Red Dot Catering (PTY LTD)
T/A The Grocery Express
Authorised by:
Chris Liebenberg
Information Officer
Date Authorised:
02 July 21
Document Number: July 21-01
Protection Of Personal Information Consent
__________________________________________________
(“The Client”)
And
Red Dot Catering (Pty)LTD t/a
The Grocery Express
REQUEST FOR CONSENT TO RECEIVE DIRECT MARKETING COMMUNICATION
SECTION 69(2) AND REGULATION 6 OF THE PROTECTION OF PERSONAL INFORMATION ACT
FORM 4 – PART A
Dear Client
We do direct marketing via electronic communication for example sms email etc.We also share
personal information with third parties in order to optimize our service delivery. You are currently on
our marketing list and only if you wish to not receive any marketing information you should click on the
opt out link below.
Please Note That our website Makes use of Cookies
1. This agreement will be applicable to all personal information as defined in the Protection of
Personal Information Act, 4 of 2013 (“POPI”).
2. By either Party submitting any personal information to the other, the disclosing Party
unconditionally and voluntarily, consents to the processing of the submitted personal
information for any and all purposes related to this agreement.
3. The Parties agrees and consent that its personal information may be processed by, or on
behalf of either of the Parties for the purposes set out in the Agreement.
4. The Parties shall at all times comply with its obligations and procure that each of
its Affiliates comply with their obligations under POPI.
5. The Parties shall ensure that any personal information that is processed by it in the course
of performing its obligations under the Agreement is done in accordance with POPI.
6. Each Party shall not process, disclose, or use personal information except:
a) to the extent necessary for the provision of Services and/or Products under
the Agreement; or
b) to fulfil their own obligations under the Agreement; or
c) as otherwise expressly authorised by the other Party in writing.
7. Red Dot Catering t/a The Grocery Express shall disclose any personal information to any
Third Party without the other Party’s prior consent in each instance, and to the extent
required by any Regulator or Law.
8. In the event the that the disclosure of personal information to a Third Party, each
Party shall:
a) make such disclosure in compliance with POPI; and
b) enter into a written agreement with the applicable Third-Party recipient of
such personal information that requires such Third Party to safeguard
the personal information in a manner no less restrictive than each Party’s
obligations under these terms.
9. The Parties shall implement and maintain an effective security safeguards that includes,
but is not limited to administrative, technical, and physical safeguards, and appropriate
technical and organisational measures, in each case, adequate to insure the security and
confidentiality of personal information, and to protect against any anticipated risks to the
security or integrity of personal information, protect against unauthorized access to or use
of personal information, protect personal information against unlawful processing
or processing otherwise than in accordance with this agreement, and protect against
accidental loss, destruction, damage, alteration or disclosure of personal information.
10. Without limiting the foregoing, such safeguards and measures shall be appropriate to
protect against the harm that may result from unauthorised or unlawful processing, use or
disclosure, or accidental loss, destruction, or damage to or of Personal Information and the
nature of the personal information, and shall maintain all safeguard measures as is
required by POPI.
11. Each Party shall not use, process, store, transfer or permit access to
any personal information across the borders of South Africa, without the written consent of
the other Party.
12. In the event of any actual, suspected, or alleged security breach, including, but not limited
to, loss, damage, destruction, theft, unauthorized use, access to or disclosure of
any personal information, each Party shall:
a) notify the other Party as soon as practicable after becoming aware of
such event;
b) provide the other Party will all information regarding the breach in the Party’s
knowledge and possession to allow the Party to ascertain what has occurred
and which personal information has been affected.
c) promptly take whatever action is necessary, at each Party’s own expense,
to minimise the impact of such event and prevent such event from recurring.
13. The Client hereby consents to the Company sharing the personal information as provided
for herein cross border. Should the Client’s personal information be shared cross border,
the personal information will not be subject to less protection than it enjoys in terms of
South Africa’s data privacy laws.
