1. Introduction

2. Amendments to this policy

Amendments to, or a review of this Policy, takes place on an ad hoc basis or at least once a year.

3. Policy Purpose

• through stating desired behaviour and directing compliance with the provisions of the POPI ACT;
• by cultivating an organisational culture that recognises privacy as a valuable human right;
• by developing and implementing internal controls for the purpose of managing the compliance risk associated with the protection of Personal Information;
• by creating business practices that will provide reasonable assurance that the rights of the Data Subject are protected and balanced with the legitimate business needs of FlameBlock;
• by assigning specific duties and responsibilities to control owners, including the appointment of an Information Officer and where necessary Deputy Information Officers;
• by raising awareness through training and providing guidance to individuals who process Personal Information (PI) so that they can act confidently and consistently.

4. Policy Function

• developing and upkeeping this policy;
• ensuring 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 role players.

4.1. Key Risks

• breach of confidentiality (information being given out inappropriately);
• insufficient clarity about the range of uses to which information will be put — leading to the Data Subject being insufficiently informed;
• failure to offer choice about information use when appropriate;
• breach of security by allowing unauthorised access;
• harm to individuals if Personal Information is not up to date;
• management of Personal Information (PI) by Third Party Operators.

5. Compliance to POPI ACT conditions

Table 2- POPI Act Conditions

6. Compliance to POPI ACT privacy Requirements

FlameBlock undertakes to implement and maintain reasonable measures to ensure that all employees, contractors and third parties acting on behalf of FlameBlock will always be subject to, and act in accordance with privacy requirements as stipulated by the POPI Act.

The reasonable measures to be implemented will be instrumental to ensure that security and privacy of Personal Information (PI) are addressed with regards to the following categories:

• Collection of Personal Information (PI);
• Processing of Personal information (PI);
• Use of Personal Information (PI);
• Safeguarding Personal Information (PI);
• Access to Personal Information (PI);
• Correction of Personal Information (PI);
• Disclosure of Personal Information (PI).

7. Collection of Personal Information (PI)

FlameBlock collects the Personal Information (PI) of our clients during the following relevant business scenarios:

• via direct communication for example face-to-face or telephone conversations,
• via email or mobile messaging communication channels

Examples of Personal Information (PI) collected by FlameBlock include:

• clients: name, surname, telephone number, address, postal code, company name; etc.
• suppliers: company name, contact person name and surname, telephone number, company registration and vat number etc.

1. Highly Sensitive Personal Information (PI)

FlameBlock collects highly sensitive personal information (PI) relating to our clients only when necessary for a specific business or regulatory process e.g., for requirements to comply to Covid 19 regulations.

7. 2. Condition of Openness

8. Processing of Personal Information (PI)

FlameBlock undertakes to destroy or delete a record of personal information (PI) collected as soon as reasonably practicable based on applicable legislation, regulations and or current business practices.

9. Use of Personal Information (PI)

In the instance where FlameBlock seeks to process and use personal information (PI) it holds for a purpose other than the original purpose for which it was collected, and where this secondary purpose is not compatible with the original purpose, FlameBlock will first obtain additional consent from their clients.

10. Safeguarding Personal Information (PI)

11. Access to Personal Information (PI)

FlameBlock clients can contact our designated Information Officer for assistance at the contact details provided.

12. Correction and De-identification of Personal Information (PI)

FlameBlock undertakes to adhere to these requests as soon as reasonably practicable based on applicable legislation, regulations and or current business practices.

13. Disclosure Personal Information (PI)

10. • FlameBlock employees, business Partners or consultants that require the information to fulfil their work duties;
    • FlameBlock suppliers and/or vendors that require the information to assist with the service provided;
    • FlameBlock courier partners to perform their courier tasks;
    • FlameBlock financial service providers and/or banking partners as required by banking and credit card association rules;
    • to law enforcement (if required to do so to protect FlameBlock’ rights);
    • other third parties from whom our clients have chosen to receive marketing information;
    • other companies’ entities in FlameBlock’ industry, that will enhance the services and products FlameBlock can offer to clients. This only applies where our clients have not objected to such sharing.