Policy in Terms of the Protection of Personal Information Act (POPIA)

1 INTRODUCTION

1.1 Whereas Centurion Gymnastics Club is obliged to comply with the Protection of Personal Information Act 4 of 2013.

1.2 Centurion Gymnastics Club is required to inform Members as to how their Personal Information is used, disclosed, and destroyed.

1.3 Centurion Gymnastics Club is committed to protecting Members’ privacy and ensuring that their Personal Information is used appropriately, transparently, securely and in accordance with applicable laws.

1.4 Wherefore this Policy sets out a way Centurion Gymnastics Club deals with Personal Information as well as stipulates the purposes for which said information is used.

2 DEFINITIONS AND INTERPRETATION

2.1 Unless otherwise expressly stated, or the context otherwise requires, the words and expressions listed below shall, when used in this policy, bear the meanings ascribed to them below, and cognate expressions bear corresponding meanings:

2.1.1 “Management” means the Centurion Gymnastics Club Management Committee serving from time to time, and which is defined in the Constitution of Centurion Gymnastics Club.

2.1.2 “Chief Information Officer” means the Chief Information Officer of Centurion Gymnastics Club.

2.1.3 “Members” means the members of Centurion Gymnastics Club as defined in the Constitution of Centurion Gymnastics Club.

2.1.4 “Personal Information” means information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, including, but not limited to:

2.1.4.1 information relating to the race, gender, sex, pregnancy, marital status, national, ethnic, or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of the person.

2.1.4.2 information relating to the education or the medical, financial, criminal or employment history of the person.

2.1.4.3 any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier, or other assignments to the person.

2.1.4.4 the biometric information of the person.

2.1.4.5 the personal opinions, views, or preferences of the person.

2.1.4.6 correspondence sent by the person that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence.

2.1.4.7 the views or opinions of another individual about the person; and

2.1.4.8 the name of the person if it appears with other personal information relating to the person or if the disclosure of the name itself would reveal information about the person.

2.1.5 “POPI” means the Protection of Personal Information Act 4, 2013.

2.1.7 “Policy” means this POPI policy.

2.2 In this Policy:

2.2.1 table of contents and paragraph headings are for purposes of reference only and shall not be used in interpretation.

2.2.2 unless the context clearly indicates a contrary intention, any word connoting any gender includes the other genders, and the singular includes the plural and vice versa.

2.2.3 When a number of days are prescribed such number shall exclude the first and include the last day unless the last day is not a business day, in which case the last day shall be the next succeeding business day.

2.2.4 A reference to a business day is a reference to any day excluding Saturday, Sunday, and a public holiday in the RSA.

3 PERSONAL INFORMATION COLLECTED

3.1 Section 10 of POPI states that “Personal Information may only be processed if, given the purpose for which it is processed, it is adequate, relevant and not excessive.”

3.2 Centurion Gymnastics Club collects and processes Members’ Personal Information pertaining to their respective membership. The type of information will depend on the need for which it is collected and will be processed for that purpose only. Whenever possible, we will inform Members’ what information they are required to provide us with and what information is optional.

3.3 Examples of the Personal Information we collect includes but is not limited to:

3.3.1 Member’s contact information, identity number, name, surname, addresses, postal code and employment details.

3.3.2 In the case of Minors, the name, surname, contact information, addresses of the parents or guardians.

3.3.3 Member’s demographic data such as gender, age, ethnicity, country, and preferred language; and

3.3.4 Any other information reasonably required by Centurion Gymnastics Club or Gymnastics South Africa.

3.5 For purposes of this Policy, Members included potential and existing Members.

4 THE USAGE OF PERSONAL INFORMATION

4.1 Members Personal Information will only be used for the purpose for which it was collected and agreed. This may include:

4.1.1 Respond to Member’s enquiries and requests.

4.1.2 Providing services to Members and to carry out the transactions requested.

4.1.3 Confirming, verifying, and updating Members details.

4.1.4 For audit and record keeping purposes.

4.1.5 In connection with legal proceedings.

4.1.6 Providing our services to Members to carry out the services requested and to maintain and constantly improve the relationship.

4.1.7 In connection with and to comply with legal and regulatory requirements or when it is otherwise allowed by law; and

4.1.11 Any other reasonable usage of Personal Information with the consent of the Member.

5 DISCLOSURES OF PERSONAL INFORMATION

5.1 Subject to a Member’s approval, Centurion Gymnastics Club may share Members’ Personal Information with and obtain information about Members from third parties for the reasons already discussed above.

5.2 Centurion Gymnastics Club may also disclose Members’ information where Centurion Gymnastics Club has a duty or a right to disclose in terms of applicable legislation, the law or where it may be deemed necessary to protect the rights of Centurion Gymnastics Club.

6 SAFEGUARDING MEMBERS INFORMATION

6.1 It is a requirement of POPI to adequately protect the Personal Information we hold and to avoid unauthorised access and use of Personal Information. We continuously review our security controls and processes to ensure that Personal Information is secure.

6.2 The following procedures are in place to protect Personal Information:

6.2.1 The Chief Information Officer and the Deputy Information Officer, whose details are available below and who is responsible for the encouragement of compliance with the conditions of the lawful processing of Personal Information and other provisions of POPI.

6.2.2 Employees are required to sign Confidentiality Agreements which are considered annexures to their Employment Contracts.

6.2.3 Hard copy files are stored at secure premises and are destroyed after five years.

6.2.4 Electronic files will be protected by appropriate passwords. 

6.2.5 Consent to process Member information is obtained from Members (or a person who is authorised by the Member to provide the Members’ Personal Information) during registration.

7 ACCESS AND CORRECTION OF PERSONAL INFORMATION

7.1 Members have the right to access the Personal Information that Centurion Gymnastics Club holds about them. Members also have the right to ask for an update, correction, or deletion of their Personal Information on reasonable grounds. Once a member objects to the processing of their Personal Information, Centurion Gymnastics Club may no longer process such Members Personal Information.

7.2 The details of our Chief Information Officer are as follows:

7.2.1 Chief Information Officer Details

7.2.1.1 Name:  Adrie Grobler

7.2.1.2 Telephone Number:  012 663 6639

7.2.2 Deputy Information Officer Details

7.2.2.1 Name:  Chaka Croukamp

7.2.2.2 Telephone Number: 082 889 6332

7.2.1.3 Registered Business Address:  71 South Street Centurion

7.2.1.4 E-mail Address: admin@cgclub.co.za