This Policy is applicable to all Data Subjects including permanent and contracted employees, customers, consultants, service providers / suppliers, operators, regulators, shareholders, directors, sub- contractors and agents, as well as all external parties who conduct business with us

1. To strive to take appropriate, reasonable, technical and organizational measures to secure the integrity and confidentiality of Personal Information in the Company possession or under its control.
2. To clarify what Personal Information we collects and the purpose of the processing of the Personal Information collected in relation to Data Subjects.
3. To clarify how we uses and protects the Personal Information of a Data Subject.
4. To stipulate the rights of a Data Subject in relation to their Personal Information.
5. To define retention periods for Personal Information and provide for the destruction of same after respective retention period(s) have lapsed.

1. Processing for purposes of this Policy is defined to mean any operation or activity or any set of operations, whether or not by automatic means, concerning Personal information, including:
   1. the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use;
   2. dissemination by means of transmission, distribution or making available in any other form; or
   3. merging, linking, as well as restriction, degradation, erasure or destruction of information.
2. Processing Limitation
   1. Personal Information must be processed lawfully and in a reasonable manner that does not infringe the privacy of the Data Subject.
   2. Personal Information may only be processed if, given the purpose for which it is processed, it is adequate, relevant and not excessive.
   3. May only process Personal Information if:
      1. The Data Subject (or a person who has been given authorisation by the Data Subject to provide
         the Data Subject’s Personal Information) consents to such processing;
      2. The Processing is necessary for the conclusion or performance of a contract;
      3. The Processing complies with a legal responsibility;
      4. The Processing protects a legitimate interest of the Data Subject;
      5. The Processing is necessary for the pursuance of a legitimate interest of RM or a third party to whom the information is supplied.
      6. Personal Information must be collected directly from the Data Subject, unless:
      7. The Data Subject consents to collection of information from another source;
      8. Personal Information is contained in a public record or has been deliberately made public by the Data Subject;
      9. Personal Information is collected from another source with the Data Subject’s consent;
      10. Collection of Personal Information from another source would not prejudice the Data Subject;
      11. Collection of Personal Information from another source is necessary to maintain, comply with or
          exercise any law or legal right;
      12. Collection from the Data Subject would prejudice the lawful purpose of collection;
      13. Collection from the Data Subject is not reasonably practicable.
3. Purpose Specification
   1. Personal Information must be collected for a specific, explicitly defined and lawful purpose related to a function or activity
   2. Records of Personal Information must not be retained any longer than is necessary for achieving the purpose for which the information was collected or processed for.
4. Further Processing Limitation
   
   1. Further processing of Personal Information must be in accordance or compatible with the original purpose of processing.
   2. Further processing will be regarded as compatible with the purpose of collection if:
   3. The Data Subject (or a person who has been given authorisation by the Data Subject to provide the Data Subject’s Personal Information) has consented to the further processing;
   4. Personal Information is contained in a public record or has been deliberately made public by the Data Subject;
   5. Further processing is necessary to maintain, comply with or exercise any law or legal right;
   6. Further processing is necessary to prevent or mitigate a threat to public health or safety, or the
      life or health of the Data Subject or a third party;
   7. The information is used for historical, statistical or research purposes.
5. Openness
   
   1. Shall take reasonable steps to ensure that the Data Subject is made aware of:
   2. What Personal Information is collected and / or the source from which the information is collected from;
   3. The name and address
   4. The purpose for which the information is being collected and processed for;
   5. Whether the supply of Personal Information is voluntary or mandatory;
   6. Consequences of a failure to provide the information;
   7. Whether collection is in terms of any law requiring such collection;
   8. Whether the Personal Information shall be transferred to a third party, another countryr an international organisation and the level of protection afforded to the information by that third party, country or  international organisation;