POPI Policy

Kruinkloof Bushveld Estate Homeowners Association NPC
Protection of Personal Information (POPIA) Policy
August 2022

Kruinkloof Bushveld Estate Homeowners Association NPC (“the HOA”) is a not for profit
company that represent the home owners of the estate known as Kruinkloof Bushveld Estate
(“the Estate”). The HOA is responsible to ensure the smooth running of the Estate.

The Protection of Personal Information Act No. 4 of 2013 (“POPIA”) aims to give effect to the
constitutional right to privacy by safeguarding personal information and regulates the manner
in which personal information must be processed. This policy explains how we will obtain,
use, secure and disclose your personal information as required by POPIA..

In respect of the circumstances to which the privacy policy applies, the HOA is the responsible
party and is responsible for your personal information, (collectively referred to as the HOA,
“we”, “us” or “our” in this privacy policy).
The HOA is obliged to comply with POPIA.

We have appointed an information officer (IO) who is responsible for overseeing questions in
relation to your personal information and this privacy policy. If you have any questions about
this privacy policy, including any requests to exercise your legal rights, please contact the IO
using the details set out in this privacy policy.

The information we collect
Personal information means information about a natural or juristic person from which that
person can be identified. Information where the identity of the subject has been removed or
de-identified does not fall within the scope of POPIA.

Section 9 of POPIA states that “Personal Information may only be processed if, given the
purpose for which it is processed, it is adequate, relevant and not excessive.”
We collect and process your personal information to provide you with access to the Estate,
ensure the required security is in place and optimize the quality of the service that you receive
from the HOA. Examples of the personal information that we collect include, but are not
limited to:

1. Identification which includes: first name, surname, title, gender, marital status, nationality.
2. Date of birth, identity number and passport number if applicable.
3. Date joined the HOA.
4. Email address, mobile telephone number and passwords if required.

5. The Estate is equipped with security cameras around the perimeter wall and gate,
when you access the Estate the camera records your movements as you enter and

Special Personal Information

We do not collect special personal information about you (this includes details about your
race, ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political
opinions, trade union membership, information about your health, and biometric
information. We do not collect information in respect of criminal convictions and

If you fail to provide personal information
In circumstances where we need to collect personal information by law, or under the terms
of the engagement with you, and you fail to provide that information when requested, we
may not be able to perform the engagement we have with you. In this case, we may not be
able to proceed with a particular engagement we have with you, however we will notify you
if this is the case at the time of the collection or request for information.

We will process your personal information in line with the following
POPIA conditions
1. Accountability: HOA ensures that the conditions set out in POPIA, and all the measures
that give effect to such conditions, are complied with at the time of the determination
of the purpose and means of the processing and during the processing itself.
2. Processing limitation: Personal information may only be processed in a fair and lawful
manner and only with your consent.
3. Purpose specific: Personal information may only be processed for specific, explicitly
defined, and lawful purpose, and related to a function or activity of the HOA.
4. Further processing limitation: Personal information may not be processed for a
secondary purpose unless that processing is compatible with the original purpose.
5. Information quality: DZHOA must take reasonably practical steps to ensure that the
personal information collected is complete, accurate, not misleading and updated
where necessary.
6. Openness: You, as a data subject whose information we are collecting, must be aware
that we are collecting such personal information and for what purpose the
information will be used. Signage and notices are displayed at entrance gates and
offices to raise awareness.
7. Security safeguards: HOA takes appropriate, reasonable technical and organisational
measures to ensure that personal information is kept secure against the risk of loss,
unlawful access, interference, modification, unauthorized destruction, and disclosure.

8. Data subject participation: HOA recognises your right to confirmation, access,
correction, destruction, or deletion of personal information, as well as your right to

How we use your information
We use your personal information only for the purpose of rendering services to you and for
the purpose for which it was collected or agreed with you, for example:
1. To effectively provide services to you;
2. To communicate with you regarding the use of the Estate;
3. To provide support to you regarding the use of the Estate;
4. To detect and prevent security breaches and other malicious activities;
5. To comply with auditing and record-keeping requirements;
6. To comply with legal and regulatory requirements;
7. To confirm and verify your identity; and
8. To share information with service providers with whom the HOA has a business
agreement to process such information on the HOA’s behalf or with those who render
services to the HOA.

Disclosure of personal information
The HOA may engage with other organisations or service providers to provide support
services to the HOA , and we may disclose your personal information to these third parties.
Third parties are obliged to respect the confidentiality of any personal information held by
the Company. Service level agreements are in place with all third parties to ensure that all
service providers comply with these privacy terms.
We may also disclose your information where we have a legal obligation or duty to disclose
your information or where it is necessary to protect our legal rights.

Cross-border transfer of personal information
We may transfer your personal information outside the Republic of South Africa for
processing and storage.

How we secure your information
The HOA are obliged by POPIA to provide adequate protection for the personal information
that we hold and to avoid unauthorised access and use of your personal information. The
HOA continually review our security controls and related processes to ensure that your
personal information is secure.

Unfortunately, no data transmission over the internet can be guaranteed to be totally secure,
however, the HOA will endeavor to take all reasonable steps to protect the personal
information which you submit to the HOA or to the HOA online services.
When we contract with third parties, we impose appropriate security, privacy and
confidentiality obligations on them to ensure that your personal information is kept secure.
The HOA may need to transfer your personal information to another country for processing
or storage. The HOA will ensure that anyone to whom we pass your personal information
agrees to treat this information with a similar level of protection as afforded to you by the

Retention of your personal information
We will only retain your personal information for as long as reasonably necessary to fulfil the
purposes we collected it for or subsequently processed, unless: the retention of the information is required or authorized by any legal or regulatory requirements, we require the information for lawful purposes relating to one of our functions or activities, we require the
information for the purposes of fulfilling our engagement with you or you consent to such
retention of information.

Your rights to access and correction of information
You have the following rights under applicable privacy laws in relation to your personal
Notification that your personal information is being collected;
Notification of any security compromises to your personal information;
Request to access to your personal information. You have the right to confirm, at no
additional cost, whether or not we hold any of your personal information and where we hold
such information you may request a copy or description of that record for a prescribed fee;
Request correction of your personal information;
Requestion destruction or deletion of your personal information;
Object to processing of your personal information;
Request restriction of processing your personal information;
Withdraw consent to processing of your personal information;
Submit a complaint to the Information Regulator in terms of POPIA; and
Institute civil proceedings against us where you believe we have violated your rights.

If you wish to exercise any of your rights set out above, please contact us. You can do this by
contacting the HOA at +27 82 5540806 or admin@kruinkloof.co.za. We will take all
reasonable steps to confirm your identity before sharing personal information with you.
Please note that any such requests may be subject to a payment of a legally allowable fee.

Changes to this policy
We may amend this policy from time to time. It is your responsibility to check the policy
periodically to inform yourself of any changes. Where material changes take place, you will
be notified directly if we have been provided with your contact details.

How to contact us
Please contact Attie Pretorius the Estate Information Officer at +27 825540806 or
admin@kruinkloof.co.za if you
• Have any questions about this policy;
• Have reason to believe that we did not adhere to this policy;
• Need further information about our privacy practices; or
• Wish to give or withdraw consent, exercise preferences or access or correct your
personal information.



The PAIA Regulations prescribe the format in which persons may make an information
request and the format in which the organisation is required to respond to the request.
To request information from our organisation in terms of the Promotion of Access to
Information Act, please make use of the hyper link (click on the section underlined in blue) in
the following Form 02: Request for Access to Record [Regulation 7]
Our response will be given in the format of form Form 03: Outcome of request and of fees payable [Regulation 8]