SOCIETA DANTE ALIGHIERI CAPE TOWN – DATA PROTECTION / PRIVACY NOTICE
Società Dante Alighieri Cape Town (hereafter named SDA), a non-profit organisation located at 137 Hatfield Street, Gardens, Cape Town, has the main purpose of promoting the Italian language and culture by offering Italian language courses and other language and cultural services & cultural events.
SDA recognises the importance of protecting your privacy and is committed to protecting and preserving your personal information in accordance with the Protection of Personal Information Act 4 of 2013 (“POPI Act”).
This data protection notice (referred to as “Notice”) describes how SDA collects, records, sorts, uses, stores, updates, shares and transfers (referred to as “Processing”) information relating directly or indirectly to SDA’s employees, students, student’s parents and/or guardians and service providers (referred to as “you”) during their relationship with SDA.
This Notice applies to all SDA employees, students, students’ parents and/or guardians and service providers (referred to as “you”).
1. INFORMATION WE COLLECT
Information about you (referred to as your “Personal Information”) is any data or information relating directly or indirectly to you, from which you would be directly or indirectly identifiable.
1.1 PERSONAL INFORMATION
SDA may, depending on its relationship with you (i.e., whether you are an employee, student, student’s parent and/or guardian or a service provider), and subject to compliance with the Data Protection Laws, collect personal information such as:
• Personal contact details such as: name and surname, title, address, telephone number and email address
• Identification number;
• Date and place of birth;
• Gender;
• Marital status;
• Photographs;
• Academic/education history;
• Attendance record;
• Banking details;
• Tax information;
• Pension fund details;
• Salary, annual leave, pension, and benefits information;
• Previous employment records (including job title, dates and places of employment, working hours, absence record, training records and professional memberships);
• Information about your partner/spouse/husband/children (name, surname, date of birth, nationality, photographs, gender, etc.);
• Recruitment information (including copies of right to work documentation, visa, references and other information included in your curriculum vitae and/or cover letter and/or as part of your application process);
• Work and academic performance;
1.1 SPECIAL PERSONAL INFORMATION
Special Personal Information is information (1) revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or (2) concerning health, a natural person’s sex life or sexual orientation. Such Special Personal Information also includes genetic and biometric data, as well as information relating to criminal convictions and offences.
Depending on your particular relationship with Dante Alighieri Cape Town, your Special Personal Information may from time to time be collected, subject to compliance with the Data Protection Laws, if this is necessary to carry out Dante Alighieri Cape Town’s legal obligations.
When authorised by the Data Protection Laws, such Special Personal Information may include, but is not limited to:
• Information about your own or your children’s health, including medical conditions, medical records, disability status. This is to ensure your health and safety in the workplace/classroom and to assess your fitness to participate, work, to provide appropriate workplace/classroom adjustments, to monitor and manage absences due to illness and to administer financial benefits including statutory parental leave, statutory sick leave, and pensions;
• Information about your relatives’ health, only when it is legitimate and proportionate to the collection of such data (i.e., to justify your absence from work due to your child’s illness);
• Personality profiling permitting an assessment of the essential characteristics of an employee’s personality;
• Information about your race or ethnic origin, only when it is legitimate and proportionate to the collection of such data (e.g., for BEEE reports, skills development, employment equity, etc.);
• Information about your trade union membership, only when it is legitimate and proportionate to the collection of such data; and
• Information about criminal convictions and offences, only if it is appropriate given the nature of the role and only where SDA is legally permitted to do so.
2. HOW DO WE COLLECT YOUR PERSONAL INFORMATION
SDA may collect personal information from you in the course of:
• our relationship with you;
• rendering our services to you; and
• our marketing activities.
SDA only collects personal information that is adequate, necessary, relevant, and is not excessive.
3. HOW WE USE YOUR PERSONAL INFORMATION
Depending on your relationship with SDA, your Personal Information will be used as required in the scope of SDA’s relationship with you, to comply with applicable laws and regulations as well as for the pursuit of SDA’s legitimate interest/s.
More specifically SDA processes your personal information for the following purposes (referred to as “Purpose/s”):
• to provide our services to you;
• to administer, manage and develop such services;
• to confirm, verify and update your details from time to time;
• to provide marketing material to you including our newsletters, our mailings, our digital marketing campaigns and/or any other marketing activities;
• to conduct market or customer satisfaction research or for statistical analysis;
• for audit and record keeping purposes;
• in connection with legal proceedings;
• to provide communication in respect of any business, legal or regulatory matters that may affect you.