Data Protection Policy
Introduction
1. Overview
a) Where we refer to “process”, it means how we collect, use, store, make available,
destroy, update, disclose, or otherwise deal with personal information. As a general
rule, we will only process this personal information if it is required to deliver or offer a
service, provide a product, carry out a transaction or obligation in a contract.
b) We may combine this personal information and use the combined personal information
for any of the purposes stated in this Privacy Policy.
c) If you use our other services, goods, products, and service channels you agree
that we may process this personal information as explained under this Privacy Policy.
Sometimes you may provide us with consent to process this personal information.
d) The Company is a global organisation and as such this Privacy Policy will apply to the
processing of personal information by any member of The Company globally. If The
Company processes personal information for another party under a contract or a
mandate, the other party’s privacy policy will apply to the processing of such information.
e) The Company can change this Privacy Policy from time to time if the law or our business
practices requires such change.
f) This policy establishes a general standard for the appropriate protection of personal
information (POPI) within The Company environment. Furthermore, it provides principles
regarding the rights of individuals to privacy and to reasonably safeguard their personal
information.
2. Scope
All employees, contractors, consultants, temporary and other workers at The Company, including
all personnel affiliated with third parties must adhere to this policy. This policy applies to
information assets owned or leased by The Company, or to devices that connect to a
Company network or reside at a Company site.
Policy Statement
1. What is personal information?
Personal information refers to any information that identifies you or specifically relates to you,
or your employees stored or processed on The Product/s. Personal information includes, but
is not limited to, the following information about you and / or your employees:
a) Marital status
b) National origin
c) Age
d) Language
e) Birthplace
f) Education
g) Relevant financial history
h) Identifying number (like an employee number, identity number or passport number)
i) E-mail address; physical address (like residential address, work address or your physical
location); telephone number
j) Biometric information (like fingerprints, signature, or voice)
k) Race; gender; sex; pregnancy status; ethnic origin; social origin; colour; sexual
orientation
l) Physical health; mental health; well-being; disability; religion; belief; conscience; culture
m) Medical history; criminal history; employment history
n) Personal views, preferences, and opinions
o) Another’s views or opinions about you.
p) Full names and initials
Personal information includes special personal information, as explained below.
2. When will we process your personal information?
We will only process this personal information for lawful purposes relating to our business if the
following applies:
a) If you have consented thereto
b) If a person legally authorised by you, the law, or a court, has consented thereto.
c) If it is necessary to conclude or perform under a contract, we have with you
d) If the law requires or permits it
e) If it is required to protect or pursue your, our or a third party’s legitimate interest.
3. What is special personal information?
Special personal information is personal information about the following:
a) Race (like where a company submits reports to the Department of Labour where the
statistical information must be recorded)
b) Ethnic origin
c) Trade union membership
d) Health (like where you apply for an insurance policy)
e) Biometric information (like to verify your identity); and / or your criminal behaviour and
alleged commission of an offense.
4. When will we process your special personal information?
We may process your special personal information in the following circumstances:
a) If you have consented to the processing
b) If the information is being used for any Human Resource or payroll related requirement
c) If the processing is needed to create, use or protect a right or obligation in law.
d) If the processing is for statistical or research purposes and all legal conditions are met
e) If the special personal information was made public by you
f) If the processing is required by law
5. When and from where we obtain personal information about you
a) We collect personal information from you directly.
b) We may collect personal information from a public record or if you have deliberately made
the information public.
c) We collect personal information from 3rd parties that are directly integrated
with our software platform.
d) We collect information about you based on your use of our products, services, or service
channels.
e) We collect information about you based on how you engage or interact with us such as
via emails, letters, telephone calls and surveys.
f) We collect personal information from completed forms i.e., contact and billing
information.
If the law requires us to do so, we will ask for your consent before collecting personal information.
