- Where we refer to “process”, it means how we collect, use, store, make available, destroy, update, disclose, or otherwise deal with youror your employees personal information. As a general rule we will only process this personal information if it is required to deliver or offer a service, provide a product or carry out a transaction.
- This policy establishes a general standard for the appropriate protection of personal information (POPI) within the LabourNet Pty Ltd its affiliate, associate and subsidiary companies environments furthermore, it provides principles regarding the rights of individuals to privacy and to reasonable safeguards of their personal information.
All employees, contractors, consultants, temporary and other workers at LabourNet, including all personnel affiliated with third parties must adhere to this policy. This policy applies to information assets owned or leased by LabourNet, or to devices that connect to a LabourNet network or reside at a LabourNet site.
What is personal information?
Personal information refers to any information that identifies you
or specifically relates to you
, or your
employees stored or processed on The Product/s
. Personal information includes, but is not limited to, the following information about you
and / or your
- Marital status
- National origin
- Birth place
- Relevant financial history
- Identifying number (like an employee number, identity number or passport number)
- E-mail address; physical address (like residential address, work address or your physical location); telephone number
- Biometric information (like fingerprints, signature or voice)
- Race; gender; sex; pregnancy status; ethnic origin; social origin; colour; sexual orientation
- Physical health; mental health; well-being; disability; religion; belief; conscience; culture
- Medical history; criminal history; employment history
- Personal views, preferences and opinions
- Another’s views or opinions about you
- Full names and initials
Personal information includes special personal information, as explained below.
When will we process your personal information?
will only process this personal information for lawful purposes relating to our
business if the following applies:
- If you have consented thereto
- If a person legally authorised by you, the law or a court, has consented thereto
- If it is necessary to conclude or perform under a contract we have with you
- If the law requires or permits it
- If it is required to protect or pursue your, our or a third party’s legitimate interest
What is special personal information?
Special personal information is personal information about the following:
- Race (like where a company submits reports to the Department of Labour where the statistical information must be recorded)
- Ethnic origin
- Trade union membership
- Health (like where you apply for an insurance policy)
- Bometric information (like to verify your identity); and / or your criminal behavior and alleged commission of an offense
When will we process your special personal information?
We may process your
special personal information in the following circumstances:
- If you have consented to the processing
- If the information is being used for any Human Resource or payroll related requirement
- If the processing is needed to create, use or protect a right or obligation in law
- If the processing is for statistical or research purposes and all legal conditions are met
- If the special personal information was made public by you
- If the processing is required by law
When and from where we obtain personal information about you
- We collect personal information from the payroll or HR departments of our clients when they capture financial and non-financial information
- We collect personal information from 3rd parties that are directly integrated with our software platform
- We collect information about you based on your use of our products, services or service channels (like our Platform, Applications, Employee Self Service, and Websites)
- We collect information about you based on how you engage or interact with us such as via our support desk, emails, letters, telephone calls and surveys
- We collect personal information from completed forms ie contact and billing information
If the law requires us
to do so, we will ask for your
consent before collecting personal information about you
employees from third parties.
The third parties from whom we
may collect your
personal information include, but are not limited to, the following:
- your spouse, dependents, partners, employer, and other similar sources;
- people you have authorised to share your personal information, like a person that makes a travel booking on your behalf or a medical practitioner for insurance purposes;
- attorneys, tracing agents, debt collectors and other persons that assist with the enforcement of agreements;
- payment processing services providers, merchants, banks and other persons that assist with the processing of your payment instructions, like EFT transaction partners.
- insurers, brokers, other financial institutions or other organisations that assist with insurance and assurance underwriting, the providing of insurance and assurance policies and products, the assessment of insurance and assurance claims and other related purposes;
- law enforcement and fraud prevention agencies and other persons tasked with the prevention and prosecution of crime;
- regulatory authorities, industry ombudsman, governmental departments, local and international tax authorities;
- trustees, Executors or Curators appointed by a court of law;
- our service providers, agents and sub-contractors like couriers and other persons we use to offer and provide products and services to you;
- courts of law or tribunals;
Reasons we need to process your personal information
will process your
personal information for the following reasons:
- to provide you with products, goods and services; such as payroll and HR, IR services.
- to market our products, goods and services to you;
- to respond to your enquiries and complaints;
- to comply with legislative, regulatory, risk and compliance requirements (including directives, sanctions and rules), voluntary and involuntary codes of conduct and industry agreements or to fulfill reporting requirements and information requests;
- to conduct market and behavioral research, including scoring and analysis to determine if you qualify for products and services or to determine your credit or insurance risk;
- to develop, test and improve products and services for you;
- for historical, statistical and research purposes, like market segmentation;
- to process payment instruments;
- to create, manufacture and print payment advice (like a payslip);
- to enable us to deliver goods, documents or notices to you;
- for security, identity verification and to check the accuracy of your personal information;
- to communicate with you and carry out your instructions and requests;
- for customer satisfaction surveys, promotional offerings.
- to enable you to take part in and make use of value-added products and services;
- to assess our lending and insurance risks; and / or
- for any other related purposes.
How we use your personal information for marketing purposes
- We will use your personal information to market our technology, services, and related products and services to you
- We may also market non-banking or non-financial products, goods or services to you
- We will do this in person, by post, telephone, or electronic channels such as SMS, email
- If you are not our customer, or in any other instances where the law requires, we will only market to you by electronic communications with your consent
- In all cases you can request us to stop sending marketing communications to you at any time
When, how and with whom we share your personal information
In general we will only share your
personal information if any one or more of the following apply:
- If you have consented to this
- If it is necessary to conclude or perform under a contract we have with you
- If the law requires it; and / or
- If it’s necessary to protect or pursue your, our or a third party’s legitimate interests
Where required, each member of LabourNet
may share your
personal information with the following persons. These persons have an obligation to keep your
personal information secure and confidential.
