1.1. The CYBER-MINDS (PTY) LTD Group of companies, comprising CYBER-MINDS (PTY) LTD, Creative Minds® Computer training, Cyber-Minds Training Institutes, MindsCampus.com and Learnminds.co.za (collectively referred to as “CYBER-MINDS (PTY) LTD”), is an organisation whose mission is to develop and provide various skills training courses.
1.2. CYBER-MINDS (PTY) LTD is obliged to comply with The Protection of Personal Information Act (‘POPI’).
1.3. POPI requires CYBER-MINDS (PTY) LTD to inform candidates as to how their Personal Information is used, disclosed and destroyed.
1.4. CYBER-MINDS (PTY) LTD guarantees its commitment to protecting candidates’ privacy and ensuring that their Personal Information is used appropriately, transparently, securely and in accordance with applicable laws.
1.5. This Policy sets out how CYBER-MINDS (PTY) LTD deals with candidates’ Personal Information and, in addition, the purposes said information is used for. This Policy is made available on our websites and by request from our Information Officer, whose details are provided in this document.
1.6. Section 9 of POPI states that “Personal Information may only be processed if, given the purpose for which it is processed, it is adequate, relevant and not excessive.”
- THE PERSONAL INFORMATION COLLECTED
2.1. CYBER-MINDS (PTY) LTD collects and processes candidates Personal Information pertaining to candidates’ Competence as learners.
The type of information will depend on the need for which it is collected and will be processed for that purpose only. Whenever possible, we will inform candidates what information they are required to provide us with and what information is optional.
Examples of the Personal Information we collect includes but is not limited to:
- Candidates identity number, name, surname, addresses, postal code and employment details;
- Description of candidate’s previous academic records; and
- Any other information required by us and Professional Institutes and Regulators to provide candidates with appropriate information to facilitate Professional Development and assess needs for further development.
2.2. For purposes of this Policy, candidates include potential, past and existing candidates.
- HOW PERSONAL INFORMATION IS USED
3.1. Candidates’ Personal Information will only be used for the purpose for which it was collected and intended. This would include:
- Providing products or services to candidates for the purposes of developing and facilitating candidates’ Professional Development and their acquisition of professional skills.
- Providing information to Professional Institutes and Regulators.
- Providing information to employer firms who are responsible for the payment of candidates’ fees.
- Enabling CYBER-MINDS (PTY) LTD to assess candidates’ further development needs;
- For audit and record keeping purposes;
- In connection with legal proceedings;
- Providing our services to candidates to carry out services requested and to maintain and constantly improve relationships;
- Providing communications in respect of CYBER-MINDS (PTY) LTD and matters that may affect candidates; and
- In connection with and to comply with legal and regulatory requirements or when it is otherwise allowed by law.
3.2. According to Section 10 of POPI, Personal Information may only be processed if certain conditions are met for CYBER-MINDS (PTY) LTD processing the Personal Information. These are listed below:
3.2.1. Candidate consents to the processing – consent is obtained from candidates during registration;
3.2.2. Processing is necessary – Persona information is required to facilitate the provision of services to candidates;
3.2.3. Processing complies with an obligation imposed by law on CYBER-MINDS (PTY) LTD;
3.2.4. Processing protects a legitimate interest of the candidate – it is in candidates’ best interests to have access to full and appropriate services;
3.2.5. Processing is necessary for pursuing the legitimate interests of CYBER-MINDS (PTY) LTD – to provide our candidates with services, we need certain Personal Information from candidates.
- DISCLOSURE OF PERSONAL INFORMATION
4.1. We may share candidates’ Personal Information with and obtain information about candidates from third parties for the reasons already discussed in 3.1 and 3.2 above.
4.2. We may also disclose candidates’ information where we have a duty or a right to disclose in terms of applicable legislation, the law or where it may be necessary to protect our rights.
- SAFEGUARDING CANDIDATES INFORMATION
5.1. It is a requirement of POPI to adequately protect the Personal Information we hold and to avoid unauthorized access and use of your Personal Information. We continuously review our security controls and processes to ensure that your Personal Information is secure.
5.2. The following procedures are in place to protect your Personal Information:
5.2.1. A third-party service provider may be mandated to ensure the safeguarding of candidates’ Personal Information;
5.2.2. Recommendations made by this possible third party are actioned.
5.2.3. The CYBER-MINDS (PTY) LTD Information Officer is Ina Lubbe, whose details are available below and who is responsible for the encouragement of compliance with the conditions of the lawful processing of Personal Information and other provisions of POPI;
5.2.4. This policy is in place throughout CYBER-MINDS (PTY) LTD
5.2.5. Employees are required to sign Confidentiality Agreements which are considered annexures to their Employment Contracts;
5.2.6. Archived candidate information is stored at third party providers who are also governed by POPI and with whom CYBER-MINDS (PTY) LTD has Service Level Agreements;
5.2.7. Hard copy files are stored at secure premises and are destroyed after 5 years;
5.2.8. CYBER-MINDS (PTY) LTD’s internal server hard drives are protected by firewalls;
5.2.9. A Security Incident Management Register will be kept to log any security incidents and to report on and manage said incidents. If any. This register will be maintained by the Information Officer.
5.2.10. A Procedures Manual has been drafted and will be implemented by 31 December 2014 to ensure that all employees follow CYBER-MINDS (PTY) LTD’s Professional Procedures to ensure candidate information is processed accurately and securely; and
5.2.11. Consent to process client information is obtained from candidates (or a person who is authorized by the client to provide the candidates’ Personal Information) during registration.
- ACCESS AND CORRECTION OF PERSONAL INFORMATION
6.1. Candidates have the right to request access to the Personal Information we hold about them.
6.2. Candidates also have the right to ask us to update, correct or delete their Personal Information on reasonable grounds.
6.3. Once a candidate objects to the processing of their Personal Information, CYBER-MINDS (PTY) LTD may no longer process said Personal Information.
6.4. The details of our Information Officer and Head Office are as follows:
6.4.1. Information Officer Details
22.214.171.124. Name: Jacomina Hendrina Lubbe
126.96.36.199. Telephone Number: 021 939 6344
188.8.131.52. Postal Address: P.O. Box 6374, Welgemoed 7538
184.108.40.206. Physical Address: 157 First Avenue, Parow, 7500, Cape Town, South Africa
220.127.116.11. E-Mail Address: firstname.lastname@example.org
6.4.2. Head Office Details
18.104.22.168. Telephone Number: 021 9396344
22.214.171.124. Postal Address: P.O. Box 6374, Welgemoed 7538
126.96.36.199. Physical Address: 157 First Avenue, Parow, 7500, Cape Town, South Africa
- AMENDMENTS TO THIS POLICY
7.1. Amendments to this Policy will take place on an ad hoc basis or at least once every five years.
7.2. Candidates are advised to check our websites periodically to inform themselves of any changes.
7.3. Where material changes take place, candidates will be notified directly.