The third parties from whom we may collect your personal information include, but are not limited to,
the following:
a) Our partners, your employer, employees directly, any of our other Bureau or channel
partners and any connected companies, subsidiary companies, its
associates, cessionary, delegates, assigns, affiliates or successors in title and / or
appointed third parties (like its authorised agents, partners, contractors, and suppliers) for
any of the purposes identified in this Privacy Policy.
b) your spouse, dependents, partners, employer, and other similar sources.
c) people you have authorised to share your personal information, like a person that makes
a travel booking on your behalf or a medical practitioner for insurance purposes.
d) attorneys, tracing agents, debt collectors and other persons that assist with the
enforcement of agreements.
e) payment processing services providers, merchants, banks, and other persons that assist
with the processing of your payment instructions, like EFT transaction partners.
f) insurers, brokers, other financial institutions, or other organisations that assist with
insurance and assurance underwriting, the providing of insurance and assurance policies
and products, the assessment of insurance and assurance claims and other related
purposes.
g) law enforcement and fraud prevention agencies and other persons tasked with the
prevention and prosecution of crime.
h) regulatory authorities, industry ombudsman, governmental departments, local and
international tax authorities.
i) trustees, Executors or Curators appointed by a court of law.
j) our service providers, agents and sub-contractors like couriers and other persons we use
to offer and provide products and services to you.
k) courts of law or tribunals.
6. Reasons we need to process your personal information.
We will process your personal information for the following reasons:
a) to provide you with products, goods and services;
b) to market our products, goods, and services to you.
c) to respond to your enquiries and complaints.
d) to comply with legislative, regulatory, risk and compliance requirements (including
directives, sanctions, and rules), voluntary and involuntary codes of conduct and industry
agreements or to fulfil reporting requirements and information requests.
e) to conduct market and behavioural research, including scoring and analysis to determine
if you qualify for products and services or to determine your credit or insurance risk;
f) to develop, test and improve products and services for you;
g) for historical, statistical and research purposes, like market segmentation.
h) to process payment instruments.
i) to create, manufacture and print payment advice;
j) to enable us to deliver goods, documents or notices to you;
k) for security, identity verification and to check the accuracy of your personal information;
l) to communicate with you and carry out your instructions and requests.
m) for customer satisfaction surveys, promotional offerings.
n) to enable you to take part in and make use of value-added products and services.
o) to assess our lending and insurance risks; and / or
p) for any other related purposes.
7. How we use your personal information for marketing purposes
a) We will use your personal information to market our services, related products, and
services to you.
b) We may also market non-banking or non-financial products, goods, or services to you.
c) We will do this in person, by post, telephone, or electronic channels such as SMS, email,
and fax.
d) If you are not our customer, or in any other instances where the law requires, we will
only market to you by electronic communications with your consent.
e) In all cases you can request us to stop sending marketing communications to you at any
time
8. When how and with whom we share your personal information
In general, we will only share your personal information if any one or more of the following
apply:
a) If you have consented to this
b) If it is necessary to conclude or perform under a contract, we have with you
c) If the law requires it; and / or
d) If it’s necessary to protect or pursue your, our or a third party’s legitimate interests.
Where required, each member of the company may share your personal information with the
following persons. These persons have an obligation to keep your personal information secure
and confidential.
a) Other members of The Company, its associates, cessionary, delegates, assigns, affiliates
or successors in title and / or appointed third parties (like its authorised agents, partners,
contractors, and suppliers) for any of the purposes identified in this Privacy Policy.
b) Our employees as required by their employment conditions.
c) Attorneys, tracing agents, debt collectors and other persons that assist with the
enforcement of agreements.
d) Payment processing services providers, merchants, banks, and other persons that assist
with the processing of your payment instructions, like 3rd party EFT service providers.
e) Law enforcement and fraud prevention agencies and other persons tasked with the
prevention and prosecution of crime.
