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Reg No: 2017/287927/07No. 6 HEATH CIRCLE, BLACKHEATH, 7580POSTNET SUITE #9, PRIVATE BAG X04, KUILSRIVER, 7579Tel: (021) 905 7338 Fax2mail: 086 604 2000www.sa-construction.co.zaPOPI POLICYINTRODUCTIONThe purpose of this policy is for SA Construction(Pty) Ltd to comply with the Protection of PersonalInformation Act, No.4 of 2013 (hereinafter referredto as the “POPI Act” or “the Act”). The POPI Act requires the Company tsandworkseekers (data subjects) of the purpose for which thecompany will process their personal information.Protect any information assets from threats,whether internal or external, deliberate ility, minimize businessdamage and maximize business opportunities.This policy sets out a compliance framework andestablishes measures and standards for theprotection and processing of personal informationwithin the Company. It further provides principlesregarding the right of an individual’s (data -subject)privacy and to reasonable safeguarding of theirpersonal information.POLICY APPLICATIONThis policy and its principles apply to the company’sowners, management, employees as well as allbranches, business units and divisions of thecompany. It further applies to all those acting onbehalf of the company.The policy’s guiding principles find application invarious situations and it’s important that it be readin conjunction with the Act and the Promotion ofAccess to Information Act no. 2 of 2000.The legal duty to comply with the Act and itsprovisions is required in any situation where thereis processing of: Personal information. Entered into a record. By or for a responsible person Who is domiciled in South Africa.The Act does not apply in situations where theprocessing of personal information is concluded inthe course of purely personal or householdactivities, or where the personal information hasbeen de-identifiedDATA SUBJECTS & THEIR RIGHTSIt is imperative for the company’s employees,clients and customers to be ensured that whereappropriate, the company will make all partiesaware of the rights as conferred upon them as datasubjects.The company will ensure that it gives effect to thefollowing rights namely:1.2.3.4.The Right to Access Personal InformationThe data subject has the right to establish whetherthe company holds personal information related tohim/her. This includes, but is not limited to, theright to request access to that information.The Right to have certain Personal InformationCorrected or DeletedThe data subject has the right to request, wherereasonable and necessary, that his or her personalinformation be corrected or deleted. This includesinstances where the company is no longer privy toinformation of the data subject.The Right that the Data Subject has to object to theProcessing of certain Personal InformationIt is to be borne in mind that the data subject hasthe right, be it on reasonable grounds, to object tothe processing of his/her personal information.Should a data subject object to the processing ofcertain personal information, the company will berequired to give due consideration to the requestand the requirements of the Act. The companymay, however, cease to use or disclose the datasubject’s personal information and may, subject toany statutory and contractual record keepingrequirements, also approve the destruction ofpersonal information.The Right to Object to Direct MarketingThe data subject has the definite right to object tothe processing of any of his/her personalinformation for the purposes of direct marketing bymeans of any unsolicited electronic communicationDIRECTORS: Julian Daniels, Diane Daniels, Nico Wilken, Heike Wilken, Cliff Swart
Reg No: 2017/287927/07No. 6 HEATH CIRCLE, BLACKHEATH, 7580POSTNET SUITE #9, PRIVATE BAG X04, KUILSRIVER, 7579Tel: (021) 905 7338 Fax2mail: 086 604 2000www.sa-construction.co.za5.6.(i.e. telemarketers contacting the data subject mymeans of telephonic calls, SMS’s or emails).The Right to Complain to the relevant InformationRegulatorThe data subject has the right to submit areasonable complaint to the company’s dulyappointed Information Regulator regarding analleged infringement of any of the rights protectedunder the Act and to institute civil proceedingsregarding the alleged non-compliance with theprotection of his/her personal information.The Right to be InformedThe data subject has the right to be informed thathis/her personal information is being collected bythe company. Furthermore, the data subject hasthe right to be notified in any situation where thecompany has reasonable grounds to believe thatthe personal information of the data subject hasbeen accessed or retained by an unauthorizedperson (i.e. server has been hacked andinformation compromised).3.GUIDING PRINCIPLESThe company, its employees and all persons actingon behalf of the company will at all times berequired to abide by, be subject to, and act inaccordance with the following principles:1.2.AccountabilityIt is extremely important