Special Personal Information Policy

In terms of POPIA Sections 26–33

    1. Purpose

    This Policy governs the processing of Special Personal Information by Emergence Growth South Africa (“the Company”) in accordance with the Protection of Personal Information Act, 2013 (POPIA).

    2. Scope

    This Policy applies to all employees, contractors, service providers and third parties who process Special Personal Information on behalf of the Company.

    3. Definition Of Special Personal Information

    Special Personal Information includes, but is not limited to:

    • Religious or philosophical beliefs
    • Race or ethnic origin
    • Trade union membership
    • Political persuasion
    • Health or biometric information
    • Sexual orientation
    • Criminal behaviour (where applicable)

    4. General Principle

    The Company will:

    • Only process Special Personal Information where permitted by law
    • Limit processing to what is strictly necessary
    • Ensure appropriate safeguards are in place

    5. Lawful Processing Conditions

    Special Personal Information may only be processed where:

    • The Data Subject has provided explicit consent
    • Processing is necessary for employment obligations
    • Processing is required by law
    • Processing is necessary to protect a legitimate interest

    6. Security Measures

    The Company will implement:

    • Strict access controls (need-to-know basis)
    • Enhanced security measures (encryption, restricted systems)
    • Confidentiality obligations for authorised personnel

    7. Access And Disclosure

    Special Personal Information:

    • May only be accessed by authorised personnel
    • Must not be shared without lawful justification
    • Must be disclosed only in line with POPIA requirements

    8. Data Minimisation

    The Company will:

    • Collect only the minimum necessary information
    • Avoid unnecessary duplication or storage

    9. Retention And Destruction

    Special Personal Information must:

    • Be retained only as long as necessary
    • Be securely destroyed when no longer required

    10. Reporting And Breaches

    Any breach involving Special Personal Information must:

    • Be reported immediately
    • Be handled in accordance with the Data Breach Policy

    11. Responsibilities

    Information Officer:

    • Oversees compliance and processing approvals

    Employees:

    • Must handle Special Personal Information with strict confidentiality

    12. Non-Compliance

    • Failure to comply may result in:
    • Disciplinary action
      • Legal consequences

    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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