PROTECTION OF PERSONAL INFORMATION ACT- POLICY AND COMPLIANCE

THE ENTITIES OF SEVEN AND TWELVE ON HOUGHTON (PTY) LTD, ARE COMMITTED TO COMPLIANCE WITH, AND TO ADHERE TO THE PROTECTION OF PERSONAL INFORMATION ACT, AND CONFIRM THAT WE COMPLY WITH THIS LEGISLATION.

Introduction

The POPI Act requires Seven and Twelve on Houghton entities to:

1. Sufficiently inform members/patrons/residents/visitors/personnel/ service providers (hereinafter referred to as “data subjects”), the purpose for which we will process their personal information;
2. Protect the Information assets of the Seven and Twelve on Houghton (Pty) Ltd entities from threats, whether internal or external, deliberate or accidental, to ensure business continuation, minimise business damage and maximise business opportunities.

This policy and compliance framework establishes measures and standards for the protection and lawful processing of personal information within the Seven and Twelve on Houghton (Pty) Ltd entities and provides principles regarding the right of individuals to privacy and to reasonable safeguarding of their personal information.

Application of this Policy

This Policy applies to all data subjects of Seven and Twelve on Houghton (Pty) Ltd.

All employees, managers, business units, project managers, departments and individuals directly associated with any of the Seven and Twelve on Houghton (Pty) Ltd entities are responsible for adhering to this policy and for reporting any security breaches or incidents to the Information Officer.

Any service provider that provides information technology services, including data storage facilities, to any of the Seven and Twelve on Houghton (Pty) Ltd entities must adhere to the requirements of the POPI Act to ensure adequate protection of personal information held by them on our behalf. Written confirmation to this effect must be obtained from relevant service providers.

Information Officer

The appointed Information Officer is responsible for:

Conducting a preliminary assessment.
The development, implementation and monitoring of this policy and compliance framework.
Ensuring that this policy is supported by appropriate documentation.
Ensuring that documentation is relevant and kept up to date.
Ensuring this policy and subsequent updates are communicated to relevant members, residents, managers, representatives, staff and other data subjects, where applicable.

Policy Principles

Principle 1: Accountability

Seven and Twelve on Houghton (Pty) Ltd entities must take reasonable steps to ensure that personal information obtained from data subjects is stored safely and securely.

This includes personal information such as names, identity numbers, addresses, email addresses, references, qualifications, integrity checks and any other personal information that may be obtained for the purpose of providing Estate services, administrative services and such other services as may be related to Seven and Twelve on Houghton (Pty) Ltd, to the data subjects.

Principle 2: Processing limitation

The Seven and Twelve on Houghton (Pty) Ltd entities will collect personal information directly from candidates.

Once in the possession of the Seven and Twelve on Houghton (Pty) Ltd entities, the data will only be processed or released to non-Seven and Twelve on Houghton (Pty) Ltd entities with the consent of the data subject in question, except where the Seven and Twelve on Houghton (Pty) Ltd entities are required to do so by law. In the latter case the data subject will be informed of such release.

Principle 3: Specific purpose

Personal information will be processed to enable us the Seven and Twelve on Houghton (Pty) Ltd entities to perform the functions of such entities and to provide the services or functions, which is the purpose of such entity.

Principle 4: Limitation on further processing

Personal information may not be processed further in a way that is incompatible with the purpose for which the information was collected initially, without the consent of the data subject.

Principle 5: Information quality

The Seven and Twelve on Houghton (Pty) Ltd entities are responsible for ensuring that processed information is complete, up to date and accurate before such information is used by the Seven and Twelve on Houghton (Pty) Ltd entities. This means that it may be necessary to request data subjects, from time to time, to update their information and confirm that it is still relevant. If we are unable to reach a data subject for this purpose, their information will be deleted from our records.

Principle 6: Transparency/openness

Where personal information is processed from a source other than directly from a data subject, the Seven and Twelve on Houghton (Pty) Ltd entities are responsible for ensuring that the data subject is aware –

that the information is being processed,
who or which Seven and Twelve on Houghton (Pty) Ltd entity is processing the information by giving them the details of the entity, and
what the specific reason for the processing of the information is.

Principle 7: Security safeguards

The Seven and Twelve on Houghton (Pty) Ltd entities will ensure technical and organisational measures to secure the integrity of personal information, and guard against the risk of loss, damage, or destruction thereof. Personal information must also be protected against any unauthorised or unlawful access or processing. The Seven and Twelve on Houghton (Pty) Ltd entities are committed to ensuring that information is only used for legitimate purposes with data subject consent and only by authorised employees of the Seven and Twelve on Houghton (Pty) Ltd entities.

Principle 8: Participation of individuals

Data subjects are entitled to know particulars of their personal information held by the Seven and Twelve on Houghton (Pty) Ltd entities, as well as the identity of any authorised employees of the Seven and Twelve on Houghton (Pty) Ltd entities that have access thereto. Data subjects are also entitled to correct any information held by the Seven and Twelve on Houghton (Pty) Ltd entities.

Operational Considerations

Monitoring

The Board of the HOA, which includes representatives of all the Seven and Twelve on Houghton (Pty) Ltd entities, the management of each of the Seven and Twelve on Houghton (Pty) Ltd entities, and the Information Officer are responsible for administering and overseeing the implementation of this policy and, as applicable, supporting guidelines, standard operating procedures, notices, consents and appropriate related documents and processes. All employees, consultants, service providers’ on-site personnel, departments and individuals directly associated with the Seven and Twelve on Houghton (Pty) Ltd entities are to be trained, according to their functions, in the regulatory requirements, policies and guidelines that govern the protection of personal information. The Seven and Twelve on Houghton (Pty) Ltd entities will conduct periodic reviews and audits, where appropriate, to ensure compliance with this policy and guidelines.

Operating controls

The Seven and Twelve on Houghton (Pty) Ltd entities shall establish appropriate standard operating procedures that are consistent with this policy and regulatory requirements. This will include:

Allocation of information security responsibilities. Incident reporting and management. User ID addition or removal. Information security training and education. Data backup.

Policy compliance

Any breach/es of this policy may result in disciplinary action and possible termination of employment.

For data subjects:

By entering the Estate and submitting your information, you confirm:

1. That you have read and understood this POPI Policy.
2. That you have no objection to us retaining your personal information in our database for the purposes of providing Estate services.
3. That the information you have provided to the Seven and Twelve on Houghton (Pty) Ltd entities is true, correct and up to date.

If you have any additional questions about the Seven and Twelve on Houghton (Pty) Ltd entities collection and storage of data, please contact steven@thehoughton.com