to note that failing tocomply with the Act could potentially damage thecompany’s reputation or expose the company to acivil claim for damages incurred. The protection ofpersonal information rests on the shoulder of allemployees and should not be taken lightly. Thecompany will ensure that the provisions of the Actand the guiding principles as outlined in this policyare complied with.Furthermore, the company will take appropriatesteps, which may include, but are not limited todisciplinary actions, against those employees whothrough their intentional or negligent actions andor omissions, fail to comply with the principles andresponsivities outlined in this policy.Processing Limitations4.5.The company will ensure that the personalinformation of its data subjects is processed in away that is fair, lawful, in a non-excessive manner,with the necessary and informed consent of thedata subject and only for a specifically definedpurpose.The company will set out to inform the relevantdata subject of the reasons for collecting his/herpersonal information and obtain written consentprior to the processing of the information. Thecompany will under no circumstances distribute orshare personal information between separate legalentities, associated companies, or organizations orwith any individuals that are not directly involvedwith facilitating the purpose for which theinformation was originally collected.Where the company deems appropriate, the datasubject will be informed of the possibility thathis/her personal information will be shared with 3rdparties and be provided with reasons for doing so.SpecificationAll of the company’s departments/divisions andoperations must be informed by what is known asthe “principle of transparency”. The company willprocess personal information only for specific,explicitly defined and legitimate reasons. Thecompany will be responsible for ensuring that itsdata subjects are made aware prior to the collectingor recording of personal information.Further LimitationsIt is to be borne in mind that any and all personalinformation will not be processed for a secondarypurpose unless that said processing is compatiblewith the original purpose for which it was collected.Thus, where the company seeks to process personalinformation it holds for a purpose other than theoriginal purpose for which it was originallycollected, and where this secondary process is notcompatible with the original purpose, the companywill first obtain additional consent from the datasubject.Quality of Information CollectedThe company will take the necessary steps toensure that all personal information collected iscomplete, accurate, and not misleading.DIRECTORS: Julian Daniels, Diane Daniels, Nico Wilken, Heike Wilken, Cliff Swart
Reg No: 2017/287927/07No. 6 HEATH CIRCLE, BLACKHEATH, 7580POSTNET SUITE #9, PRIVATE BAG X04, KUILSRIVER, 7579Tel: (021) 905 7338 Fax2mail: 086 604 2000www.sa-construction.co.za6.7.Where personal information is collected from 3rdparties, the company will take reasonable steps toensure that the information is correct by verifyingthe accuracy of the information directly with thedata subject.Open CommunicationThe company will take reasonable steps to ensurethat data subjects are always notified that theirpersonal information is being collected – includingthe purpose for which it is being collected andprocessed. The company will ensure that it goesfurther to establish a facility (electronic help deskor provide an email address or phone number) fordata subjects who wish to enquire whether thecompany holds related personal information, orrequest access to related personal information, orrequest the company to update or correct personalinformation, or issue a complaint concerning theaccess or processing of personal information.Necessary Security SafeguardsThe company will manage the security of its filingsystem to ensure that personal information isadequately protected. Security controls will beimplemented in order to minimize any risk of loss,unauthorized access, disclosure, interference,modification or destruction.The company will ensure to continuously review itssecurity controls which will include inter alia,regular testing of protocols and measures put inplace to combat cyber-attacks on the company’s ITnetwork (i.e. server).The company will ensure that all paper andelectronic records comprising of personalinformation are securely stored and only madeaccessible to authorized individuals.All new employees will be required to sign contractscontaining contractual terms for the use andstorage of employee information. Confidentialityclauses will also be included in said contracts toreduce the risk of unauthorized disclosures ofpersonal information for which the company isresponsible. All existing employees will, after therequired consultation process has been followed,be required to sign an addendum to their8.employment contract containing the relevantconsent and confidentiality clauses.Data Subject ParticipationA