POPI Policy

Kruinkloof Bushveld Estate Homeowners Association NPC
Protection of Personal Information (POPI) Policy
15 June 2021

Introduction
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 (“the Act”) 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 the Act.
The HOA is obliged to comply with the Act.

The information we collect
Section 9 of the Act 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
exit.

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 Association.
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 take 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 recognise your right to confirmation, access,
correction, destruction, or deletion of personal information, as well as your right to
objection.

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 Company has a business
agreement to process such information on the Company’s behalf or with those who
render services to the Company.

Disclosure of personal information
The Company may engage with other organisations or service providers to provide support
services to the Company, 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.

How we secure your information
The HOA are obliged by the Act 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
HOA.

Your rights to access and correction of information
You have the right to request a copy of the personal information that we hold about you.
You also have the right to ask us to update, correct or delete your personal information. You
can do this by contacting the HOA at +27 82 414 6402 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 Bernard Kaizer the Estate Information Officer at +27 83 440 8366 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.