- Our employees as required by their employment conditions
- Attorneys, tracing agents, debt collectors and other persons that assist with the enforcement of agreements
- Payment processing services providers, merchants, banks and other persons that assist with the processing of your payment instructions, like 3rd party EFT service providers
- Law enforcement and fraud prevention agencies and other persons tasked with the prevention and prosecution of crime
- Regulatory authorities, industry ombudsmen, governmental departments, local and international tax authorities and other persons the law requires us to share your personal information with
- Our service providers, agents and sub-contractors like couriers and other persons we use to offer and provide products and services to you
- Persons to whom we have ceded our rights or delegated our obligations to under agreements, like where a business is sold
- Courts of law or tribunals that require the personal information to adjudicate referrals, actions or applications;
- Trustees, Executors or Curators appointed by a court of law
- Participating partners in our customer loyalty reward programmes, where you purchase goods, products and service or spend loyalty rewards; and / or our joint venture and other partners with whom we have concluded business agreements, for your benefit
Under what circumstances will we transfer your information to other countries?
will only transfer your
personal information to third parties in another country in any one or more of the following circumstances:
- Where your personal information will be adequately protected under the other country’s laws or an agreement with the third party recipient
- Where the transfer is necessary to enter into or perform under a contract with you, or a contract with a third party that is in your interest
- Where you have consented to the transfer; and / or
- Where it is not reasonably practical to obtain your consent, the transfer is in your interest
This transfer will happen within the requirements and safeguards of the law. Where possible, the party processing your
personal information in the other country will agree to apply the same level of protection as available by law in your
country or if the other country’s laws provide better protection the other country’s laws would be agreed to and applied.
An example of us
personal information to another country is where foreign payments take place if you
purchase goods or services in a foreign country, or request that we
facilitate salary payments to your
employees in the countries.
Your duties and rights about the personal information we have about you
must provide proof of identity when enforcing the rights below.
must inform us
personal information changes.
Please refer to our Promotion of Access to Information Act 2 of 2000 Manual (PAIA Manual
) for further information on how you
can give effect to the rights listed below.
have the right to request access to the personal information we
have about you
by contacting us
. This includes requesting:
- Confirmation that we hold your personal information
- A copy or description of the record containing your personal information; and
- The identity or categories of third parties who have had access to your personal information
will attend to requests for access to personal information within a reasonable time. You
may be required to pay a reasonable fee to receive copies or descriptions of records, or information about third parties. We
will inform you
of the fee before attending to your
Please note that the law may limit your
right to access information.
have the right to request us
to correct or delete the personal information we
have about you
if it is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, obtained unlawfully or we
are no longer authorised to keep it. You
must inform us
request in writing. Please refer to our PAIA Manual for further information in this regard, like the process you
should follow to give effect to this right. It may take up to 15 business days for the change to reflect on our systems.
may request documents from you
to verify the change in personal information.
A specific agreement that you
have entered into with us
may determine how you
must change your
personal information provided at the time when you
entered into the specific agreement. Please adhere to these requirements. If the law requires us
to keep the personal information, it will not be deleted upon your
request. The deletion of certain personal information may lead to the termination of your
business relationship with us
may object on reasonable grounds to the processing of your
will not be able to give effect to your
objection if the processing of your
personal information was and is permitted by law; you
have provided consent to the processing and our
processing done according to your
consent or the processing is necessary to conclude or perform under a contract with you
must inform us
of any objection in writing. Please refer to our
PAIA Manual for further information in this regard, like the process you
should follow to give effect to this right.
have provided your
consent for the processing of your
personal information, you
may withdraw your
consent. If you
will explain the consequences to you
may proceed to process your
personal information even if you
have withdrawn your
consent if the law permits or requires it. It may take up to 15 business days for the change to reflect on our
systems, during this time we
may still process your
have a right to file a complaint with us
or any Regulator with jurisdiction about an alleged contravention of the protection of your
personal information by us. We
will address your
complaint as far as possible.
How we secure your personal information
will take appropriate and reasonable technical and organisational steps to protect your
personal information according to industry best practices. Our
security measures (including physical, technological and procedural safeguards) will be appropriate and reasonable. This includes the following:
- Keeping our systems secure (like monitoring access and usage)
- Storing our records securely
- Controlling the access to our buildings, systems and/or records; and
- Safely destroying or deleting records
- Ensure compliance with international ISO27001 security standards
How long do we keep your personal information?
will keep your
personal information for as long as:
- The law requires us to keep it
- A contract between you and us requires us to keep it
- You have consented to us keeping it
- We require it for statistical or research purposes
- A code of conduct requires us to keep it; and / or
- We require it for our lawful business purposes
may keep your p
ersonal information even if you
no longer have a relationship with us
, for the historical data that may be required by your
employer or employee.
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided LabourNet
with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.
A cookie is a small piece of data sent from our
websites or applications to your
computer or device hard drive or Internet browser where it is saved. The cookie contains information to personalise your
experience on our
websites or applications and may improve your
experience on the websites or applications. The cookie will also identify your
device, like the computer or smart phone.
By using our
websites or applications you
agree that cookies may be forwarded from the relevant website or application to your
computer or device. The cookie will enable us
to know that you
have visited the website or application before and will identify you
may also use the cookie to prevent fraud and for analytics.
An employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment. A violation of this policy by a temporary worker, contractor, or vendor may result in the termination of their contract or assignment with LabourNet.
Any exception to the policy must comply with the Exceptions Policy.
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