VKB Privacy Portal


The VKB Group is committed to respecting your right to privacy as regulated by the
Protection of Personal Information Act (POPIA).

We have created the VKB Privacy Portal to provide you with easy access to all relevant VKB privacy information.

We have divided this information into sections for easy navigation, so you can see and understand how we process and protect your personal information.

A VKB POPIA Committee has been established to facilitate compliance - the committee consists of a multidisciplinary team.

For any inquiries regarding VKB’s POPIA Compliance Framework and / or any of the information on this page, please contact the POPIA Committee via email at: This email address is being protected from spambots. You need JavaScript enabled to view it..


Vkb Group Privacy Statement

Website Privacy Statement

Frequently Asked Questions

PAIA/POPIA Manuals

Notices

VKB Group Privacy Statement

IN TERMS OF THE PROTECTION OF PERSONAL INFORMATION ACT 4 of 2013 (‘POPIA’)

(hereinafter referred to as ‘the/this Statement’)

1. INTRODUCTION

1.1. For purposes of this Statement:

1.1.1 ‘Applicable Laws’ means all Laws that VKB is required to comply with;

1.1.2 ‘Law’ means the common law and any applicable Constitution, statute, by-law, proclamation, regulation, rule, notice, treaty, directive, code of practice, charter, judgment or order having force of law in South Africa, and any interpretation of any of them by any court or forum of law;

1.1.3 ‘Related Entities’ in relation to VKB Beleggings (Pty) Ltd - all subsidiaries, associated, affiliated, related and inter-related persons, companies, entities and trusts;

1.1.4 ‘Personal Information’ means Personal Information as defined in POPIA;

1.1.5 ‘Process’ / ‘Processing’ / ‘Processed’ means Processing as defined in POPIA;

1.1.6 ‘Stakeholder’ means any prospective, new or existing shareholder, client, employee, supplier or contractor of VKB; and

1.1.7 ‘VKB’ means VKB Beleggings (Pty) Ltd registration number: 2011/007000/07 and any of its Related Entities.

1.2. This Statement sets out how a Stakeholder’s Personal Information will be Processed by VKB and applies to any information, including Personal Information, a Stakeholder may provide to VKB or which VKB may collect from third parties.

1.3. It is important that all Stakeholders read this Statement carefully before submitting any Personal Information to VKB.

1.4. By submitting Personal Information to VKB, a Stakeholder provides consent to the Processing of such Personal Information as set out in this Statement.

1.5. The provisions of this Statement are subject to mandatory, unalterable provisions of Applicable Laws.

1.6. Stakeholders should not submit any Personal Information to VKB if they do not agree to any of the provisions of this Statement. Please note that that VKB may then not be able to: 1) Provide its products and/or services to a Stakeholder; 2) Allow a Stakeholder to provide products and services to VKB; and/or 3) Fulfil its contractual/legal obligations towards a Stakeholder.

 

2. CONTACT DETAILS

Any comments or questions regarding this Statement can be directed to the Information Officer via telephone on 058 863 8111 or email at This email address is being protected from spambots. You need JavaScript enabled to view it.

 

3. PRIVACY AND INDEMNITY

3.1. VKB takes its Stakeholder’s privacy and the protection of their Personal Information very seriously and will only Process Personal Information in accordance with this Statement and applicable data protection legislation, which specifically include POPIA.

3.2 VKB has implemented reasonable technical and operational measures to keep Personal Information secure.

3.3. Stakeholders hereby indemnify and hold VKB harmless from any loss, damages or injury that a Stakeholder may incur as a result of –

3.3.1. any unintentional disclosures of its Personal Information to unauthorised persons; and/or

3.3.2. the provision of incorrect or incomplete Personal Information to VKB.

 

4. INFORMATION ABOUT STAKEHOLDERS

4.1. VKB may collect the following information about its Stakeholders (the list is however not exhaustive):

4.1.1. name, address, company details, company registration documents, contact details, date of birth, place of birth, identity number, passport number, bank details, tax and/or VAT number and other financial information;

4.1.2. records of correspondence or enquiries from a Stakeholder or anyone acting on its behalf;

4.1.3. details of transactions carried out with VKB;

4.1.4. details of contracts, sales, purchases or leases carried out with VKB; and

4.1.5 sensitive or special categories of Personal Information, including biometric information, such as images and fingerprints.

4.2. Should a Stakeholder provide VKB with the Personal Information of a third party, such Stakeholder shall take all reasonable steps to inform the third party of such disclosure to VKB. VKB will Process such Personal Information in accordance with this Statement.

