[divex_textheader heading=”POPI ACT COMPLIANCE POLICY” _builder_version=”4.9.4″ header_text_align=”center”][/divex_textheader]

1. Preamble

To promote the protection of personal information processed by Umsinsi Health Care and to introduce conditions to establish minimum requirements for the processing of personal information.

2. Introduction

The Protection of Personal Information Act of South Africa describes how organisations including Umsinsi Health Care (Pty) Ltd – must collect, handle and store personal information. These rules apply regardless of whether data is stored electronically, on paper or on other materials.

Umsinsi Health Care (Pty) Ltd needs to gather and store certain personal information belonging to individuals. These can include customers, suppliers, business contacts, employees, and other people the organisation has a relationship with or may need to contact.

This policy describes how personal data is collected, handled, and stored to meet the company’s standards and to comply with the law.

3. Purpose

This policy ensures Umsinsi Health Care (Pty) Ltd:

 

  1. Complies with protection of personal information law and follows good practice.
  2. Protects the rights of staff, customers, and partners.
  3. Is open about how it stores and processes individuals’ data.
  4. Protects itself from the risks of a data breach.

4. Definitions

  1. Company/Business – Umsinsi Health Care (Pty) Ltd Consent’’ means any voluntary, specific, and informed expression of will in terms of which permission is given for the processing of personal information.
  2. Data subject’’ means the person to whom personal information relates.
  3. Filing system’’ means any structured set of personal information, which is accessible according to specific criteria.
  4. Information officer – An employee delegated by the Managing Director of Umsinsi Health Care (Pty) Ltd with the authority and duties of Information Officer contemplated in terms of section 1 of POPIA,
  5. Personal Information:’ means information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, including, but not limited to:
    • information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of the person; information relating to the education or the medical, financial, criminal or employment history of the person;
    • any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier or other particular assignment to the person;
    • the biometric information of the person;
    • the personal opinions, views or preferences of the person;
    • the views or opinions of another individual about the person; and
    • the name of the person if it appears with other personal information relating to the person or if the disclosure of the name itself would reveal information about the person;

5. Principles

To comply with the law, personal information will be collected and used fairly, stored safely and not disclosed unlawfully.

The policy is underpinned by the following principles. Personal data must:

 

  1. Be processed fairly and lawfully.
  2. Be obtained only for specific, lawful purposes.
  3. Be adequate, relevant, and not excessive.
  4. Be accurate and kept up to date.
  5. Not be held for any longer than necessary.
  6. Processed in accordance with the rights of data subjects.

6. Policy Scope

This policy applies to all staff of Umsinsi Health Care (Pty) Ltd and all contractors, volunteers, suppliers, and other people working on behalf of Umsinsi Health Care (Pty) Ltd.

It applies to all information that the company holds relating to identifiable individuals. This can include Names of individuals, Postal addresses, Email addresses, Telephone numbers and any other information relating to individuals.

7. Data Protection Risks

This policy helps to protect Umsinsi Health Care (Pty) Ltd from some very real data security risks, including:

 

  1. Breaches of confidentiality. For instance, information being given out inappropriately.
  2. Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
  3. Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

8. Responsibilities

Everyone who works for or with Umsinsi Health Care (Pty) Ltd has some responsibility for ensuring data is collected, stored, and handled appropriately.

 

  1. Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.
  2. Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.
  3. The Umsinsi Leadership Team is ultimately responsible for ensuring that Umsinsi Health Care (Pty) Ltd meets its legal obligations.
  4. The Information Officer as provided for by POPIA, duly appointed and assigned by the Managing Director and registered with the Regulator, is responsible for:UHC POPIA POLICY Page3 of 5
    • Keeping the policy and Leadership Team updated about data protection responsibilities, risks, and issues.
    • Reviewing all data protection procedures and related policies, in line with an agreed schedule.
    • Arranging data protection training and advice for the people covered by this policy.
    • Handling data protection questions from staff and anyone else covered by this policy.
    • Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
  5. The IT manager, (Outsourced Service) is responsible for:
    1. Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
    2. Performing regular checks and scans to ensure security hardware and software is functioning properly.
    3. Evaluating any third-party services, the company is considering using to store or process data. For instance, cloud computing services.
    4. Approving, uploading any data protection statements attached to communications such as emails and letters.
  6. General Staff Guidelines
    1. The only people able to access data covered by this policy should be those who need it for their work.
    2. Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
    3. Employees should keep all data secure, by taking sensible precautions and following the guidelines below. In particular,
      • Strong passwords must be used, and they should never be shared.
      • Personal data should not be disclosed to unauthorised people, either within the company or externally.
      • Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
      • Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.
      • Report incidents where their password is compromised or suspected to be.

9. Data Storage

These rules describe how and where data should be safely stored. When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

 

  1. When not required, the paper or files should be kept in a locked drawer or filing cabinet.
  2. Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
  3. Data printouts should be shredded and disposed of securely when no longer required.
  4. When data is stored electronically, it must be protected from unauthorised access, accidental deletion, and malicious hacking attempts:
  5. Data should be protected by strong passwords that are changed regularly and never shared between employees.
  6. If data is stored on removable media these should be kept locked away securely when not being used.
  7. Data should only be stored on designated drives and servers and should only be uploaded to an approved cloud computing service.
  8. Servers containing personal data should be sited in a secure location, away from general office space.
  9. Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
  10. Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
  11. All servers and computers containing data should be protected by approved security software and a firewall.

10. Data Use

  1. When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
  2. Personal data should not be shared informally. It should never be sent by email, as this form of communication is not secure.
  3. Data must be encrypted before being transferred electronically.
  4. Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

11. Data Accuracy

The law requires Umsinsi Health Care (Pty) Ltd to take reasonable steps to ensure data is kept accurate and up to date. It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

 

  1. Staff should not create any unnecessary additional data sets.
  2. Umsinsi Health Care (Pty) Ltd will make it easy for data subjects to update the information company holds about them.
  3. Data should be updated as inaccuracies are discovered.

12. Data Access and Rights

All individuals who are the subject of personal data held by Umsinsi Health Care (Pty) Ltd are entitled to:

 

  1. Ask what information the company holds about them and why.
  2. Ask how to gain access to it.
  3. Be informed how to keep it up to date.
  4. Be informed how the company is meeting its data protection obligations.
  5. Subject access requests from individuals should be made by email, addressed to the data controller at compliance@uhcare.co.za .
  6. The data controller will aim to provide the relevant data within 14 days.
  7. The data controller will always verify the identity of anyone making a subject access request before handing over any information.

13. Disclosing Data for Other Reasons.

In certain circumstances, the policy allows personal data to be disclosed to law enforcement agencies without the consent of the data subject. Under these circumstances, Umsinsi Health Care (Pty) Ltd will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.

14. Providing Information

Umsinsi Health Care (Pty) Ltd aims to ensure that individuals are aware that their data is being processed safely, used correctly as per policy, and securely stored:

 

  1. To this end, the Umsinsi Health Care (Pty) Ltd has a privacy statement, setting out how data relating to individuals is used by the company.