THE HILTONIAN SOCIETY NPC (‘Society’)
THE OLD HILTONIAN CLUB (‘OHC’)
THE PROTECTION OF INFORMATION ACT No. 4, 2013 (‘Act’)
PRIVACY STATEMENT and GENERAL CONSENT
This statement explains how we obtain, use and disclose your personal information in accordance with the requirements of the Act. The Hiltonian Society NPC and The Old Hiltonian Club are committed to protecting your privacy and to ensure that your personal information (PI) is collected and used properly, lawfully and transparently.
By acknowledging this Privacy Statement, you hereby grant consent and permission for the Society and / or the OHC to collect and process PI for the lawful purposes consistent with the purposes for which such PI is collected and processed by the Society and/or the OHC.
PRINCIPLES OF COLLECTION
- PI will only be obtained for lawful purposes.
- PI will be processed in a reasonable manner that does not impinge on the privacy of the individual or organisation.
- PI will only be collected as necessary for the Society/OHC to conduct its business. The principle of minimality of collection will be applied.
- The Society/OHC undertakes to obtain specific consent wherever possible for the collection and processing of PI; however, there are instances where such consent may be tacit or verbal.
- PI will generally be collected directly from the data subject but subject to the provisions of S12 of the Act.
THE INFORMATION WE COLLECT AND PROCESS
PI will be collected to meet, and further, the aims of the Society/OHC and especially the principal operating activity of Hilton College. The definition of PI is contained in the Act, however in our context such will include, but not necessarily be limited to:
- Addresses, postal and physical
- Contact details including telephone/cell phone numbers and email addresses
- Banking details for payment of fee accounts
- Health and other ‘special information’
- PI in respect of children
It is specifically noted that as an educational institution PI is key to the activities carrying out education including, where appropriate and, in accordance with Part C of the Act, PI of children.
In carrying out its activities, by the very nature of a Christian ethos school and the maintaining of security and control of access, certain types of ‘special personal information’ are required. This will be processed in accordance with Part B of the Act.
In addition, the maintenance of an alumni database is common practice in educational institutions meaning that the Society/OHC will retain certain PI on an on-going, indefinite, basis to meet alumni record purposes.
Website usage information may be collected using ‘cookies’ which allows us to collect standard internet visitor usage information.
In maintaining and retaining PI the Society/OHC shall have reference to:
- The retention of records in accordance with the law.
- The period for which the Society requires the PI in order to carry out its activities including alumni relationship management.
- De-identify or destroy/delete PI records in a responsible manner that precludes reconstruction once it has no further use for them. Where possible a certificate of destruction of records will be obtained.
PI IS COLLECTED FROM
As the nature of the Society, OHC and Hilton College is founded on the relationship between people and these bodies, there are various persons, natural and juristic, who have an interest in being associated with each other.
These include but are not necessarily limited to:
- Interested and prospective parents and pupils and applicants for employment
- Current pupils
- Past pupils, the alumni
- Staff members, present and past
- Parents, present and past
- Governors, present and past
- Individuals and organisations regarded as being ‘Friends of Hilton’
- Donors and benefactors
- Persons and organisations associated with the Vula Programme at Hilton College
- Members of the Fleur-de-Lys Club
PROCESSING AND DISCLOSURE
Processing of PI will be conducted only where the purpose is consistent/compatible with the Society’s/OHC’s activities and objectives of the provision of education and inclusive of alumni relationship management.
Your PI may be disclosed under the following circumstances:
- Tour service providers who are involved in the delivery of product or services to you. They are required to comply with the provisions of the Act.
- Where we have a duty or a right to disclose in terms of law or industry codes.
- Where we believe it is necessary to protect our rights.
- With respect to alumni, for institutional history and heritage purposes and to alumni colleagues for social purposes, the promotion of collegiality, and retention of contact with their alma mater, as consistent with the Objects of the Constitution of The Old Hiltonian Club.
- Where such disclosure matches the legitimate purposes associated with each of the persons and organisations described above.
Further processing, if lawfully warranted, will only be carried out where it is compatible with the purpose of collection.
Condition 7 of the Act sets out the principles for the security and safeguarding of PI; however, in general terms, the Society/OHC in meeting its obligations thereunder will include:
- Minimising the number of electronic databases where PI is stored.
- Limiting and consolidating where practical the number of hard-copy records.
- Restricting access to hard-copy records.
- Instituting and maintaining a variety of electronic safeguards which include:
- Secured “V-lans”
- Password protection
- Data encryption where appropriate and practical
- Securely shredding hard-copy data either internally or via a reputable third-party provider who will provide a certificate of safe destruction.
- Denaturing, de-identifying and deleting and prevent from reconstruction electronic records.
- Employing physical barriers such as locks, access control mechanisms and security cameras.
- Regard all PI as confidential in nature and take all reasonable steps to prevent inappropriate disclosure whether accidentally or via unauthorised access
Where reasonable grounds for breach of security has occurred, the Society/OHC will be guided by S22 of the Act in notifying all specified persons and/or organisations.
You have the right to request a copy of the personal information we hold about you. To do this, please contact us in writing, or via electronic media, specifying what information you require. We will need a certified copy of your Identity Document or other suitable identification to authenticate your identity before providing the details of your PI. Please note that any such access request may be subject ta payment of a legally allowable fee. We also draw your attention to the procedure set out in our Promotion to Access of Information Manual which is accessible on the Hilton College website.
Whilst it is your right to withdraw consent tour processing of your PI, we draw your attention to the fact that such withdrawal may have unintended consequences relating to your contractual or other relationship with the Society/OHC.
INTEGRITY OF PERSONAL INFORMATION
As we are required to ensure that the PI we hold is accurate, we require that you regularly update us, in writing, of any changes to your PI so that we may amend our records accordingly. In providing us with changes, we will need a certified copy of your Identity Document or other suitable identification to authenticate the change(s).
In the context of providing education, information relating thereto, particularly to parents who are not locally resident, and alumni related activities, the Society/OHC need to employ the techniques afforded by modern electronic communication such as, but not limited to, specialist database platforms, bulk e-mails other similar e-notification methodologies, and social media. The Society/OHC will be guided by Chapter 8 of the Act in all such communication.
TRANS-BORDER INFORMATION FLOWS
The Society/OHC will be guided by Chapter 9 of the Act, however, it is recorded that the following types of activity give rise to trans-border information flows in accordance with the specified purpose of the organisation. These include but are not limited to:
- Pupils who are enrolled but who are normally resident outside South Africa.
- Alumni who are normally resident outside South Africa.
- The intention of pupils to enrol at educational institutions outside South Africa and where the provision of PI is necessary to facilitate enrolment.
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