Shellard Media Audio Visual Projects (Pty) Ltd POPI Act Policy
POLICY IN TERMS OF THE PROTECTION OF PERSONAL
TABLE OF CONTENTS
1. PURPOSE OF THIS POLICY...........................................................................
2. THE PERSONAL INFORMATION WE MAY COLLECT ...................................
3. HOW YOUR PERSONAL INFORMATION IS COLLECTED ............................
4. HOW AND WHY, WE PROCESS YOUR PERSONAL INFORMATION ...........
5. WHO WE SHARE YOUR PERSONAL INFORMATION WITH .........................
6. DATA SECURITY.............................................................................................
7. HOW LONG YOUR PERSONAL INFORMATION WILL BE KEPT...................
8. INTERNATIONAL TRANSFER OF PERSONAL INFORMATION ....................
9. YOUR RIGHTS.................................................................................................
10. HOW TO CONTACT US...................................................................................
11. CHANGES TO THIS PRIVACY POLICY ..........................................................
ANNEXURE A: TYPES OF INFORMATION WE COLLECT AND WHY WE USE IT.......
1. PURPOSE OF THIS POLICY
1.1 Protecting your privacy is especially important to us.
1.2 Shellard Media Audio Visual Projects (Pty) Ltd is committed to complying with the
Protection of Personal Information Act 4 of 2013 in relation to the processing of your
personal information.
1.3 The purpose of this policy is to describe how and why we collect, store, use, share
or otherwise process your personal information. It also explains your rights in
relation to your personal information and how to contact us if you have a question
or complaint.
1.4 Please note that we may update this policy from time to time. The latest version of
this policy is available on request.
2. THE PERSONAL INFORMATION WE MAY COLLECT
2.1 We may collect and process the following personal information about you:
- (a) Your name and contact information, including your email address, telephone
number, physical address, postal address and other location information,
- (b) Your date of birth, age, gender, race, nationality, title and language preferences;
- (c) Your identity number, passport number and photograph;
- (d) Your vehicle registration number, vehicle license and driving license;
- (e) Your biometric information, including but not limited to, if applicable, that
information obtained from your fingerprints, hands, facial recognition and/or
retinal scanning;
- (f) Your verified banking details;
- (g) Your employment details;
- (h) Correspondence from you of a private or confidential nature;
- (i) such other personal information as is reasonably required by us to engage with
you and/or provide services to you.
3. HOW YOUR PERSONAL INFORMATION IS COLLECTED
3.1 We may collect or obtain personal information about you:
- (a) directly from you;
- (b) during the course of our interactions with you;
- (c) when you visit and/or interact with our website or any other social media
platforms or IT services;
- (d) from publicly available sources; and
- (e) from a third party who is authorised to share that information;
- (f) via a mobile or other software applications
4. HOW AND WHY, WE PROCESS YOUR PERSONAL INFORMATION
4.1 The personal information we may collect and why and how we use it depends on
our relationship with you.
4.2 POPIA requires that personal information “is collected for a specific, explicitly
defined and lawful purpose related to a function or activity of the responsible
party.”
4.3 Further, POPIA provides that personal information may only be processed if:
- (a) the data subject or a competent person where the data subject is a child
consents to the processing;
- (b) processing is necessary to carry out actions for the conclusion or
performance of a contract to which the data subject is party;
- (c) processing complies with an obligation imposed by law on the responsible
party;
- (d) processing protects a legitimate interest of the data subject;
- (e) processing is necessary for the proper performance of a public law duty by a
public body; or
- (f) processing is necessary for pursuing the legitimate interests of the
responsible party or of a third party to whom the information is supplied.
4.4 Our PAIA manual sets out a list of the types of information we collect and explains
why we collect and use it.
4.5 We may collect other personal information from time to time where you provide it
to us, as necessary for our business requirements, or in order to comply with
applicable laws.
4.6 Where it is lawful and practicable for us to allow it, you have the right not to identify
yourself when dealing with us. However, if you don’t provide us with your personal
information, it may impact our ability to engage with you and/or provide services to
you.
