Data Protection and Privacy Policy

 

Company Overview

 

The coming into effect of the Protection of Personal Information Act No. 4 of 2013 (referred to as “POPIA”) on 1 July 2020, known as POPIA, sets conditions for how information can be processed. POPIA aims to ensure that Personal Information is processed in line with internationally accepted data protection principles. One’s privacy is also governed by the PAIA (Promotion of Access to Information Act). This Privacy Policy is in terms of both POPIA and PAIA.

 

POPIA is intended to protect both natural and juristic persons (Data Subjects) from harm by protecting their personal information. POPIA ensures that all websites, companies, and organisations (Responsible Parties) that hold, and process personal information do so carefully and with respect for the rights and interests of the data subjects.

 

This Privacy Policy of Select PPE and its group of companies regulates how we collect and use the information that we have about all our customers, suppliers and employees and your rights in this regard. Your right to privacy is important to us and therefore, we set out to treat your personal information as private and confidential. We are committed to taking steps to protect your privacy when you use our website, services and/or materials provided by us, and we apply business practices that comply with the POPIA. In this Privacy Policy, we explain how we will use and protect your Personal Information in terms of Applicable Law.

 

Select PPE and its group of companies obtains personal information of external stakeholders while performing its services. The introduction of the Protection of Personal Information Act (POPIA) set out conditions on how personal information should processed and Select PPE has updated its data protection and privacy policy.

 

Purpose of processing personal information

 

Select PPE and its group of companies is committed to processing personal information in a lawful, relevant and transparent manner. Accordingly, we process personal information for purposes relating to our relationship and subsequent agreement with external stakeholders, where applicable. This includes the following:

 

• Contractual agreement and performance management consisting of the following:
  • Issuing Personal Protective Equipment (PPE) to employees of the client and its related group of companies; and/or
  • Invoicing a client and its related group of companies for PPE issued; and/or
  • Employee management report and other related reporting matters to a client and its group of companies.
• Internal and/or external audit review and assurance; and
• Regulatory Reporting as required by applicable law.

 

Select PPE and its group of companies is required to inform you about the grounds under the applicable law that permit us to process your personal data. Those grounds are:

 

• Processing as it relates to and is necessitated by the performance of a contract with a client and related group of companies; and
• Processing for compliance with legal or regulatory obligations to which Select PPE and its group of companies is subject; and
• The processing is necessary to carry out our obligation under the contractual agreement; and/or
• In some limited case, where we have obtained your prior consent.

 

To the extent that we process any sensitive personal information relating to a client, its employees and related group of companies for any of the purposes outlined above, we will do so because either:

• you have given us your explicit consent to process that information; and/or
• the processing is necessary for reasons of substantial public interest on the basis of applicable law; and/or
• the processing is necessary to carry out our contractual obligations; and/or

• the processing is necessary for the establishment, exercise or defence of legal claims; or you have made the information manifestly public.

 

Manner of processing personal information

 

Select PPE and its group of companies takes its obligations with regards to data protection and the privacy of all our stakeholders extremely seriously. Protecting their personal data has and will always be important to Select PPE and its group of companies.

 

We are committed to being transparent about how we process (which includes to collect, receive, process, migrate, record, organise, collate, store, update, modify, retrieve, alter, consult, use, disseminate, transmit, distribute, merge, link, block, degrade, erase, destroy and/or transfer) the personal information of stakeholders, and to ensure that we act lawfully in processing this personal information.

 

Personal data means any information that Select PPE and its group of companies processes, which relates to external stakeholders, its employees and related group of companies (where applicable) and is identifiable as your personal data. Such range of information is listed below:

• Employee of clients
  • Employee Surname
  • Employee Initials
  • Employee ID or Passport number
  • Operations
  • Industry Number
  • Employee Type
  • Designation
  • HiTag Number (where applicable)
  • MiFare Number (where applicable)
  • RF Number (where applicable)
  • Omega Number, or similar no.: (where applicable)
  • Environment
  • Organisation Unit
  • Shaft
  • Department
  • Unit
  • Section
  • Gender
  • Previous Payroll Numbers
  • Cost Centre
  • Employee work Contract detail (where applicable)

 

• Clients and its group of companies
  • Company Name
  • Company Registration Number
  • Company Address
  • Company VAT Number
  • Company Banking details
  • Company email address
  • Company website/web address
  • Company logo
  • Company Fax Number
  • Company Telephone Number

 

• Cookies

Cookies are small files about browsing activity that are stored on a device’s web browser by the websites that are visited and are generally used to improve user experience.

• When you use our website, we automatically receive and record information on our server logs from your browser, such as your location, IP address, general internet usage and Google Analytics information. This is statistical data about browsing actions and patterns.
• Cookies enable us to improve our Website and Services, estimate our audience size and usage patterns, store information about your preferences, save your password so that you don’t need to re-enter it each time you use our website, and recognise when you return to our website.
• The pop-up cookie notice will notify visitors about this feature when they land on our website, and they will be able to reject or approve the use of cookies for their visit.
• We do not link non-personal information from cookies to Personal Information without your permission.