data subject may as aforementioned, request thecorrection or deletion of his/her personalinformation held by the company. The company willensure that it provides a facility for data subjectswho wish to request the correction or deletion oftheir personal information.CORPORATEGOVERNANCEOFFICER(INFORMATION OFFICER)The Company will appoint a Corporate GovernanceOfficer (hereinafter referred as a “CGO”) and wherenecessary, a Corporate Governance Assistant toassist the CGO –The company’s CGO is responsible for ensuringcompliance with the Act.Where no CGO is appointed, the head of thecompany will automatically assume the role of theCGO. Consideration will be given on an annual basisto the re appointment or replacement of the CGOand the reappointment of the CGO’s Assistant.Once appointed, the company will be responsiblefor registering the Information Officer with theSouth African Information Regulator under the Actprior to performing his/her duties.DUTIES & RESPONSIBILITIESThe company’s CGO will be responsible for thefollowing: Take the necessary steps to ensure that thecompany’s compliance with the Act. Keeping the owners of the company updatedabout the company’s information protectionresponsibilities under the Act Analyzing privacy regulations and aligning suchregulations with the company’s personalinformation and the processing of suchinformation. To ensure that regular POPI audits arescheduled and conducted. Ensure that it is at all times for the datasubjects of the company to convenientlyupdate their information or lodge a complaint.DIRECTORS: Julian Daniels, Diane Daniels, Nico Wilken, Heike Wilken, Cliff Swart
Reg No: 2017/287927/07No. 6 HEATH CIRCLE, BLACKHEATH, 7580POSTNET SUITE #9, PRIVATE BAG X04, KUILSRIVER, 7579Tel: (021) 905 7338 Fax2mail: 086 604 2000www.sa-construction.co.za In cases where the company is dealing withignorance or minor negligence, the company willundertake to provide further awareness training tothe employee, however, any gross negligence orthe wilful mismanagement of personal information,will be considered a serious form of misconduct forwhich the organization may summarily dismiss theemployee.To approve any contracts entered into with 3rdparties which may have an impact on thepersonal information held by the company.To ensure that those acting on behalf of thecompany are fully acquainted with the risksassociated with the processing of personalinformation and that they remain informedabout the company’s security controls.To address employees on questions related tothe Act.To work with the Information Regulator inrelation to any ongoing investigations relatedto the breach of any personal information.POPI AUDITThe CGO along with a consultant from DanshawConsulting will schedule a full and comprehensivePOPIA audit. The purpose of the audit is to: Identify the processes used to collect,record, store, disseminate and destroypersonal information. Redefine the purpose for gathering andprocessing of personal information. Ensuring that the processing parametersare adequately limited. Ensure that any new data subjects aremade fully aware of the processing ofpersonal information. Verify the quality and security of personalinformation. Monitor the extent of compliance withthe Act and this policy. Monitor the effectiveness of all internalcontrols established to manage theorganizations POPI related compliancerisk.DISCIPLINARY ACTIONIn matters where a POPI complaint or infringementhas been finalized, the company may recommendany appropriate administrative, legal and/ordisciplinary action be taken against any employeereasonably suspected of being implicated in anynon-complaint activity as aforementioned.It is to be borne in mind that disciplinary procedureswill only commence where there is sufficientevidence to support an employee’s grossnegligence. Examples of immediate action to betaken subsequent to an investigation include, butare not limited to: Upon recommendation to commence withdisciplinary action. A referral to appropriate law enforcementagencies for criminal investigation, and Recovery of funds and assets to limitfurther prejudice or damages caused.1. 2.3.STORAGE OF DOCUMENTS – HARD COPIESThe Basic Conditions of Employment Act, No 75 of1997The Basic Conditions of Employment Act(hereinafter referred to as the “BCEA”) requires aretention period of 3 years for the documents asmentioned below:Section 29(4) – Written particulars of an employeeafter termination of employment.Section 31 – Employee’s name and occupation,time worked by each employee, remuneration paidto each employee and date of birth of anyemployee under the age of 18 years.Employment Equity Act, No 55 of 1998:Section 26 and the General AdministrativeRegulations of 2009 (Regulation 3(2)) requires theretention period of 3 years for the documents asmentioned below: Any record in respect of the company’sworkforce, employment equity and otherrecords relevant to compliance with the Act.Labour Relations Act, No 66 of 1995:DIRECTORS: Julian Daniels, Diane Daniels, Nico Wilken, Heike Wilken, Cliff Swart
