The purpose of this policy is to ensure that Global Choices adheres to the requirements as set out in the Protection of Personal Information Act 4 of 2013 (POPI Act), which relates to the handling, use, processing and protection of a data subjects’ personal information.

Global Choices is committed to ensuring that all our operations relating to the processing of personal information complies with the POPI Act in the interest of protecting our organisations, our clients and our business partners.

 

This policy provides guidelines on the management and processing of personal information within Global Choices, as well as the rights of our clients to the protection of their personal information.

This policy will be reviewed annually to ensure that it continues to meet its purpose.

'Data subject’ means the person to whom the personal information relates to. Also referred to as client in this policy.

‘POPI Act’ means the Protection of Personal Information Act 4 of 2013.

‘Consent’ means any voluntary, specific and informed expression of will in terms of which permission is given for the processing of personal information.

‘Personal information’ means information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person and defined in the POPI Act.

Condition 1: Accountability

Global Choices undertakes to comply with the requirements of the POPI Act in the processing of personal information.

 

We will take reasonable steps to ensure the adequate storage protection of all personal information that we have access to in the daily operation of business.

Condition 2: Processing Limitation

Global Choices commits to the lawful processing of personal information.

 

Every effort is made to ensure that the processing of personal information is done in a manner that does not infringe the privacy of the data subject. All personal information in our possession will only be processed for its indented purpose. Due to the nature of our business, in which all our clients are pre-existing clients of our business partners, we inherit the consent of a data subject to process their personal information through the data subject’s relationship with our business partners. The personal information is necessary for our operation and as such we rely on our business partners to obtain consent in a lawful manner before sharing this information with Global Choices.

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We collect data directly from a data subject only, when necessary, in order to perform our functions, this data is only used for its intended purpose and is stored and protected in the same manner as personal information acquired from our business partners.

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Condition 3: Purpose specification

All personal information acquired from business partners is used for the verification of a data subject as a policyholder of the relevant business partner. All personal information collected from a data subject is for the purpose of providing the relevant Global Choices service to the data subject at that time or to enable Global Choices to provide a better level of service in the future. All data is retained according to arrangement with our business partners in line with the relevant laws regarding the retention and destruction of personal information.

All personal information that has reached its life span or is no longer required by Global Choices in order to perform our operations is discarded as soon as it is no longer required.

Condition 4: Further Processing Limitation

Further processing of personal information will not be conducted if it is not in compliance with the POPI Act. We only collect information for the verification of policies and to provide our services to clients, and all personal information will only be processed for this reason.

Condition 5: Information Quality

We have agreements in place with all our business partners to provide us with updated personal information on a regular basis in order to ensure that all personal information is accurate and complete.

Any information not required for our operations is deleted. Where necessary, we also verify personal information with the data subject to ensure that all personal
information is kept updated as often as possible.

Condition 6: Openness

Global Choices does rely on our business partners to inform data subjects that their personal information is being shared with Global Choices and the purpose thereof.

 

Global Choices is also committed to being transparent to a data subject regarding the type of personal information that we have as well as what this information is used for.

Condition 7: Security Safeguards

Global Choices makes use of various security measures to ensure the protection of personal information.

All personal information received from our business partners is encrypted, and we ensure that only authorised Global Choices employees have access to the personal information through system control and user rights. Agents do not have access to amend any of the personal information.

We make use of virus protection and other IT security measures to combat any potential cyber threats to our systems.

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Condition 8: Data Subject Participation

All data subjects are entitled to know what personal information Global Choices has in our possession as well as what this information is used for. Each data subject is also entitled to know who in Global Choices has access to their personal information.

Each data subject is also allowed to correct any incorrect information that we have, or to request for Global Choices to delete any personal information provided that this personal information in not required by Global Choices to perform any of our services. This information will only be made to a data subject once they have provided proof of identification, as is made available without any cost to the data subject

Monitoring

The Global Choices Management team is responsible for the oversight and management of this policy.

An external IT company has been appointed to manage our security controls. Global Choices will conduct internal and external audits across all functions on a periodic basis to ensure compliance with the POPI Act. All Global Choices employees will be trained on this policy to ensure adherence to the POPI Act.

Security Controls

Global Choices employs various security controls to ensure the protection of personal information:

 

• We have McAfee virus protection software; the software also provides data leak and anti-ransom software.

• All user passwords are changed every 60 days, with set criteria for new passwords.

• Security training is provided to all employees.

• All remote access is controlled through a VPN.

• We have Active Directory and Office 365 for password protection.

• Firewalls are in place for web security, with access to only pre-approved sites given to employees.

• Active Directory Group policies with prohibit the installed of software without authorized administration privileges.

• Mimecast for e-mail security.

Breaches

Any breach of the POPI Act may result in disciplinary action.

Global Choices has appointed an Information Officer: Pieter Wilhelm van der Merwe- CEO

The Information Officer has been appointed as per Section 55 of the POPI Act, the responsibilities of the Information Officer include –

 

• The encouragement of compliance by Global Choices, with the conditions for the lawful processing of personal information;

• Dealing with request made pursuant to this Act. Requests may come from the Regulator, and other legal body or a data subject;

• Working with the Regulator in relation to investigations conducted pursuant to Chapter 6 of the POPI Act;

• Ensuring that Global Choices complies with the POPI Act;

• As may be prescribed by the Regulator.