SA Harvest is fully committed to ensuring the proper management and use of all personal information it collects and handles in accordance with applicable privacy laws, including the South African Privacy Principles and pledges its best efforts to that end.
This Policy does not apply to SA Harvest’s employee records and is subject to a separate Policy to ensure privacy is maintained in accordance with applicable privacy laws.
1. OPEN AND TRANSPARENT MANAGEMENT OF PERSONAL INFORMATION
- the kinds of Personal Information that SA Harvest collects and holds
- how and the purposes for which SA Harvest collects, holds and uses Personal Information
- who SA Harvest discloses Personal Information to
- how an individual may access Personal Information about the individual that is held by SA Harvest and seek the correction of such information
- how an individual may complain about a privacy issue or alleged breach of the South African Privacy Principles and how SA Harvest will deal with such a complaint
- whether SA Harvest is likely to disclose Personal Information to overseas recipients
2. WHAT PERSONAL INFORMATION SA Harvest COLLECTS, FROM WHOM AND THE PURPOSE FOR THE COLLECTION?
SA Harvest will only collect Personal Information that is necessary for its functions and activities. It will only collect Personal Information by lawful and fair means and not in an obtrusive way. SA Harvest collects and holds different categories of information depending on the engagement we have with you and the country and State and Territory that those services are being provided in. The following types of Personal Information may be collected:
Information about SA Harvest’s Contractors and Suppliers
SA Harvest collects, directly from our contractors and suppliers, Personal Information about our contractors and suppliers. This Personal Information will include their name and contact details so that we can contact them. For workplace health and safety reasons we may also collect from contractors certain Sensitive Information; for example, medical information a contractor has provided us about any injuries he or she may currently suffer.
From third parties, we may also collect feedback and information relating to our contractors and suppliers’ performance of services for SA Harvest. This information is collected solely so that we can monitor our contractors and suppliers’ performance of services and ensure that we provide the highest quality products and services to our customers.
Information about job applicants
If you apply for a position at SA Harvest we may collect from you your name, contact details and any information that you have provided us as part of your job application. This may include information contained your CV, driver’s licence or passport. We may also collect from third parties you have identified in your job application Personal Information relating to you. This information is solely used for the purposes of determining your suitability for the role that you have applied for. Or where permission is expressly provided for other suitable roles.
Information about donors, agencies and clients
When you become a donor, agency, client, participant or student we may collect Personal Information from you which is relevant for the engagement. This may or may not include such personal information as your name, contact details, bank account and credit card details.
All Personal Information collected by SA Harvest is solely used to achieve our Purpose. It may be used as follows:
- for donors and customers, details relating to billing purposes and order fulfilment
- for food recipient charities, to contact you in relation to the provision of food or other engagements
- to maintain your account details
- to provide food rescue support
- for general public and volunteers to provide you with information in relation to our programs, events, or other engagement opportunities that you may have requested
- to streamline and personalise your experience while dealing with SA Harvest
- to undertake satisfaction surveys and to tailor SA Harvest information to improve our offerings and enhance your experience
- your image, video and sound recordings for promotional and marketing and reporting purposes
- survey and questionnaire responses to improve our services, systems and processes in case of emergencies
Occasionally, SA Harvest uses de-identified Personal Information derived from our donors and clients in order to provide SA Harvest with anonymous demographic and usage information. SA Harvest will then use this anonymous, aggregated information to develop new and/or more appropriate services and support.
3. QUALITY OF PERSONAL INFORMATION
SA Harvest will ensure, to the extent reasonably possible, that Personal Information collected (may be in hard copy form or electronic form), used or disclosed is accurate, up-to-date, complete and relevant. If SA Harvest becomes aware that any of the Personal Information it holds is inaccurate it will take prompt steps to update its records so that those records are correct.