Reg No: 2017/287927/07No. 6 HEATH CIRCLE, BLACKHEATH, 7580POSTNET SUITE #9, PRIVATE BAG X04, KUILSRIVER, 7579Tel: (021) 905 7338 Fax2mail: 086 604 2000www.sa-construction.co.za4.Sections 53(4), 98(4) and 99 require a retentionperiod of 3 years for thedocuments mentioned below: The relevant Bargaining Councilmust retain books of accounts,supporting vouchers, income andexpenditure statements, balancesheets, reports by auditors andminutes of all meetings. Registered Trade Unions andregisteredemployer’sorganizations must retain booksof accounts, supporting vouchers,incomeandexpenditurestatements, balance sheets,reports by auditors and minutesof all meetings. Registered Trade Unions andemployer’s organizations mustretain the ballot papers. Employers must retain allcollectiveagreementsandarbitration awards. Sections 99, 205(3), Schedule 8 of Section 5and Schedule 3 of Section 8(a) require anindefinite retention period for thedocuments as mentioned below: Registered Trade Unions andRegistered Employer’s Organizationsmust retain a list of its members. An employer must retain prescribeddetails of any past or present strike,lock-out or protest action involving itsemployees. Records of each employee specifyingthe nature of any disciplinaryactions/transgressions, the actionstaken by the employer and thereasons for the actions.Unemployment Insurance Act, No 63 of 2002:The Act, applies to all employees and employersexcept: Workers working less than 24 hours amonth. Learners. Public servants.Foreigners working on a contract basis.Workers who get a monthly pension.Workers who only earn commission.Section 56(2) (c) requires a retention periodof 5 years, from the date of submission forthe documentation as mentioned below:Employers must retain personal records of each oftheir current employees in terms of their names,identification number, monthly remuneration, andaddress where the employee is employed.ELECTRONIC STORAGE OF DOCUMENTSThe electronic storage of information – importantdocuments and information must be referred toand discussed with the designated IT officer(internal or external). He/she will be responsible forthe indexing, storage and retrieval of electronicdocuments containing personal information.If documents are scanned, the hard copy must alsobe retained for as long as the information is usedfor 1 year after the date of scanning, with theexception of documents pertaining to employees.Any and all documents containing information onthe written particulars of an employee, including anemployee’s name and occupation, time worked byeach employee, remuneration and date of birth ofan employee under the age of 18; must be retainedfor a period of 3 years after termination ofemployment.Sec 51 of the Electronic Communications Act No 25of 2005 (hereinafter referred to as the “ECT Act”)requires that personal information and the purposefor which the data was/is collected must be kept bythe individual who electronically requests, collects,collates, processes or stores the information and arecord of any 3rd party to whom the informationwas disclosed must be retained for a period of 1year for as long as the information is used. The Actfurther requires that all personal information whichbecomes obsolete must be destroyed.DESTRUCTION OF DOCUMENTSDIRECTORS: Julian Daniels, Diane Daniels, Nico Wilken, Heike Wilken, Cliff Swart
Reg No: 2017/287927/07No. 6 HEATH CIRCLE, BLACKHEATH, 7580POSTNET SUITE #9, PRIVATE BAG X04, KUILSRIVER, 7579Tel: (021) 905 7338 Fax2mail: 086 604 2000www.sa-construction.co.zaEach department within the company is responsiblefor attending to the destruction of its documents,this must be done on a regular basis. Files must bechecked in order to ensure that they may bedestroyed and also to ascertain if there areimportant original documents in the file. All originaldocuments must be returned to the holder thereof,failing which, they should be retained by theCompany pending such return.After the process as aforementioned, the managerof the department shall, in writing, authorize theremoval and destruction of the documents.The documents are then to be made available forcollection by the necessary removers of theCompany’s documents, who also ensure that thedocuments are shredded before disposal. This alsohelps to ensure confidentiality of information.Alternatively, documents may be stored off-site, instorage facilities approved by the company.CONSENTWHEREAS IT IS AGREED THAT,By signature hereunder, all parties irrevocablyagree to abide by the terms and conditions as setout in this agreement as well as you irrevocablyagree and acknowledge that all informationprovided, whether personal or otherwise, may beused and processed by the company and such usemay include placing such information in the publicdomain.Further it is specifically agreed that the companywill use its best endeavors and take all reasonableprecautions to ensure that any informationprovided, is