2. PERSONAL INFORMATION 

Forsurance Lifestyle Consultants (Pty) Limited aligns itself with the Protection of Personal Information Act of 2013 (POPIA) in handling of any information obtained by FLC in the interaction with all our platforms such as the Website, Apps and other physical means such as Application Forms containing such information that can be classified as personal information in terms of the Act. Such information consists of information such as age, race, gender, identity number, postal or street address, marital status, biometric information, financial, criminal or employment information. 

The act of processing information includes any activity or any set of operations, whether by automatic means, concerning personal information and includes: ▪ the collection, receipt, recording, Forsurance Lifestyle Consultants, collation, storage, updating or modification, retrieval, alteration, consultation or use. FORSURANCE LIFESTYLE CONSULTANTS (PTY) LIMITED PRIVACY POLICY 1 ▪ dissemination by means of transmission, distribution or making available in any other form; or ▪ merging, linking, as well as any restriction, degradation, erasure or destruction of information. 

4. RIGHTS OF DATA SUBJECTS Data Subject refers to the natural or juristic person to whom personal information relates, such as an individual client, customer or a company that supplies the Forsurance Lifestyle Consultants with products or other goods. Where appropriate, the Forsurance Lifestyle Consultants will ensure that its clients and customers are made aware of the rights conferred upon them as data subjects. The Forsurance Lifestyle Consultants will ensure that it gives effect to the following seven rights. 

4.1 The Right to Access Personal Information The Forsurance Lifestyle Consultants recognises that a data subject has the right to establish whether the Forsurance Lifestyle Consultants holds personal information related to him, her or it includes the right to request access to that personal information. 

4.2 The Right to have Personal Information Corrected or Deleted The data subject has the right to request, where necessary, that his, her or its personal information must be corrected or deleted where the Forsurance Lifestyle Consultants is no longer authorised to retain the personal information. 

4.3 The Right to Object to the Processing of Personal Information The data subject has the right, on reasonable grounds, to object to the processing of his, her or its personal information. In such circumstances, the Forsurance Lifestyle Consultants will consider the request and the requirements of POPIA. The Forsurance Lifestyle Consultants may cease to use or disclose the data subject’s personal information and may, subject to any statutory and contractual record keeping requirements, also approve the destruction of the personal information. 

4.4 The Right to Object to Direct Marketing The data subject has the right to object to the processing of his, her or its personal information for purposes of direct marketing by means of unsolicited electronic communications. 

4.5 The Right to Complain to the Information Regulator The data subject has the right to submit a complaint to the Information Regulator regarding an alleged infringement of any of the rights protected under POPIA and to institute civil proceedings regarding the alleged non-compliance with the protection of his, her or its personal information. 

4.6 The Right to be Informed The data subject has the right to be notified that his, her or its personal information is being collected by the Forsurance Lifestyle Consultants . The data subject also has the right to be notified in any situation where the Forsurance Lifestyle Consultants has reasonable grounds to believe that the personal information of the data subject has been accessed or acquired by an unauthorised person. 

5. FORSURANCE LIFESTYLE GENERAL GUIDING PRINCIPLES 

All employees and persons acting on behalf of the Forsurance Lifestyle Consultants will at all times be subject to, and act in accordance with, the following guiding principles: 

5.1 Accountability 

Failing to comply with POPIA could potentially damage the Forsurance Lifestyle Consultants ’s reputation or expose the Forsurance Lifestyle Consultants to a civil claim for damages. The protection of personal information is therefore everybody’s responsibility. The Forsurance Lifestyle Consultants will ensure that the provisions of POPIA and the guiding principles outlined in this policy are complied with through the encouragement of desired behaviour. However, the Forsurance Lifestyle Consultants will take appropriate sanctions, which may include disciplinary action, against those individuals who through their intentional or negligent actions and/or omissions fail to comply with the principles and responsibilities outlined in this policy. 

5.2 Processing Limitation 

The Forsurance Lifestyle Consultants will ensure that personal information under its control is processed: ▪ in a fair, lawful and non-excessive manner, and ▪ only with the informed consent of the data subject, and ▪ only for a specifically defined purpose. The Forsurance Lifestyle Consultants will inform the data subject of the reasons for collecting his, her or its personal information and obtain written consent prior to processing personal information. Alternatively, where services or transactions are concluded over the telephone or electronic video feed, the Forsurance Lifestyle Consultants will maintain a voice recording of the stated purpose for collecting the personal information followed by the data subject’s subsequent consent. The Forsurance Lifestyle Consultants will under no circumstances distribute or share personal information between separate legal entities, associated Forsurance Lifestyle Consultants s (such as subsidiary companies) or with any individuals that are not directly involved with facilitating the purpose for which the information was originally collected. Where applicable, the data subject must be informed of the possibility that their personal information will be shared with other aspects of the Forsurance Lifestyle Consultants ’s business and be provided with the reasons for doing so. 

