Compliance Statement

This is the POPIA Compliance Framework for the Close Corporation of Innov-X-Africa CC (hereinafter referred to as “Close Corporation”) develop and implemented in terms of paragraph 4(1)(a) of the Regulations in terms of the Protection of Personal Information Act, 2013 (POPIA).

Our Commitment

Our Close Corporation is committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognise our obligations in updating and expanding this program to meet the demands of the POPIA Act.

Our Close Corporation is dedicated to safeguarding the personal information under our remit and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new POPIA Act. Our preparation and objectives for POPIA compliance have been summarised in this statement and include the development and implementation of new data protection roles, policies, procedures, controls, and measures to ensure maximum and ongoing compliance.

Our preparations for the POPIA Act

Our Close Corporation has always had a consistent level of data protection and security across our organisation; however, it is our aim to be fully compliant with the POPIA Act now it has come into force on 1 July 2021.

Our preparations have included:

1. Information Audit - carrying out an audit to identify and assess what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed.
2. Top Management buy-in -The management of our Close Corporation is fully committed to protecting data in the Close Corporation and be able to demonstrate that we are POPIA compliant.
3. Policies & Procedures - revising or implementing our data protection policies and procedures to ensure we meet the requirements and standards of the POPIA Act.
4. Legal Basis for Processing - we are reviewing all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to. Where applicable, we also maintain records of our processing activities, ensuring that our obligations are met.
5. Privacy Notice/Policy – we are developing our Privacy Notice(s) to comply with the POPIA Act, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
6. Obtaining Consent - we are revising our consent mechanisms for obtaining personal information, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information. We have developed stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time.
7. Data Subject Rights - In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we respect an individual’s right to access any personal information that our Close Corporation processes about them and to request information about: -
8. What personal information we hold about them?
9. The purposes of the processing.
10. The categories of personal information concerned.
11. The recipients to whom the personal information has/will be disclosed.
12. How long we intend to store your personal information for?
13. If we did not collect the data directly from them, information about the source?
14. The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this.
15. The right to request erasure of personal information (where applicable) or to restrict processing in accordance with the POPIA Act, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use.
16. The right to lodge a complaint or seek judicial remedy and who to contact in such instances.

Information Security & Technical and Organisational Measures

Our Close Corporation takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure and precaution to protect and secure the personal information that we process. We have robust information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure, or destruction.

Close Corporation Roles and Employees

Our Close Corporation has designated the undermentioned as our Information Officer / Deputy Information Officer with the responsibility to maintain our compliance with the POPIA Act.

If you have any questions about our compliance with the POPIA Act, please contact us by email at geraldine@innovxafrica.co.za