only used for the purposes it has beenprovided. It is agreed that such information may beplaced in the public domain and by signaturehereunder, all parties acknowledge that they haveread all of the terms in this policy and that theyunderstand and agree to be bound by the termsand conditions as set out in this agreement.PRIVACY POLICYPrivacy PolicyLast updated: August 31, 2021This Privacy Policy describes Our policies andprocedures on the collection, use and disclosure ofYour information when You use the Service andtells You about Your privacy rights and how the lawprotects You.We use Your Personal data to provide and improvethe Service. By using the Service, You agree to thecollection and use of information in accordancewith this Privacy Policy. This Privacy Policy has beencreated with the help of the Privacy PolicyGenerator.Interpretation and DefinitionsInterpretationThe words of which the initial letter is capitalizedhave meanings defined under the followingconditions. The following definitions shall have thesame meaning regardless of whether they appearin singular or in plural.DefinitionsFor the purposes of this Privacy Policy:Account means a unique account created for You toaccess our Service or parts of our Service.Company (referred to as either "the Company","We", "Us" or "Our" in this Agreement) refers to SAConstruction Group Companies (SA Construction(Pty) Ltd, Nejeni Construction and ProjectManagement (Pty) Ltd, Umdla Civils (Pty) Ltd,WeConstruct (Pty) Ltd, Sidinga Suppliers (Pty) Ltd,Blackheath, Western Cape.Cookies are small files that are placed on Yourcomputer, mobile device or any other device by awebsite, containing the details of Your browsinghistory on that website among its many uses.Country refers to: South AfricaDevice means any device that can access theService such as a computer, a cellphone or a digitaltablet.DIRECTORS: Julian Daniels, Diane Daniels, Nico Wilken, Heike Wilken, Cliff Swart
Reg No: 2017/287927/07No. 6 HEATH CIRCLE, BLACKHEATH, 7580POSTNET SUITE #9, PRIVATE BAG X04, KUILSRIVER, 7579Tel: (021) 905 7338 Fax2mail: 086 604 2000www.sa-construction.co.zaPersonal Data is any information that relates to anidentified or identifiable individual.Service refers to the Website.Service Provider means any natural or legal personwho processes the data on behalf of the Company.It refers to third-party companies or individualsemployed by the Company to facilitate the Service,to provide the Service on behalf of the Company, toperform services related to the Service or to assistthe Company in analyzing how the Service is used.Usage Data refers to data collected automatically,either generated by the use of the Service or fromthe Service infrastructure itself (for example, theduration of a page visit).Website refers to SA Construction Group ction.co.zaYou means the individual accessing or using theService, or the company, or other legal entity onbehalf of which such individual is accessing or usingthe Service, as applicable.When You access the Service by or through amobile device, We may collect certain informationautomatically, including, but not limited to, thetype of mobile device You use, Your mobile deviceunique ID, the IP address of Your mobile device,Your mobile operating system, the type of mobileInternet browser You use, unique device identifiersand other diagnostic data.We may also collect information that Your browsersends whenever You visit our Service or when Youaccess the Service by or through a mobile device.Tracking Technologies and CookiesWe use Cookies and similar tracking technologies totrack the activity on Our Service and store certaininformation. Tracking technologies used arebeacons, tags, and scripts to collect and trackinformation and to improve and analyze OurService. The technologies We use may include: Collecting and Using Your Personal DataTypes of Data CollectedPersonal DataWhile using Our Service, We may ask You to provideUs with certain personally identifiable informationthat can be used to contact or identify You.Personally identifiable information may include,but is not limited to: Email address First name and last name Usage DataUsage DataUsage Data is collected automatically when usingthe Service.Usage Data may include information such as YourDevice's Internet Protocol address (e.g. IP address),browser type, browser version, the pages of ourService that You visit, the time and date of Yourvisit, the time spent on those pages, unique deviceidentifiers and other diagnostic data. Cookies or Browser Cookies. A cookie is asmall file placed on Your Device. You caninstruct Your browser to refuse all Cookiesor to indicate when a Cookie is being sent.However, if You do not accept Cookies,You may not be able to use some parts ofour Service. Unless you have adjusted Yourbrowser setting so that it will refuseCookies, our Service may use Cookies.Flash Cookies. Certain features of ourService may use local stored objects (orFlash Cookies) to collect and storeinformation about Your preferences orYour activity on our Service. Flash Cookiesare not managed by the same browsersettings as those used for BrowserCookies. For more information on how Youcan delete Flash Cookies, please read"Where can I change the settings fordisabling, or deleting local ORS: Julian Daniels, Diane Daniels, Nico Wilken, Heike Wilken, Cliff Swart