4. ANONYMITY AND PSEUDONYMITY
Due to the nature of the services that SA Harvest provides, in most situations it will be impracticable for an individual to deal with us on an anonymous basis. However, SA Harvest will consider requests on a case by case basis. An example of a situation where SA Harvest might permit an individual to deal with us anonymously or through the use of a pseudonym is when an individual is making an enquiry about our services or employment opportunities or if an individual makes a donation on an anonymous basis.
SA Harvest takes active measures to ensure the security of Personal Information (both hard copy form and electronic form), it holds from misuse, interference, loss and unauthorised access, modification or disclosure.
All Personal Information (both hard copy form and electronic form) is stored securely. Electronic Personal Information is stored using the high quality data management and IT security systems and controls including passwords and firewalls.
When we no longer require your Personal Information it is securely destroyed and disposed of.
Our security systems are regularly reviewed and audited so that we can identify any potential security weaknesses and take steps to promptly rectify them.
6. ACCESS AND CORRECTION OF PERSONAL INFORMATION
Subject to verification of your identity, if we hold Personal Information about you then you may make a request to access, update or correct this Personal Information at any time.
Any information change requests for access and correction should be made in writing to:
The Privacy Officer
Email: Privacy.Officer@SA Harvest.org
There is no fee to make a request for access to your Personal Information. However, we may charge you a processing fee if you request copies of your information.
We will endeavour to respond to written requests for access and correction of Personal Information within 15 business days after a request is received by us, unless extenuating circumstances exist.
7. DIRECT MARKETING
SA Harvest will only engage in direct marketing practices in accordance with the law.
SA Harvest may despatch marketing communications by telephone (eg: SMS messaging), electronic messages (eg: email), online (eg: websites and apps) and other means, unless you opt out or we are subject to legal restrictions. These may include communications relating to SA Harvest and its programs, educational and fundraising campaigns and promotional messages, event invitations and newsletters.
At any time, an individual or organisation may contact info@SA Harvest.org to request that they no longer receive any marketing material or information from SA Harvest.
For email and other modes of communication, SA Harvest also provides a simple opt-out (unsubscribe) mechanism that individuals can easily submit at any time.
8. OVERSEAS DISCLOSURE AND RETENTION OF PERSONAL INFORMATION
As part of our operations SA Harvest may store some Personal Information to cloud based service providers which retains Personal Information on servers that may be located in a number of overseas countries.
SA Harvest will take all reasonable steps to ensure that no person or entity, including any overseas entity breaches applicable privacy laws.
You are taken to expressly agree and consent to the transfer, storing or processing of your personal information outside of South Africa in submitting it to us. In providing consent, you understand and acknowledge that countries outside South Africa do not always have the same privacy protection requirements as South Africa in relation to personal information.
SA Harvest only retains Personal Information for as long as required by law and needed for our business functions and activities. It is then securely destroyed and disposed of.
If you do not agree to the transfer of your personal information outside South Africa, you should contact:
The Privacy Officer
Tel: (02) 9516 3877
G3/G4, 46-62 Maddox Street, Alexandria NSW 2015 South Africa
PO Box 7257, Alexandria NSW 2015 South Africa
9. THIRD PARTY DISCLOSURE
Your personal information may be provided to organisations and/or third parties that may include the following:
- external service providers where you are transferring to a service provider that is not part of us
- a government agency, as required by law
- third party service providers who assist us with the delivery of services or who provide services to or partner with us to enable us to deliver services, or in undertaking quality assurance of our services
- third party service providers who assist us with fundraising activities or strategy or in analysis of our fundraising activities, strategy or patterns
- third parties who assist us with co-ordination of volunteers, community activities and advocacy
- government or non-government agencies where we have a reasonable concern regarding your safety or wellbeing
- third parties who collate and/or analyse information for the purposes of research and advocacy
- third parties for the electronic storage of information, some of which may be overseas
Whilst we seek to ensure through our contracts with external parties that they comply with the Act regarding the use of your personal information, we have limited control around how some external parties (for example, government agencies) use your personal information.
