Direct Marketing Policy

(In terms of the Protection of Personal Information Act, 4 of 2013)

    1. Purpose

    This Policy regulates direct marketing activities conducted by Emergence Growth South Africa (“the Company”) in compliance with Section 69 of POPIA.

    2. Scope

    This Policy applies to all electronic direct marketing communications sent to customers, prospects, suppliers and business contacts.

    3. Definition

    Direct Marketing means any communication sent directly to a Data Subject to promote products, services, events or brand awareness.

    4. Lawful Basis for Direct Marketing

    The Company will only conduct electronic direct marketing where:

    • The Data Subject has provided prior consent (opt-in); or
    • The Data Subject is an existing customer and marketing relates to similar products/services, with an option to opt-out

    5. Consent (Opt-In)

    Consent must be:

    • Voluntary
    • Specific
    • Informed

    The Company will obtain consent through:

    • Website sign-ups
    • Event registrations
    • Direct engagement (e.g. business cards, email requests)

    The Company does not use third-party marketing lists unless valid consent can be demonstrated.

    2. Scope

    This Policy applies to all employees, contractors, and third parties who access or process information in any format (electronic or physical).

    3. Data Classification Levels

    All information must be classified into one of the following categories:

    • Restricted (High Risk)
      Sensitive information requiring strict protection.
      Examples: ID numbers, financial data, passwords, health information.
    • Confidential (Medium Risk)
      Internal business and operational information.
      Examples: contracts, employee records, supplier agreements.
    • Public (Low Risk)
      Information approved for public disclosure.
      Examples: marketing materials, website content.

    4. Responsibilities

    Information Officer:

    • Oversee implementation of this Policy
    • Ensure compliance with POPIA

    Data Owners:

    • Classify information appropriately
    • Review classifications regularly

    Data Custodians (IT):

    • Implement technical controls
    • Ensure secure storage and backups

    Users:

    • Handle data according to its classification
    • Report any misuse or breaches

    5. Classification Process

    Information must be classified based on:

    • Sensitivity of the data
    • Risk of unauthorised disclosure
    • Legal and regulatory requirements

    Where uncertainty exists, the higher classification level must be applied.

    6. Handling Requirements

    Restricted:

    • Encryption required
    • Strict access control
    • Secure transmission

    Confidential:

    • Access limited to authorised users
    • Protected storage

    Public:

    • No special restrictions

    6. Opt-Out

    All marketing communications will include a clear and easy opt-out mechanism.

    Data Subjects may opt-out at any time by:

    Opt-out requests will be actioned promptly.

    7. Types Of Communication

    The Company may send:

    • Event invitations
    • Industry insights and updates
    • Product and service information
    • Company news

    8. Data Accuracy

    The Company will periodically review contact details and preferences to ensure information is accurate and up to date.

    9. Data Protection

    All Personal Information used for marketing will be processed in accordance with the Company’s

    Privacy Notice and Data Protection Policy.

    10. Prohibited Practices

    The Company will not:

    • Send unsolicited marketing without lawful basis
    • Share Personal Information for marketing without consent
    • Ignore opt-out requests

    11. Responsibilities

    Information Officer:

    • Oversees compliance with POPIA

    Employees:

    • Must ensure marketing is conducted lawfully
    • Must respect opt-out requests

    Updates to this Policy

    The Company reserves the right to amend this Policy at any time to ensure ongoing compliance with applicable legislation and best practices.

     

    Updated March 2026

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