Privacy

Policy

Empowering the community to protect itself.

1. Purpose of this Privacy Policy

   1. The Community Security Organisation (NPO Registration number 2018/497653/08) “CSO“, “We“, “Us“, or “Our“)” is committed to safeguarding the privacy and the confidentiality of all of your Personal Information. It is important that you are aware of how We collect and process your Personal Information, and for what purpose We use your Personal Information.
   2. This Privacy Policy (“Policy“) describes how and when We collect, use, and share your Personal Information and applies to all Personal Information collected by CSO in whichever manner or form.
   3. Personal Information includes Special Personal Information and Personal Information of both natural persons and legal entities.
   4. If you have questions about this Privacy Policy, please send an email to Our Information Officer Jevon Greenblatt at popia@cso.org.za

2. To whom does this policy apply

   This Policy applies to all external parties with whom We engage as part of Our operations and provision of services including (“Data Subjects” / “You” / “Your“) –

   1. Rabbis, community leaders, youth movements (leadership, participants, parents, staff);
   2. users of all services offered by CSO
   3. members of the Jewish community
   4. Jewish Community Organisations
   5. potential and active Donors
   6. CSO Trustees
   7. staff at schools, Synagogues and businesses to whom CSO may provide services
   8. Suppliers, service providers and other entitles with whom CSO may engage in the conduct of its activities;
   9. applicants for employment
   10. browsers of Our Website

3. What Personal Information and Special Personal Information We Collect and Use in Our Operations

   1. Juristic Entities
      Where CSO, in the conduct of its operations, engages and contracts with Juristic Entities, it also engages with individuals within the Entities and may collect and use the Personal Information of such persons. We will Process the Personal Information of such individuals as stated in this Privacy Policy.
   2. Personal Information
      1. Contact Information such as name, e-mail addresses, physical and postal address, phone numbers, name and contact details of Your next of kin.
      2. Cultural and Criminal Information: race, social origin, gender, religion, culture, language, personal and behavioural profile, criminal history
      3. Account and payment information such as authorised account users, VAT and Income tax reference numbers, bank details, invoices and records;
      4. Identifiers such as registration numbers, identity numbers, Supplier/Vendor numbers, B-BBEE status, vehicle registration numbers, driver’s license, photographs and video recording, online identifier or other particular assignment (cookies), Biometric information E.g., fingerprint, voice print, retina or iris, image
      5. Financial information – bank account details, tax certificates, VAT number, financial statements, credit and trade references, donations
      6. Medical Information: Disabilities, Medical history, treatment,
      7. Background information including credit status, criminal record, background and fraud checks;
      8. Recruitment information: CV/resume, SA ID number; training records, education and work history, address, contact details, certifications/qualifications
      9. Communication Information: Recordings of telephone calls or video calls we receive or make, what’s app communications, correspondence sent that is implicitly/explicitly of private or confidential nature or further correspondence that would reveal the contents of the original correspondence,
      10. Website, Social Media information: when you access any CSO website, We collect your IP address and other technical information about your computer and website usage;
      11. Direct Marketing Information: which includes your preferences in respect of receiving marketing information from us and our third parties, and your communication preferences.
   3. Special Personal Information
      1. health Information: medical/trauma treatment, historical medical history;
      2. reports or notes on your health or any treatment and care you have received or need.
      3. patient feedback and treatment outcome information you provide.
      4. Religious and philosophical beliefs, Race and ethnic origin
   4. Children’s Information
      1. Given the nature of the services We provide, we will Collect and process the Personal Information and/or Special Personal Information of children under the age of 18 years, including name, contact details, location information, biometric information E.g., fingerprint, photos and CCTV footage, medical and treatment information, disabilities, medical history.
      2. This information is collected and used for purposes related to the services we provide the Community and for purposes of ensuring security and protection of Children, including security services at Schools, Shuls, School Outings, Camps and community events.