If Dante Alighieri Cape Town considers that it needs to use Your Personal Information for a reason incompatible with the above mentioned Purposes, SDA will notify you and explain why Your Personal Information is needed for such other Purpose. If Your Personal Information was processed on the basis of your consent, you will be asked to provide your consent again.
Dante Alighieri Cape Town will take reasonable measures to ensure Your Personal Information is correct and up-to-date, and you may request its correction at any time.
4. RETENTION OF PERSONAL INFORMATION
Records of your personal information will not be retained or stored for any longer than is necessary for achieving the purpose for which such information was collected or subsequently processed in accordance with Data Retention Storage and Disposal Policy and any applicable laws.
5. DISCLOSURE OF YOUR PERSONAL INFORMATION
Dante Alighieri Cape Town will only disclose Your Personal Information to:
• National authorities when required by law;
• Third parties Processing Your Personal Information on behalf and under the supervision of SDA, where required by applicable laws and/or regulations or where SDA has a legitimate interest in doing so;
• Third parties in the event of the sale, merger and/or reorganisation of SDA;
SDA shall require third parties to take appropriate security measures to protect Your Personal Information and to treat it in accordance with the Data Protection Laws.
We may transfer Your Personal Information outside of the Republic of South Africa. When doing so, you can expect a similar degree of protection in respect of Your Personal Information than that which SDA provides.
6. SECURITY MEASURES
SDA will implement appropriate technical and organisational security measures to protect Your Personal Information against any accidental or illegal destruction, accidental loss, alteration, unauthorised disclosure, or unauthorised access, and against any illegal means of Processing.
7. WHAT ARE YOUR RIGHTS IN CONNECTION WITH YOUR PERSONAL INFORMATION?
Under certain circumstances, in accordance with the Data Protection Laws, you have the right to:
• request access to Your Personal Information held by SDA;
• object to the processing of your personal information;
• withdraw your consent to the processing of your personal information;
• withdraw your consent to receive any marketing material;
• request the correction or amendment of incorrect personal information held by SDA;
• request deletion of your personal information held by SDA;
• restrict the processing of your personal information held by SDA;
• request receipt by SDA, or transfer from SDA, of your personal information from or to another organisation; and
• seek relief to your local data protection authority should any of your privacy rights be violated.
8. DIGITAL MEDIA
SDA uses emails and social media to keep in touch with its audience, providing them with newsletters where possible.
A subscriber’s email address, name and other contact details may be added to the newsletter mailing list if an individual has subscribed themselves, or has asked us to add their details to receive our newsletter, or if the individual has had meaningful interactions with Dante Alighieri in the past and expressed interest in keeping in touch..
Should you wish to Unsubscribe from our mailing list, we may retain limited information sufficient to identify you so that we can honour your opt-out request.
If you wish us to update or remove your details manually please email info@ladante.co.za or office@ladante.co.za to request this.
If you wish to no longer receive only certain communications, please identify such communications in your request.
SDA uses the Google suite of applications for certain business processes such as data processing and storage. Our accounts are secured through strong password protection and antivirus solutions.
If SDA interacts with an individual via electronic mediums, the data the individual has chosen to share with SDA will be stored on its systems unless the individual specifically requests deletion of confidential data (and if SDA is legally able to delete the data.)
SDA has profiles on social media such as Facebook, Instagram and Twitter. These platforms track users, and the information as to what data they may keep can be found on each platform’s terms of use and/or privacy policies.
SDA has a website, ladante.co.za which is hosted on Xneelo.co.za using the WordPress platform, owned by Automattic. This platform’s cookies may track a visitor’s interactions with the site as part of its analytics system. More information about what visitor’s data is tracked and retained can be found on Automattic privacy notice.
9. SECURITY AND NOTIFICATION
SDA will take all appropriate and reasonable technical and organisational security measures to protect your personal information that is in our possession to prevent loss, damage, unauthorised alteration or destruction of your personal information or unlawful access to or processing of your personal information in accordance with the applicable law. Only authorised persons are provided access to your personal information and such individuals have agreed to maintain the confidentiality of this information.
Should we reasonably believe that your personal information has been unlawfully accessed or acquired by any unauthorised persons, we will notify the relevant regulator and yourself, unless we are made aware that notifying you will impede a criminal investigation.
10. HOW YOU MAY EXERCISE YOUR RIGHTS
Should you wish to exercise your rights relating to this Notice, please contact SDA’s Information Officer at info@ladante.co.za