 

5. COLLECTION OF PERSONAL INFORMATION

5.1. Stakeholders may provide Personal Information to VKB either directly or indirectly (acting through an agent):

5.1.1. by completing the relevant on-boarding / application forms;

5.1.2. by requesting further information about VKB’s products and/or services, whether in writing, through VKB’s website, via telephone or any other means;

5.1.3. by submitting information as part of a tender/procurement process; and/or

5.1.4. by concluding/signing a contract with VKB.

5.2.VKB may also collect Personal Information from a Stakeholder’s appointed agent, any regulator, or other third party that may hold such information and are legally mandated to provide same to VKB.

 

6. USE OF PERSONAL INFORMATION

6.1. VKB may Process Personal Information for the purposes of:

6.1.1. providing a Stakeholder with the services, products or offerings requested, and notifying the Stakeholder about important changes to such services, products or offerings;

6.1.2. managing and executing the contractual relationship with a Stakeholder;

6.1.3. detecting and preventing fraud and money laundering and/or in the interest of security and crime prevention;

6.1.4. assessing and dealing with complaints;

6.1.5. operational, marketing, auditing, legal and record keeping requirements;

6.1.6. verifying a Stakeholder’s identity;

6.1.7. complying with Applicable Laws, including lawful requests for information received from local or foreign law enforcement, government and tax collection agencies;

6.1.8. recording and/or monitoring a Stakeholder’s telephone calls and electronic communications to/with VKB in line with contractual obligations;

6.1.9. disclosing Personal Information to third parties for reasons set out in this Statement or where it is not unlawful to do so;

6.1.10. monitoring, keeping record of and having access to all forms of correspondence or communications received by or sent from VKB or any of its employees, agents or contractors, including monitoring, recording and using as evidence all telephone communications between a Stakeholder and VKB; and

6.1.11. improving or evaluating the effectiveness of VKB’s business or products, services or offerings.

 

7. DISCLOSURE OF PERSONAL INFORMATION

7.1. A Stakeholder’s Personal Information may be shared with all companies within the VKB Group, its agents and sub- contractors, and selected third parties who Process Personal Information on our behalf.

7.2. VKB may also disclose Personal Information to third parties in the following circumstances:

7.2.1. to any of the companies within the VKB Group to determine which products and services may be of interest to a Stakeholder and/or to send information about such products and services, unless a Stakeholder objects or chooses not to receive such communications;

7.2.2. to any relevant person and/or entity for purposes of prevention, detection and reporting of fraud and criminal activities, the identification of the proceeds of unlawful activities and the combatting of crime;

7.2.3. as part of VKB’s onboarding, application and/or due diligence processes;

7.2.4. as part of our regular auditing process or for any reason as set out in a signed contract;

7.2.5. to any regulator or supervisory authority if VKB is required to do so in terms of Applicable Laws;

7.2.6. to a prospective buyer or seller of any of VKB’s businesses or assets;

7.2.7. to an operator Processing Personal Information on VKB’s behalf, which Processing relates to VKB’s bona fide business activities;

7.2.8. to any person if VKB is under a duty to disclose or share such Personal Information in order to comply with any Applicable Laws, or to protect the rights, property or safety of VKB, other clients or other third parties; and/or

7.2.9. to an agent or any other person acting on behalf of a Stakeholder.

7.3. VKB will ensure that anyone to whom Personal Information is disclosed, treat such Personal Information at least in accordance with POPIA.

7.4. Stakeholders may contact VKB (as per the contact details above) should they not wish for VKB to disclose their Personal Information to third parties. However, VKB may then not be able to: 1) Provide its products and services to a Stakeholder; 2) Allow a Stakeholder to provide products and services to VKB; and/or 3) Fulfil its contractual/legal obligations towards a Stakeholder.

 

8. RETENTION OF PERSONAL INFORMATION

VKB will retail Personal Information in accordance with its Records Management Policy. However, as a general rule, VKB will retain Personal Information in accordance with retention periods as set out in Applicable Laws, unless required to be retained longer for a lawful purpose.

 

9. AMENDMENT OF THIS STATEMENT

9.1. VKB may amend this Statement from time to time for any of the following reasons:

9.1.1. to provide for the introduction of new systems, methods of operation, services and products;

9.1.2. to comply with changes to any legal or regulatory requirement;

9.1.3. to ensure that this Statement is accurate and relevant;

9.1.4. to rectify any mistake that may be discovered from time to time; and/or

9.1.5. for any other reason which VKB, in its sole discretion, may deem reasonably necessary.