 

Please note that third parties may also use cookies, but we do not have access to, or control over them, and therefore cannot take responsibility for them.

 

Retention of Personal Information

 

We retain personal data for as long as necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements. In general, although there may be limited exceptions:

• personal data is kept as per the requirements of in-country laws and regulations, although we may continue to keep such personal data for a longer time if we have obtained your consent to do so;
• If Select PPE and its group of companies has used a record of your personal information to make a decision about you as a data subject, we retain the record for such period as may be required or prescribed by law; or
• if there is no law prescribing a retention period, retain the record for a period which will afford you a reasonable opportunity, taking all considerations relating to the use of the personal information into account, to request access to the record;
• personal data relating to stakeholders with whom we no longer have a contractual agreement per the requirements of in-country laws and regulations, from the date when their entitlements cease, unless we are requested to delete such personal data earlier.

 

Select PPE and its group of companies will restrict processing of your personal information:

• if its accuracy is contested by a you; or for a period enabling Select PPE and its group of companies to verify the accuracy of the information; and/or
• we no longer need the personal information for achieving the purpose for which the information was collected or subsequently processed, but it has to be maintained for purposes of proof; and /or
• the processing is unlawful and you opposed its destruction or deletion and requests the restriction of its use instead; and/or
• you requested to transmit the personal data into another automated processing system.

 

Information Sharing

 

Select PPE and its group of companies does not sell, rent, or lease any Personal Information of individuals or companies to anyone for marketing or other purposes, and we take commercially reasonable steps to maintain the security of the Personal Information that we hold.

 

We will implement reasonable measures to keep your Personal Information confidential and only share it with others in terms of this Privacy Policy, or if you consent to it, or if the law requires from us to share it. We may disclose your Personal Information to:

• Our business partners or third-party service providers and processors in order to provide you with access to our website and/or services, such as data storage service providers, couriers, etc. in accordance with written agreements with these third parties.:
  • Accountants, Credit Controllers, auditors, lawyers, and other external professional advisors in terms of written agreements with them under a signed non-disclosure and confidentiality agreement protecting your personal information.
  • Personal Information will only be disseminated internally within Select PPE and its group of companies on a “need to know” and is authorised.
• Management report and other related reporting matters to a client and its group of companies
• We may disclose your personal information when legally required by government and/or a court of law.

 

Cross Border Transfer of Personal Information

 

Due to the nature of the services and business practices of Select PPE and its group of companies, we may need to transfer Personal Information to and from different countries for business purposes and to provide the services.

As allowed by POPIA, we may transfer Personal Information to recipients (mainly to companies within the Select PPE group) in other countries, but we will only transfer Personal Information to third parties in countries with adequate data protection laws or do so in terms of a written agreement with the recipient which imposes data protection requirements on that party as required by POPIA and consistent with the policy.

That will be prevented from further transferring the personal information of other third parties.

 

Legal Rights in respect of your Personal Information

 

You have certain rights in relation to your Personal Information. As available and except as limited under POPIA or other applicable laws, you have the following rights in respect of your Personal Information:

• right of access: the right to be informed of and request access to the Personal Information that we process about you.

• right to rectification and erasure: you may request that your Personal Information be amended or updated where it is inaccurate or incomplete or that we delete your Personal Information, subject to applicable limitations and exceptions.
• right to restrict processing: you may request that we temporarily or permanently stop processing your Personal Information.
• right to object: you may object to us processing your Personal Information, and to your Personal Information being processed for direct marketing purposes.
• right not to be subject to automated decision-making: where a decision that has a legal or other significant effect is based solely on automated decision making, including profiling, you may request that your Personal Information not be processed in that manner.
• Where you have provided consent for us to process your Personal Information, you may also withdraw your consent where our processing is based on your consent. However, we may continue to process your Personal Information if another legal justification exists for the processing.

 

Security

 

We have implemented appropriate technical and organisational security measures designed to protect Personal Information against accidental or unlawful destruction, loss, alteration, disclosure, access and other unlawful or unauthorised forms of processing. These measures are in accordance with the requirements of POPIA. Select PPE must use of generally accepted information security practices and procedure to safeguard the personal information of stakeholders.

 

Your Responsibility

 

As a Stakeholder, you are responsible for the accuracy and completeness of your personal data that you have provided to Select PPE. The quality of information ensures that both Select PPE and you derive maximum value from the use of your personal data, for the purposes of our relationship, the contractual agreements and the execution of obligations in terms of the contractual agreement. Please ensure that you keep your personal data, accurate and up-to-date.

 

Lodging a Complaint

 

If you want to raise any objection or have any queries about our privacy practices, you can contact us at privacy@selectppe.co.za.

 

You also have the right to formally lodge a complaint with the Information Regulator:

• Website: http://www.justice.gov.za/inforeg/index.html
• Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
• Email: inforeg@justice.gov.za