Accessing SA Harvest’s websites will result in some information being logged including the time of access, your IP address and the pages that have been viewed or accessed.
SA Harvest’s websites may contain links to external websites. SA Harvest is not responsible for the content or privacy policies that govern these websites.
11.MANDATORY NOTIFIABLE DATA BREACHES
We will comply with the notification and other requirements of the Act where your personal information held by us has been inadvertently lost or disclosed or improperly accessed and that loss, disclosure or access may result in serious harm to you.
12.COVID-19 SIGN-IN TERMS AND CONDITIONS, COLLECTIONS NOTICE & DATA PROTECTION
As COVID-19 restrictions apply around South Africa, some States and Territories are managing the ongoing risks of the virus by issuing a Direction or Order requiring businesses to collect personal contact information about customers and visitors to their premises as a condition of particular businesses reopening and operating.
This document sets out how SA Harvest will collect, use, disclose and protect personal information collected from Visitors, Volunteers, Employees and all other persons who enter an SA Harvest site.
The purpose of the collection is to assist with COVID-19 contact tracing.
In compliance with a State or Health Authority Direction or Order that may apply to SA Harvest, and in the interest of enabling rapid detection and to control COVID-19 outbreaks, the collection of your personal information will be necessary for SA Harvest’s functions and activities.
This means the collection of contact information is permitted under the Privacy Act 1988 and SA Harvest abides by all applicable existing privacy laws and obligations where we operate and will:
- Only collect the personal information required under the Direction or Order and where necessary for SA Harvest’s functions and activities and will only be used for the purpose of contact-tracing for COVID-19 and will not be used for any other purpose.
- Notify all individuals before collecting the personal information: what information we are collecting; that the collection is required by law; the purposes of collection; who the information will be disclosed to and the consequences of failing to provide the information. SA Harvest will do this by displaying a prominent notice at the entrance to our premises and website or in any email invitation or App, and reiterating the information when we talk to our clients, stakeholders and all visitors to our premises.
- Securely store this information once it has been collected.Access to the information is restricted only to the Director of Governance, Risk & Compliance and Privacy Officer who see it and ensure that the information is secured and protected at all times.
- Only provide this information to relevant State and Territory health authorities who undertake contact tracing activities, when requested to do so.
- Delete this information once it is no longer reasonably necessary for the purpose of contact tracing.
All SA Harvest staff are made aware of the COVIDSafe App and encouraged to download the App and to support contract tracing if required by the authorities.
You may be refused entry into an SA Harvest site if you do not provide your contact details as required when you sign in on arrival at our premises or when completing your visitor record prior to your arrival.
Covid-19 Sign-in Terms & Conditions as at 7 September 2020.
13.ACCESS TO THIS POLICY
You can also request a free copy of it by contacting:
The Privacy Officer
SA Harvest NPC
All complaints relating to the handling and management of Personal Information by SA Harvest or any breach of the applicable privacy laws, including the South African Privacy Principles should be addressed to:
The Privacy Officer
SA Harvest NPC
In order to deal with complaints appropriately, please include the below information with your complaint:
- A summary of the privacy concern or alleged breach
- Any action, or inaction, SA Harvest has taken, or failed to take, regarding the matter
- Copies of any relevant documentation in connection with the complaint, including any communications that SA Harvest has had with you.
SA Harvest’s Privacy Officer will investigate the complaint, and, if necessary, may refer the complaint to the relevant department at SA Harvest that the complaint relates to. SA Harvest will endeavour to respond to complaints within 15 business days unless extenuating circumstances exist.
SA Harvest will take immediate steps to redress proven privacy concerns or breaches.
If you are not satisfied with SA Harvest’s response and your complaint relates to a privacy concern or alleged breach by one of SA Harvest’s South African affiliates, you may take your complaint to the Office of the South African Information Privacy Commission (Telephone: 1300 363 992).
This Policy is subject to regular review. It was last reviewed by the CFO and Privacy Officer on 8 September 2020.