9.2. Any such amendment will come into effect and become part of any agreement/contract a Stakeholder may have with VKB when such amended Statement is published on VKB’s website. It is a Stakeholder’s responsibility to regularly check the relevant website(s).

 

10. ACCESS TO, CORRECTION AND DELETION OF PERSONAL INFORMATION

10.1. Stakeholders may request details of Personal Information which VKB holds about them under the Promotion of Access to Information Act, 2 of 2000 (“PAIA”). Fees to obtain a copy or a description of Personal Information held are prescribed in terms of PAIA. Confirmation of whether or not VKB holds Personal Information about a Stakeholder may be requested free of charge. VKB’s PAIA manual can be accessed on its website.

10.2. Stakeholders may request the correction of their Personal Information held by VKB. Stakeholders must ensure that their Personal Information with VKB are kept complete, accurate and up to date. VKB may not be held liable for any loss or damage suffered as a result of a Stakeholder’s failure to comply with this clause 10.2. To submit a request for the correction or update of Personal information please contact [email protected].

10.3. Stakeholders have a right, in certain circumstances, to request the destruction or deletion of and, where applicable, to obtain restriction on the Processing of their Personal Information. Stakeholders can exercise such right by contacting [email protected].

 

COMPLAINTS

11.1. Stakeholders may contact [email protected] should they be of the opinion that VKB has utilised its Personal Information contrary to Applicable Laws. VKB undertakes to resolve such complaints with the necessary urgency.

11.2. If a Stakeholder is not satisfied with VKB’s complaint handling procedure, such Stakeholder may lodge a complaint with the Information Regulator at [email protected]

 

Version 1.2

Published: 1 July 2021

Website Privacy Statement

Your privacy is important to us. It is the VKB Group’s policy to respect the privacy of any information we may collect from you across our website, www.vkb.co.za, and other sites we own and operate.

We will only ask for personal information when we need it to provide a service to you. We will process your personal information in compliance with all applicable privacy laws, which specifically include the Protection of Personal Information Act 4 of 2013.

We only retain collected information for as long as necessary to provide you with your requested service, unless otherwise required by law. What data we store, will be protected within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification.

We do not share any personal information obtained through our website publicly or with third parties, except when legally required to do so.

Our website may link to external sites that are not operated by us. We have no control over the content and practices of these sites, and do not accept responsibility or liability for their respective privacy policies.

You are free to refuse any request to provide us with your personal information, with the understanding that we may be unable in such instances to provide you with some services.

Your use of our website will be regarded as an acceptance of this privacy statement. If you have any questions about the way in which we deal with user data and personal information, feel free to contact us.

This policy is effective as of 12 June 2021.

Frequently Asked Questions

What is POPIA?

POPIA is the Protection of Personal Information Act (Act 4 of 2013).
It was promulgated in 2013 & became effective on 1 July 2020 with a 1-year grace period for implementation (1 July 2021 is the final compliance deadline).

The act regulates the PROCESSING of Personal Information (“PI”) and protects your constitutional right = your right to privacy. Both individuals and legal entities enjoy protection under POPIA.

What is Personal Information (PI)?

  1. ​​​​​​​It’s any information about a person or about a business, which can be used to identify that particular person/business.
  2. The moment you can identify an individual/business = POPIA is applicable, EVEN IF IT IS AUTOMATED.
  3. When PI is de-identified = POPIA is NOT applicable, subject thereto that neither you nor anyone else can think of a way to connect the information with a particular person/business.
  4. In terms of Section 3 of the Act, the Act stipulates the necessary requirements (“CONDITIONS”), which a Responsible Party must adhere.

What are examples of Personal Information (PI)?

Information about race, belief, political, trade union, health or criminal behavior, children PI, name & address, telephone number, e-mail address, age, medical record etc.

Exceptions are: prices, turnover, labelling information, product specifications, cost of sales and advertisements for example.

When is POPIA applicable to you?

​​​​​​​If you collect, use, store, copy, process, transfer PI of a person (individual) or a business (legal entity).

What are the eight compliance conditions of POPIA?

  1. Accountability
  2. Processing Limitation
  3. Purpose Specification
  4. Further Processing Limitation
  5. Information Quality
  6. Openness
  7. Security Safeguards
  8. Data Subject Participation

PAIA/POPIA Manuals

Notices

26 July 2021