The Company Privacy Notice is a mandatory document under South Africa's Protection of Personal Information Act (POPIA) for any organization processing personal information. It serves as the primary instrument for achieving transparency in data processing activities and fulfilling the organization's duty to inform data subjects about how their personal information is handled. The notice must be easily accessible, written in clear language, and cover all aspects of data processing, from collection to disposal. It should be implemented when an organization begins operations or processing personal information, and must be regularly reviewed and updated to reflect changes in processing activities or legal requirements. The document is particularly crucial in the South African context, where POPIA imposes strict requirements on responsible parties (data controllers) to ensure lawful processing of personal information and respect for data subject rights.
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1. Introduction: Overview of the organization and scope of the privacy notice
2. Definitions and Interpretation: Key terms used in the notice, aligned with POPIA definitions
3. Information Officer Details: Contact details of the Information Officer and Deputy Information Officer as required by POPIA
4. Types of Personal Information We Process: Comprehensive list of personal information categories collected and processed
5. How We Collect Personal Information: Methods and sources of personal information collection
6. Purposes for Processing Personal Information: Detailed explanation of why personal information is collected and processed
7. Lawful Basis for Processing: Legal grounds under POPIA for processing personal information
8. Information Sharing and Disclosure: Details about third parties with whom information is shared and circumstances of sharing
9. Cross-border Transfer of Personal Information: Information about international transfers and safeguards in place
10. Information Security: Measures taken to protect personal information
11. Data Subject Rights: Explanation of rights under POPIA and how to exercise them
12. Retention of Personal Information: How long information is kept and criteria for retention periods
13. Changes to This Privacy Notice: Process for updating the notice and notifying of changes
14. Complaints Procedure: How to raise concerns and contact the Information Regulator
1. Cookie Policy: Required if the organization operates websites using cookies
2. Direct Marketing: Required if the organization engages in direct marketing activities
3. Children's Privacy: Required if services or products may involve processing children's personal information
4. Automated Decision Making: Required if the organization uses automated processing or profiling
5. Employee Privacy: Required if the notice covers employee data processing
6. CCTV and Surveillance: Required if premises have surveillance systems
7. Special Personal Information: Required if processing special categories of personal information as defined in POPIA
1. Schedule 1: Categories of Personal Information: Detailed breakdown of all categories of personal information processed
2. Schedule 2: Third Party Processors: List of third-party service providers and processors with access to personal information
3. Schedule 3: Technical and Organizational Security Measures: Detailed description of security measures implemented
4. Schedule 4: Countries for Cross-border Transfers: List of countries to which personal information may be transferred and applicable safeguards
5. Appendix A: Data Subject Request Form: Standard form for submitting data subject access requests
6. Appendix B: Consent Forms: Standard consent forms for specific processing activities where required
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