4. If You Do Not Provide Us with The Personal Information

   If You do not provide Us with the Personal Information, by way of illustration only:

   1. We may not be able to provide services to you
   2. We may not be able to consider you for employment;

5. How We Collect Personal Information:

   1. We collect information directly from You when:
      1. We render Services to You
      2. through direct or active interactions with you including face to face and via emails;
      3. through automated or passive interactions with You;
      4. through CCTV footage including from external sites where we render Services and when You enter any of Our Offices and work areas (for example via CCTV)
      5. You contact Our call centre
      6. You register for and attend events;
      7. submit an application for employment/reply to any employment opportunities
      8. make a Donation
      9. through social media platforms e.g., Instagram, Facebook using website cookies and other various technologies.
   2. We collect Personal Information indirectly about You from:
      1. publicly available sources (registers or the internet)
      2. third parties that We engage for the purposes of rendering our Services and conducting our business (credit bureaux, Regulators, Government departments and third-party service providers);
      3. Your next of kin or other family member;
      4. doctors, health care professionals, hospitals, and other health care providers;
      5. the SAPS and other enforcement bodies;
      6. employment agencies, background check providers, exiting and former employers, credit reference agencies.
      7. Schools, Shuls, Youth Movements and communal organisations.

6. What We Use Your Personal Information For

   1. We Use Your Personal information –
      1. to conduct Our Operations
      2. to render Our services to you, including medical and security related services;
      3. and demographics to focus services and resources, managing callers to our control room, managing security incidents, facilitating ease of access to community events
      4. to contact You regarding fundraising initiatives or requests for donations and community outreach
      5. to conduct the recruitment processes;
      6. to invite you to functions or events that we may host
      7. to understanding demographics to better focus our services and resources
      8. to implement and manage relationships with You including onboarding as a Supplier, sending invoices, processing payments, accounting, auditing, collection;
      9. to comply with all laws, codes of conduct, regulations and registrations with professional bodies who requires Us to collect the information;
      10. to comply with demands or requests made by Regulators, Governmental Authorities and Law Enforcement Authorities;
      11. to better understand the users of Our services and the needs of the Community
      12. to ensure We have Your up-to-date contact information;
      13. to conduct internal audits and investigations;
      14. to verify information provided by You.
      15. for direct marketing
   2. We use your Special Personal Information –
      1. to render Our services to you, including medical and security related services
      2. to comply with all laws, codes of conduct, regulations and registrations with professional bodies which requires Us to collect the information;
      3. to comply with demands or requests made by Regulators, Governmental Authorities and Law Enforcement Authorities.

7. Who We Share the Personal Information With?

   We may share Your Personal Information with –

   1. Doctors, hospitals, treatment centres, ambulance services and other health care providers to provide our services
   2. Our Volunteers who are engaged in the rendering of Our Services to You
   3. Our professional advisors;
   4. third-party service providers who provide services to Us, such as hosting Our information technology systems and information storage
   5. Regulatory bodies to the extent that We are legally obliged to do so;
   6. Jewish Community Organisations who we work with for the purposes of rendering our Services;
   7. to third party partner private security companies, and medical services when necessary for the purposes of rendering our Services.
   8. law enforcement, government officials, or other third parties as may be necessary or appropriate in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose Us to legal liability;

8. Transfer of Personal Information to Other Countries?

   1. We may transfer certain Personal Information across geographical borders to service providers for the purposes set out in 7.4 above;
   2. Where We transfer Your Personal Information outside of South Africa, We ensure that We do so in accordance with the requirements for lawful transfer outside of South Africa as set out in the Protection of Personal Information Act No.4 of 2013.

9. How Long Do We Keep Your Personal Information?

   1. We will retain your Personal Information for as long as necessary to achieve the purpose for which it was collected or subsequently processed.
   2. Personal Information may be held for longer periods where –
      1. retention of the record is required or authorised by law;
      2. We reasonably require the record for lawful purposes related to Our functions or activities;
      3. retention of the record is required by a contract between You and Us; or
      4. You have consented to the retention of the record.

