sender or the person on whose behalf the communication has been sent and an address or other contact details to which the recipient may send a request that such communications cease.

7. TRANSFER OF INFORMATION OUTSIDE OF SOUTH AFRICA

Global Digital Freight Surveyors (PTY) LTD does not send any data outside of the Republic of South Africa.

8. SECURITY BREACHES

Should the Global Digital Freight Surveyors (PTY) LTD detect a security breach on any of its systems that contain personal information, it shall take the required steps to assess the nature and extent of the breach in order to ascertain if any information has been compromised. Global Digital Freight Surveyors (PTY) LTD shall notify the affected parties should it have reason to believe that their information has been compromised. Such notification shall only be made where the organization can identify the data subject to which the information relates. Where it is not possible it may be necessary to consider website publication and any other measure the Information Regulator prescribes.

Notification will be provided in writing by means of either:

  • email
  • registered mail
  • the organization’s website

The notification shall provide the following information where possible:

  • Description of possible consequences of the breach.
  • Measures are taken to address the breach.
  • Recommendations to be taken by the data subject to mitigate adverse effects.
  • The identity of the party responsible for the breach if it is available.
  • In addition to the above, Global Digital Freight Surveyors (PTY) LTD shall notify the Regulator of any breach and/or compromise to personal information in its possession and work closely with and comply with any recommendations issued by the Regulator.

The following will apply in this regard:

  • The Information Officer will be responsible for overseeing the investigation.
  • The Information Officer will be responsible for reporting to the Information Regulator within 72hrs of becoming aware of the breach/ compromise to personal information.
  • The Information Officer will be responsible for reporting to the Data Subject(s) within 72hrs, as far as is reasonable and practicable, of a breach/ compromise to personal information.
  • The timeframes above are guidelines and depending on the merits of the situation may require earlier or later reporting.

9. ACCESS AND CORRECTION OF PERSONAL INFORMATION:

Employees, Members, and clients have the right to request access to any personal information that Global Digital Freight Surveyors (PTY) LTD holds about them. Volunteers, Members, and clients have the right to request that Global Digital Freight Surveyors (PTY) LTD update, correct or delete their personal information on reasonable grounds. Such requests must be made to the Information Officer (see details above) Where an employee, member, or client objects to the processing of their personal information Global Digital Freight Surveyors (PTY) LTD may no longer process said personal information. Unless there is a legal requirement for Global Digital Freight Surveyors (PTY) LTD to continue processing said information. The consequences of the failure to give consent to process the personal information must be set out before the client confirms his/her objection. The member or client or employee must provide reasons for the objection to the processing of his/her personal information to the Information Officer in writing ( see details above)

10. AMENDMENTS TO THIS POLICY:

Amendments to this Policy will take place from time to time subject to the discretion of Global Digital Freight Surveyors (PTY) LTD and pursuant to any changes in the law. Such changes will be brought to the attention of employees, members, and clients where it affects them.