POPI Policy

Comms Partner (Pty) Ltd. is committed to complying with the Protection of Personal Information Act 4 of 2013 concerning the processing of your personal information. Protecting your privacy and that of our employees, suppliers and clients is very important to us. This policy will describe how and why we collect, store, share, or otherwise process personal information for employees, suppliers, and clients. It also explains your rights concerning your personal information and how to contact us if you have any questions or complaints.


“we”“us”, or “our” means COMMS PARTNER (PTY) LTD.

“Personal information” means information relating to an identifiable, living, natural person, and where it is applicable and identifiable, existing juristic person, including, but not limited to:

  • information relating to the race, gender, sex, pregnancy, marital status, national, ethnic, or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of the person;
  • information relating to the education or the medical, financial, criminal or employment history of the person;
  • any identifying number, symbol, email address, physical address, telephone number, location information, online identifier, or other particular assignments to the person;
  • the biometric information of the person;
  • the personal opinions, views or preferences of the person;
  • correspondence sent by the person that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence;
  • the views or opinions of another individual about the person; and
  • the name of the person if it appears with other personal information relating to the person or if the disclosure of the name itself would reveal information about the person;

“POPIA” means the Protection of Personal Information Act 4 of 2013, as amended from time to time;

“Processing” means any operation or activity or any set of processes, whether or not by automatic means, concerning personal information, including:

  • the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use;
  • dissemination through transmission, distribution or making available in any other form; or
  • merging, linking, as well as restriction, degradation, erasure, or destruction of information.


1.1 We may collect and process the following personal information about you:

  • Your name and contact information, including your email address, telephone number, physical address, postal address and other location information, erf number;
  • Your date of birth, age, gender, race, nationality, title and language preferences;
  • Your identity number, passport number and photograph;
  • Your vehicle registration number, vehicle licence and driving licence;
  • Your biometric information, including but not limited to, if applicable, that information obtained from your fingerprints, hands, facial recognition and/or retinal scanning;
  • Your verified banking details;
  • Your employment details;
  • Correspondence from you of a private or confidential nature;
  • such other personal information as is reasonably required by us to engage with you and/or provide services or employment to.


2.1 We may collect or obtain personal information about you: directly from you;

  • during our interactions with you;
  • when you visit the company;
  • when you visit and/or interact with our website or any other social media platforms or IT services;
  • from publicly available sources; and
  • from a third party who is authorised to share that information.


3.1  The personal information we may collect and why and how we use it depends on our relationship with;

3.2  POPIA requires that personal information “is collected for a specific, explicitly defined and lawful purpose related to a function or activity of the responsible”;

3.3  Further, POPIA provides that personal information may only be processed if:

  • the data subject or a competent person where the data subject is a child consents to the processing;
  • processing is necessary to carry out actions for the conclusion or performance of a contract to which the data subject is party;
  • processing complies with an obligation imposed by law on the responsible party;
  • processing protects a legitimate interest of the data subject;
  • processing is necessary for the proper performance of a public law duty by a public body; or
  • processing is necessary for pursuing the legitimate interests of the responsible party or of a third party to whom the information is supplied.

3.4  The table at Annexure hereto sets out a list of the types of information we collect and explains why we collect and use it;

3.5  We may collect other personal information from time to time where you provide it to us, as necessary for our business requirements, or to comply with applicable;

3.6  Where it is lawful and practicable for us to allow it, you have the right not to identify yourself when dealing with it. However, if you don’t provide us with your personal information, it may impact our ability to engage with you and/or provide services to you.


4.1 Depending on the circumstances, we may disclose your personal information to the following categories of persons:

  • Auditors, legal and other professional advisers and consultants of Comms Partner (Pty) Ltd. or other third parties who help us deliver our services;
  • Information Technology and other service providers who help us run the company or otherwise manage or store the personal information;
  • Government and law enforcement authorities;
  • Financial institutions;
  • Other third parties where disclosure is required by law or otherwise required for us to perform our obligations and provide our services; and
  • To any other person with your consent to the disclosure.

4.2  We take reasonable steps to protect the confidentiality and security of your personal information when it is disclosed to a third party and seek to ensure the third-party deals with your information in accordance with our instructions, applicable privacy laws, and only for the purpose for which it is.

  1. DATA SECURITY                                                                                                                               .

5.1  We may hold your personal information electronically or in hard copy. We may keep this information at our premises;

5.2  We are committed to keeping your personal information safe;

5.3  We use a range of physical, electronic, and procedural safeguards to do. We update these safeguards from time to time to address new and emerging security threats. We also train our people on privacy matters as appropriate and seek to limit access to personal information to those who need to know that information;

5.4   We implement appropriate security measures to protect your personal information that is in our possession against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, in accordance with applicable;

5.5  Where there are reasonable grounds to believe that your personal information that is in our possession has been accessed or acquired by any unauthorised person, we will notify the relevant regulator and you, unless a public body responsible for detection, prevention or investigation of offences or the relevant regulator informs us that notifying you will impede a criminal.

  1. HOW LONG YOUR PERSONAL INFORMATION WILL BE KEPT                                                    

6.1 We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service) or to comply with applicable legal, tax or accounting;

6.2 We shall only retain and store your personal information for the period for which the information is required to serve the purpose for its collection, or legitimate interest or the period required to comply with applicable legal requirements, whichever is.

  1. INTERNATIONAL TRANSFER OF PERSONAL INFORMATION                                                           

7.1 In some cases, the third parties to whom we may disclose your personal information may be located outside your country of residence (for example, in a cloud service, system, or server) and may be subject to a different privacy;

7.2 When we disclose personal information overseas, we will take appropriate safeguards to protect your personal information to ensure that the recipient will handle the information in a manner consistent with this policy and the level of protection provided for in.


8.1 You have the right to:

  • ask what personal information we hold about you;
  • request access to the personal information that we hold about you;
  • ask us to update, correct or delete any out-of-date or incorrect personal information we hold about you;
  • unsubscribe from any direct marketing communications we may send you; or
  • object to the processing of your personal information.

8.2 If you wish to exercise any of these rights or you have any queries regarding the personal information that we hold about you, you can contact us at the details provided;

8.3 To protect the integrity and security of the information we hold, we may ask that you follow a defined access procedure, including steps to verify your identity;

8.4 If you want us to delete all personal information about you, we may need to terminate the agreements we have in place. We can refuse to delete your information if required by law to retain it or protect our rights.

  1. HOW TO CONTACT US                            

9.1  If you have a question, concern, or complaint regarding how we handle your personal information, or if you believe that we have failed to comply with this policy or breached any applicable laws concerning the management of that information, you can submit a complaint;

9.2  Any question, concern or complaint or if you wish to request to access your personal information in terms of Section 23 of POPIA, should be made in writing to the Comms Partner (Pty) Ltd. information officer:

Information Officer: Claire Godden

Address: Waterview 2, First Floor, Suite 103, 1 Waterview Close, Century City, 7441, South Africa

Telephone number: +27 21 007-2109

Email: information-officer@commspartner.co.za