Protection of Personal Information

In terms of POPIA and PAIA requirements

    1. Purpose

    This Policy sets out how Emergence Growth South Africa (“the Company”) provides access to Personal Information in accordance with the Protection of Personal Information Act, 2013 (POPIA) and the Promotion of Access to Information Act, 2000 (PAIA).

    2. Scope

    This Policy applies to all Personal Information held by the Company relating to employees, clients, suppliers, contractors and other data subjects.

    3. Principles For Access

    Access to Personal Information will:

    • Be lawful, reasonable and transparent
    • Be granted only where appropriate and permitted by law
    • Be subject to verification of the requester’s identity
    • Be limited to information required for the stated purpose

    4. Request Procedure

    All requests for access must:

    • Be submitted in writing using prescribed PAIA forms (where applicable)
    • Clearly identify the information requested
    • Specify the purpose for access
    • Include proof of identity

    The Company may:

    • Request additional information to verify identity
    • Charge prescribed fees in line with PAIA
    • Refuse access where legally justified

    5. Grounds For Refusal

    Access may be refused where:

    • It would unreasonably disclose personal information of another individual
    • It involves confidential, proprietary or commercially sensitive information
    • It relates to internal investigations, disciplinary processes or legal proceedings
    • It is restricted under any applicable law

    6. Internal Access Control

    Access to Personal Information within the Company is based on:

    • Role-based access control
    • “Need-to-know” and “least privilege” principles
    • Approved user access procedures

    User access must be:

    • Authorised and documented
    • Reviewed periodically
    • Removed upon termination or role change

    7. Information Security

    The Company will ensure that:

    • Personal Information is protected against unauthorised access
    • Appropriate technical and organisational safeguards are in place
    • Data is encrypted and securely transmitted where required

    8. Data Handling

    All Personal Information must be:

    • Stored securely (physical and electronic)
    • Shared only where authorised
    • Disposed of in accordance with the Document Retention Policy

    9. Data Subject Rights

    Data Subjects have the right to:

    • Access their Personal Information
    • Request correction or deletion
    • Object to processing (where applicable)

    Requests will be handled in accordance with POPIA requirements.

    10. Responsibilities

    The Information Officer is responsible for:

    • Oversight of access requests
    • Ensuring compliance with POPIA and PAIA
    • Maintaining records of requests and responses

    All employees are responsible for protecting Personal Information and complying with this Policy.

    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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