10. How we keep your Personal Information Secure

    1. We secure the integrity and confidentiality of Personal Information in Our possession or under Our control by taking appropriate, reasonable technical and organisational measures to prevent loss of damage to or unauthorised destruction of Personal Information; and unlawful access to or processing of Personal Information.
    2. In order to ensure such security, We have in place policies, controls and related processes, which are reviewed and updated on a regular basis.

11. Cookies

    1. We may place small text files called ‘cookies’ on Your device when You visit Our website. Cookies do not contain Personal Information, but they do contain a personal identifier allowing Us to associate Your Personal Information with a certain device.
    2. We use the following types of cookies on Our website:
       1. Essential cookies which are crucial to a user’s experience of a website, enabling core features functions on Our website;
       2. Performance cookies which track how You use a website during Your visit. This information is typically anonymous and aggregated and helps Us understand visitor usage patterns, identify and diagnose problems users may encounter, and make better decisions in improving the overall website experience;
       3. Functionality cookies which are used to collect information about Your device and any settings you may configure on the Website you’re visiting (like language and time zone settings). With this information, websites can provide a customized, enhanced, or optimized content and services.
    3. Your web browser can be set to allow You to control whether you will accept or reject cookies or to notify You each time a cookie is sent to Your browser. If Your browser is set to reject cookies, websites that are cookie-enabled will not recognize You when you return to the website, and some website functionality may be lost.

12. Direct marketing

    1. You have the right to object at any time and free of charge to our processing of your Personal Information for direct marketing purposes.
    2. This right can be exercised by sending an email to popia@cso.org.za or by other electronic means, such as selecting “unsubscribe” from direct marketing communications.

13. Your Rights

    1. You have the right to –
       1. request a record of Your Personal Information. We may charge You a fee to provide such a record, but We will tell You how much this is beforehand. In certain circumstances, We cannot tell you what Personal Information We have about You. For example, to protect (a) the privacy of others; (b) confidential information of third parties; (c) the safety of others;
       2. request correction of Your Personal Information if it is inaccurate, irrelevant, excessive, misleading or obtained unlawfully;
       3. request deletion of Your Personal Information where there is no lawful basis to retain it;
       4. withdraw consent previously given in respect of the processing of Your Personal Information. Withdrawal of consent may limit Our or a third party’s ability to carry out certain functions in respect of the services we render.
    2. We will comply with Your request unless We have a reasonable explanation why We cannot comply.
    3. If We cannot agree whether to correct or delete the Personal Information and if You ask Us to, We will indicate on the Personal Information register that a correction was requested but was not made.
    4. If changes to the Personal Information impact any earlier decisions that impact You, if reasonably practicable, We will inform all persons to whom the Personal Information has been disclosed of those steps.
    5. We will notify You of the action taken by Us because of Your request.
    6. All requests can be made via email to popia@cso.org.za. We will always require that You verify You are in fact the owner of such Personal Information or are authorised to request such information.

14. Right to withdraw consent

    1. In the limited circumstances where processing of Your Personal Information is based on Your Consent, You have the right to withdraw such consent at any time. To withdraw Your consent, please send an email to popia@cso.org.za
    2. Once We are notified that You have withdrawn Your consent, We will no longer process Your Personal Information for the purpose You originally agreed to, unless We have another lawful basis for doing so.

15. How to lodge a complaint with the information Regulator

    1. You may lodge a complaint in respect of this Privacy Policy or any of Our Personal Information Processing activities with the Information Regulator, at POPIAComplaints@inforegulator.org.za
    2. The details of the Information Regulator are available at https://inforegulator.org.za

16. Revisions to the Policy

    We may update this Privacy Policy from time to time. Changes to this Privacy Policy will be posted on Our website.