Reg No: 2017/287927/07No. 6 HEATH CIRCLE, BLACKHEATH, 7580POSTNET SUITE #9, PRIVATE BAG X04, KUILSRIVER, 7579Tel: (021) 905 7338 Fax2mail: 086 604 2000www.sa-construction.co.zaflash.html#main Where can I change the settings for disabling or deleting local shared objects Web Beacons. Certain sections of ourService and our emails may contain smallelectronic files known as web beacons(also referred to as clear gifs, pixel tags,and single-pixel gifs) that permit theCompany, for example, to count users whohave visited those pages or opened anemail and for other related websitestatistics (for example, recording thepopularity of a certain section andverifying system and server integrity).Cookies can be "Persistent" or "Session"Cookies. Persistent Cookies remain on Yourpersonal computer or mobile device when Yougo offline, while Session Cookies are deleted assoon as You close Your web browser. Learnmore about cookies: Cookies: What Do TheyDo?.We use both Session and Persistent Cookies for thepurposes set out below:Necessary / Essential CookiesType: Session CookiesAdministered by: UsPurpose: These Cookies are essential to provide Youwith services available through the Website and toenable You to use some of its features. They help toauthenticate users and prevent fraudulent use ofuser accounts. Without these Cookies, the servicesthat You have asked for cannot be provided, andWe only use these Cookies to provide You withthose services.Cookies Policy / Notice Acceptance CookiesType: Persistent CookiesAdministered by: UsPurpose: These Cookies identify if users haveaccepted the use of cookies on the Website.Functionality CookiesType: Persistent CookiesAdministered by: UsPurpose: These Cookies allow us to rememberchoices You make when You use the Website, suchas remembering your login details or languagepreference. The purpose of these Cookies is toprovide You with a more personal experience andto avoid You having to re-enter your preferencesevery time You use the Website.For more information about the cookies we use andyour choices regarding cookies, please visit ourCookies Policy or the Cookies section of our PrivacyPolicy.Use of Your Personal DataThe Company may use Personal Data for thefollowing purposes:a)To provide and maintain our Service,including to monitor the usage of ourService.b) To manage Your Account: to manage Yourregistration as a user of the Service. ThePersonal Data You provide can give Youaccess to different functionalities of theService that are available to You as aregistered user.c)For the performance of a contract: thedevelopment,complianceandundertaking of the purchase contract forthe products, items or services You havepurchased or of any other contract with Usthrough the Service.d) To contact You: To contact You by email,telephone calls, SMS, or other equivalentforms of electronic communication, suchas a mobile application's push notificationsregarding updates or es, products or contractedDIRECTORS: Julian Daniels, Diane Daniels, Nico Wilken, Heike Wilken, Cliff Swart
Reg No: 2017/287927/07No. 6 HEATH CIRCLE, BLACKHEATH, 7580POSTNET SUITE #9, PRIVATE BAG X04, KUILSRIVER, 7579Tel: (021) 905 7338 Fax2mail: 086 604 2000www.sa-construction.co.zaservices, including the security updates,when necessary or reasonable for theirimplementation.e) To provide You with news, special offersand general information about othergoods, services and events which we offerthat are similar to those that you havealready purchased or enquired aboutunless You have opted not to receive suchinformation.f)To manage Your requests: To attend andmanage Your requests to Us.g)For business transfers: We may use Yourinformation to evaluate or conduct amerger,divestiture,restructuring,reorganization, dissolution, or other saleor transfer of some or all of Our assets,whether as a going concern or as part ofbankruptcy, liquidation, or similarproceeding, in which Personal Data heldby Us about our Service users is among theassets transferred.h) For other purposes: We may use Yourinformation for other purposes, such asdata analysis, identifying usage trends,determining the effectiveness of ourpromotional campaigns and to evaluateand improve our Service, products,services, marketing and your experience.We may share Your personal information in thefollo
Tel: (021) 905 7338 Fax2mail: 086 604 2000 www.sa-construction.co.za Daniels, Diane Daniels, Nico Wilken, Heike Wilken, Cliff Swart Where personal information is collected from 3rd parties, the company will take reason able steps to ensure that the information is correct by verifying the accuracy of the information directly with the data .