5.3 Purpose Specification 

All the Forsurance Lifestyle Consultants ’s business units and operations must be informed by the principle of transparency. The Forsurance Lifestyle Consultants will process personal information only for specific, explicitly defined and legitimate reasons. The Forsurance Lifestyle Consultants will inform data subjects of these reasons prior to collecting or recording the data subject’s personal information. 

5.4 Further Processing Limitation

Personal information will not be processed for a secondary purpose unless that processing is compatible with the original purpose. Therefore, where the Forsurance Lifestyle Consultants seeks to process personal information it holds for a purpose other than the original purpose for which it was originally collected, and where this secondary purpose is not compatible with the original purpose, the Forsurance Lifestyle Consultants will first obtain additional consent from the data subject. 

5.5 Information Quality 

The Forsurance Lifestyle Consultants will take reasonable steps to ensure that all personal information collected is complete, accurate and not misleading. The more important it is that the personal information be accurate (for example, the beneficiary details of a life insurance policy are of the utmost importance), the greater the effort the Forsurance Lifestyle Consultants will put into ensuring its accuracy. Where personal information is collected or received from third parties, the Forsurance Lifestyle Consultants will take reasonable steps to confirm that the information is correct by verifying the accuracy of the information directly with the data subject or by way of independent sources. 

5.6 Open Communication 

The Forsurance Lifestyle Consultants will take reasonable steps to ensure that data subjects are notified (are always aware) that their personal information is being collected including the purpose for which it is being collected and processed. The Forsurance Lifestyle Consultants will ensure that it establishes and maintains a “contact us” facility, for instance via its website or through an electronic helpdesk, for data subjects who want to: ▪ Enquire whether the Forsurance Lifestyle Consultants holds related personal information, or ▪ Request access to related personal information, or ▪ Request the Forsurance Lifestyle Consultants to update or correct related personal information, or ▪ Make a complaint concerning the processing of personal information. 

5.7 Security Safeguards 

The Forsurance Lifestyle Consultants will manage the security of its filing system to ensure that personal information is adequately protected. To this end, security controls will be implemented to minimise the risk of loss, unauthorised access, disclosure, interference, modification or destruction. Security measures also need to be applied in a context-sensitive manner. For example, the more sensitive the personal information, such as medical information or credit card details, the greater the security required. The Forsurance Lifestyle Consultants will continuously review its security controls which will include regular testing of protocols and measures put in place to combat cyber-attacks on the Forsurance Lifestyle Consultants ’s IT network. The Forsurance Lifestyle Consultants will ensure that all paper and electronic records comprising personal information are securely stored and made accessible only to authorised individuals. All new employees will be required to sign employment contracts containing contractual terms for the use and storage of employee information. Confidentiality clauses will also be included to reduce the risk of unauthorised disclosures of personal information for which the Forsurance Lifestyle Consultants is responsible. All existing employees will, after the required consultation process has been followed, be required to sign an addendum to their employment containing the relevant consent and confidentiality clauses. The Forsurance Lifestyle Consultants ’s operators and third-party service providers will be required to enter into service level agreements with the Forsurance Lifestyle Consultants where both parties pledge their mutual commitment to POPIA and the lawful processing of any personal information pursuant to the agreement.  

5.8 Data Subject Participation 

A data subject may request the correction or deletion of his, her or its personal information held by the Forsurance Lifestyle Consultants . The Forsurance Lifestyle Consultants will ensure that it provides a facility for data subjects who want to request the correction of deletion of their personal information. Where applicable, the Forsurance Lifestyle Consultants will include a link to unsubscribe from any of its electronic newsletters or related marketing activities. 

6. REQUEST TO ACCESS PERSONAL INFORMATION PROCEDURE 

Data subjects have the right to: ▪ Request what personal information the Forsurance Lifestyle Consultants holds about them and why. 

▪ Request access to their personal information. 

▪ Be informed how to keep their personal information up to date. Access to information requests can be made by email, addressed to the Information Officer at infoofficer@forsurancelifestyle.co.za . The Information Officer will provide the data subject with a “Personal Information Request Form.” Once the completed form has been received, the Information Officer will verify the identity of the data subject prior to handing over any personal information. 

All requests will be processed and considered against the Forsurance Lifestyle Consultants ’s PAIA Policy. The Information Officer will process all requests within a reasonable time. 

7. FEEDBACK 

Should you have any questions about this policy or would like to register a complaint please contact the Information Officer on the details below: 

Information Officer: Justice Makhanya 

Phone Number: +27(10) 502 1842 

Email address: infoofficer@forsurancelifestyle.co.za 

Postal address: 24 Vermotten Street, Brackenhurst, Alberton, 1451