f) Regulatory authorities, industry ombudsmen, governmental departments, local and
international tax authorities, and other persons the law requires us to
share your personal information with
g) Our service providers, agents and sub-contractors like couriers and other
persons we use to offer and provide products and services to you
h) Persons to whom we have ceded our rights or delegated our obligations to under
agreements, like where a business is sold
i) Courts of law or tribunals that require the personal information to adjudicate referrals,
actions or applications.
j) Trustees, Executors or Curators appointed by a court of law
k) Participating partners in our customer loyalty reward programmes, where you purchase
goods, products and service or spend loyalty rewards; and / or our joint venture and other
partners with whom we have concluded business agreements, for your benefit.
9. Under what circumstances will we transfer your information to other countries?
We will only transfer your personal information to third parties in another country in any one or
more of the following circumstances:
a) Where your personal information will be adequately protected under the other country’s
laws or an agreement with the third-party recipient
b) Where the transfer is necessary to enter into or perform under a contract with you, or a
contract with a third party that is in your interest.
c) Where you have consented to the transfer; and / or
d) Where it is not reasonably practical to obtain your consent, the transfer is
in your interest.
This transfer will happen within the requirements and safeguards of the law. Where possible, the party
processing your personal information in the other country will agree to apply the same level of
protection as available by law in your country or if the other country’s laws provide better protection
the other country’s laws would be agreed to and applied.
An example of us transferring your personal information to another country is where foreign
payments take place if you purchase goods or services in a foreign country, or request
that we facilitate salary payments to your employees in the countries.
10. Your duties and rights about the personal information we have about you
You must provide proof of identity when enforcing the rights below.
You must inform us when your personal information changes.
Please refer to our Promotion of Access to Information Act 2 of 2000 Manual (PAIA
Manual) for further information on how you can give effect to the rights listed below.
You have the right to request access to the personal information we have about you by
contacting us. This includes requesting:
a) Confirmation that we hold your personal information.
b) A copy or description of the record containing your personal information; and
c) The identity or categories of third parties who have had access
to your personal information.
We will attend to requests for access to personal information within a reasonable time. You may be
required to pay a reasonable fee to receive copies or descriptions of records, or information about
third parties. We will inform you of the fee before attending to your request.
Please note that the law may limit your right to access information.
You have the right to request us to correct or delete the personal information we have about you if it
is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, obtained unlawfully or we are
no longer authorised to keep it. You must inform us of your request in writing. Please refer to our
PAIA Manual for further information in this regard, like the process you should follow to give effect to
this right. It may take up to 15 business days for the change to reflect on our systems. We may
request documents from you to verify the change in personal information.
A specific agreement that you have entered with us may determine how you must
change your personal information provided at the time when you entered into the specific agreement.
Please adhere to these requirements. If the law requires us to keep the personal information, it will
not be deleted upon your request. The deletion of certain personal information may lead to the
termination of your relationship with us.
You may object on reasonable grounds to the processing of your personal information.
We will not be able to give effect to your objection if the processing of your personal information was
and is permitted by law; you have provided consent to the processing and our processing done
according to your consent or the processing is necessary to conclude or perform under a contract
with you.
You must inform us of any objection in writing. Please refer to our PAIA Manual for further
information in this regard, like the process you should follow to give effect to this right.
Where you have provided your consent for the processing of your personal information, you may
withdraw your consent. If you withdraw your consent, we will explain the consequences
to you. We may proceed to process your personal information even if you have
withdrawn your consent if the law permits or requires it. It may take up to 15 business days for the
change to reflect on our systems, during this time we may still process your personal information.
You have a right to file a complaint with us or any Regulator with jurisdiction about an alleged
contravention of the protection of your personal information by us. We will address your complaint as
far as possible.
11. How we secure your personal information
We will take appropriate and reasonable technical and organisational steps to
protect your personal information according to industry best practices. Our security measures
(including physical, technological, and procedural safeguards) will be appropriate and reasonable.
