Privacy and Personal Information Policy

Introduction and the meaning of personal information

1. This privacy policy (“the policy”) governs the way in which i-Tell, a division of Insiox Detection (Pty) Ltd, will manage your personal information and any other data we have collected from, or which was submitted by you as a user of this website.

2. This policy should be read with our Terms of Use, and any word used in this policy that is defined in the Terms of Use, shall carry the meaning so defined.

3. In essence South African legislation, through the Protection of Personal Information Act (“POPIA”) defines the term “personal information” to include:

  • your 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;
  • your education;
  • your medical, financial, criminal or employment history;
  • your ID number, symbol, e-mail address, physical address, telephone number, location, online identifier or other particular assignment;
  • your biometrics;
  • your personal opinions, views or preferences;
  • correspondence sent by you that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence;
  • the views or opinions of others about you;
  • your name, but only if your name appears with other personal information about you, or your name itself would reveal information about you;
  • your views about the proposal of a grant, award or prize to another person.

4. We also treat personal information to include “personal data” as defined in the European General Data Protection Regulation (“GDPR”), being any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

5. We take your privacy very seriously and we shall take all reasonable steps to ensure that your personal information and data are protected.

6. This policy is governed by the laws of South Africa.

7. We reserve the right to amend this policy from time to time. By continuing to access this website you agree to be bound by these terms.

The sharing of your personal information

  1. As a starting point we treat any personal information we gather about you, and any data collected from you, or any Content you have provided, as confidential.
    We will only disclose your personal information to other persons on the grounds as recorded in this policy.
  2. We may disclose it if you have expressly consented thereto. You will have the choice to provide your personal information on the basis of anonymity, or not to provide it at all.
  3. We shall disclose it if we, in good faith, believe that we are compelled to do so in terms of South African law. We follow the law, and if it requires of us to disclose your personal information, we have no choice but to comply. If there is a legal basis upon which we should rely to refuse the disclosure of your personal information, we shall rely thereon.
  4. We shall disclose it if compelled to do in terms of a court order. As a general rule you will receive notice of court proceedings which may lead to the disclosure of your personal information.
  5. If we are compelled, by law or court order, to reveal your personal information, we shall inform you, if at all possible, prior to the disclosure thereof.

Whistleblower reports

1. We collect and receive Content, through whistleblowing reports, on a continuous basis.

2. Whistleblowers will have a choice to disclose Content and personal information anonymously. Where you, as a whistleblower, provide Content or personal information on the basis of anonymity, we will accept that that such Content and/or personal information was provided:

  • in circumstances where criminal or civil proceedings might be contemplated;
  • in circumstances where you would regard the disclosure of your personal
  • information as unreasonable;
  • as commercially sensitive; and/or
  • in confidence.

3. Unless we are compelled to do so under South African law or in terms of a court order as already explained, your personal information, if you are a whistleblower, will only be processed and used in relation to the report you made, and only to:

  • contact you to provide feedback;
  • contact you to clarify details reported; or
  • provide your personal information to the relevant i-Tell client, if you consented thereto.

4. We record, process and analyse Content and personal information within a secure cloud based environment.

5 All our employees and staff members are bound to non-disclosure agreements and only designated individuals will be granted access to any Content you have provided and to your personal information.

How data reaches us

  1. You can provide your personal information to us by submitting your details in the various web forms, or providing it via the chat functions on the website.
  2. Whilst we have taken great care in ensuring a safe and secure form to e-mail submission process, you use such form to e-mail processes at your own risk.
  3. If you do not provide your personal information, and subject to our cookie policy, we will not have access to it.

The collection and retention of personal information

  1. We only collect, process and collate the personal information you have voluntarily shared with us directly or through our trusted third parties.
  2. Sharing your personal information with us has the effect of also consenting to us retaining and storing it.
  3. We will retain, store and keep a record of personal information for as long as we are required by law to do so.
  4. If we disclose your personal information to another person (whether with your consent, or in terms of our obligations under the law or a court order), we will also keep a record of that disclosure, including with whom we shared it, the date we did so and the purpose or reason of the disclosure. You are entitled to this information.
  5. We are committed to keeping your personal information safe and secure from unlawful access and we preserve and maintain your personal information only to accomplish the purpose for which it was intended and to comply with applicable legal requirements.
  6. We will not attempt to link information contained on our website logs with the users of our website.
  7. We do not sell or rent web-generated mailing lists or any other format of personal information, and we will never share your personal information, or any mailing lists we may have compiled, with external organisations. While we retain relevant information to enable us to contact you (if you provided your contact details), we will not provide this information, without your express consent, to external organisations.