5. WHO WE SHARE YOUR PERSONAL INFORMATION WITH
5.1 Depending on the circumstances, we may disclose your personal information to
the following categories of persons:
- (a) Auditors, legal and other professional advisers and consultants of Shellard
Media Audio Visual Projects or other third parties who help us deliver our
services;
- (b) Information Technology and other service providers who help us with our
services to you or otherwise manage or store the personal information;
- (c) Government and law enforcement authorities;
- (d) Financial institutions;
- (e) Other third parties where disclosure is required by law or otherwise required for
us to perform our obligations and provide our services; and
- (f) To any other person with your consent to the disclosure.
5.2 We take reasonable steps to protect the confidentiality and security of your
personal information when it is disclosed to a third party and seek to ensure the
third-party deals with your information in accordance with our instructions,
applicable privacy laws, and only for the purpose for which it is disclosed.
6. DATA SECURITY
6.1 We may hold your personal information in electronic or in hard copy form. We may
keep this information at our own premises, or at sites managed by our services
providers.
6.2 We are committed to keeping your personal information safe.
6.3 We use a range of physical, electronic, and procedural safeguards to do this. We
update these safeguards from time to time in order to address new and emerging
security threats. We also train our people on privacy matters as appropriate and
seek to limit access to personal information to those of our people who need to
know that information.
6.4 We implement appropriate security measures to protect your personal information
that is in our possession against accidental or unlawful destruction, loss, alteration,
unauthorised disclosure, unauthorised access, in accordance with applicable law.
6.5 Where there are reasonable grounds to believe that your personal information that
is in our possession has been accessed or acquired by any unauthorised person,
we will notify the relevant regulator and you, unless a public body responsible for
detection, prevention or investigation of offences or the relevant regulator informs
us that notifying you will impede a criminal investigation.
7. HOW LONG YOUR PERSONAL INFORMATION WILL BE KEPT
7.1 We retain personal information we collect from you where we have an ongoing
legitimate business need to do so (for example, to provide you with a service) or to
comply with applicable legal, tax or accounting requirements.
7.2 We shall only retain and store your personal information for the period for which
the information is required to serve the purpose for its collection, or a legitimate
interest or the period required to comply with applicable legal requirements,
whichever is longer.
8. INTERNATIONAL TRANSFER OF PERSONAL INFORMATION
8.1 In some cases, the third parties to whom we may disclose your personal information
may be located outside your country of residence (for example, in a cloud service,
system or server), and may be subject to different privacy regimes.
8.2 When we disclose personal information overseas, we will take appropriate
safeguards to protect your personal information to ensure that the recipient will
handle the information in a manner consistent with this policy and the level of
protection provided for in POPIA.
9. YOUR RIGHTS
9.1 You have the right to:
- (a) ask what personal information we hold about you;
- (b) request access to the personal information that we hold about you;
- (c) ask us to update, correct or delete any out-of-date or incorrect personal
information we hold about you;
- (d) unsubscribe from any direct marketing communications we may send you; or
- (e) object to the processing of your personal information.
9.2 If you wish to exercise any of these rights or you have any queries regarding the
personal information that we hold about you, you can contact us at the details
provided below.
9.3 To protect the integrity and security of the information we hold, we may ask that
you follow a defined access procedure, which may include steps to verify your
identity.
9.4 If you want us to delete all personal information, we have about you, we may need
to terminate the agreements we have with you. We can refuse to delete your
information if we are required by law to retain it or if we need it to protect our rights.
10. HOW TO CONTACT US
10.1 If you have a question, concern, or complaint regarding the way in which we handle
your personal information, or if you believe that we have failed to comply with this
policy or breached any applicable laws in relation to the management of that
information, you can make a complaint.
10.2 Any question, concern or complaint should be made in writing to:
info@shellard.co.za
10.3 If you wish to make a request to access your personal information in terms of Section
23 of POPIA, please follow the procedure described in Shellard Media Audio Visual
Projects’ PAIA Manual which is available from our offices or on our website.
11. CHANGES TO THIS PRIVACY POLICY
11.1 This Policy was published on 2 August 2021 and last updated on 2 August 2021.
11.2 We may change this privacy notice from time to time