This includes the following:
a) Keeping our systems secure (like monitoring access and usage)
b) Storing our records securely
c) Controlling the access to our buildings, systems and/or records; and
d) Safely destroying or deleting records
e) Ensure compliance with international security standards.
12. How long do we keep your personal information?
We will keep your personal information for as long as:
a) The law requires us to keep it
b) A contract between you and us requires us to keep it
c) You have consented to us keeping it
d) We are required to keep it to achieve the purposes listed in this Privacy Policy.
e) We require it for statistical or research purposes.
f) A code of conduct requires us to keep it; and / or
g) We require it for our lawful business purposes.
a. Note: We may keep your personal information even if you no longer have a relationship
with us, for the historical data that may be required by your employer or employee.
13. Children's Privacy
Our Service does not address anyone under the age of 13. We do not knowingly collect
personally identifiable information from anyone under the age of 13. If You are a parent or
guardian and You are aware that Your child has provided The Company with Personal Data,
please contact Us. If We become aware that We have collected Personal Data from anyone
under the age of 13 without verification of parental consent, we take steps to remove that
information from Our servers.
If We need to rely on consent as a legal basis for processing Your information and Your country
requires consent from a parent, we may require Your parent's consent before We collect and use that
information.
14. Our cookie policy
A cookie is a small piece of data sent from our websites or applications to your computer or
device hard drive or Internet browser where it is saved. The cookie contains information to
personalise your experience on our websites or applications and may improve your experience
on the websites or applications. The cookie will also identify your device, like the computer or
smart phone.
By using our websites or applications you agree that cookies may be forwarded from the relevant
website or application to your computer or device. The cookie will enable us to know that you have
visited the website or application before and will identify you. We may also use the cookie to prevent
fraud and for analytics.
Password Policy
1. Introduction
Overview
Passwords are an important aspect of computer security. A poorly chosen password may result in
unauthorized access and/or exploitation of The Company resources. All users, including contractors
and vendors with access to The Company systems, are responsible for taking the appropriate steps,
as outlined below, to select and secure their passwords
3. Password Protection
a) Refrain from sending plaintext passwords over networks or email, it could
compromise security. Passwords sent in plain text can be read by anyone.
b) Passwords must not be shared with anyone. All passwords are to be treated as
restricted The Company information.
c) Passwords may be inserted into email messages, Alliance cases or other forms of
electronic communication, but must be encrypted and the encryption key must be
shared via a different media source. Refer to the Acceptable Encryption Policy.
d) Do not reveal a password on questionnaires or security forms.
e) Do not hint at the format of a password (for example, "my family name").
f) Do not share The Company passwords with anyone, including administrative
assistants, secretaries, managers, co-workers, and family members.
g) Do not write passwords down and store them anywhere in your workspace.
h) Do not store passwords in a file on a computer system or mobile devices (phone,
tablet)
i) Do not use the "Remember Password" feature of applications (for example, web
browsers).
j) Any user suspecting that his/her password may have been compromised must report
the incident to the The Company IT department immediately and request a change
of passwords on all user access accounts.
k) Password managers can be used, users must refer to the pre-authorized software
list, held by InfoSec and IT departments.
5. Password Construction Guidelines
Passphrases are not the same as passwords. A passphrase is a longer version of a password
and is, therefore, more secure. A passphrase is typically composed of multiple words. Because
of this, a passphrase is more secure against "dictionary attacks".
A good passphrase is relatively long and contains a combination of upper and lowercase letters,
numeric and punctuation characters.
Passwords that are listed in the password blacklist will not be available for use.
The Company Passwords must meet three of the four characteristics below:
• Contain at least 6 alphanumeric characters.
• Contain both upper- and lower-case letters.
• Contain at least one number (for example, 0-9).
• Contain at least one special character (for example, $%^&*()_+|~-‐=\`{}[]:";'<>?,/).