Privacy Policy for COMENSA
Comensa is accountable for the processing of personal information of a data subject in a safe and responsible manner. This Privacy Policy explains why and how COMENSA collects, uses and stores personal information. The processing of personal data must be transparent and secure, and in conformity with the Protection of Personal Information Act 4 of 2013 (“POPIA”).
- When data subjects have day-to-day dealings with COMENSA, some personal information may be obtained.
- ‘Personal information’ is defined in POPIA. In essence it refers to any information that can be used to identify a data subject. A data subject is any person, living or juristic, to whom the personal information relates and that engages with COMENSA.
- POPIA is aimed at protecting data subjects’ personal information and prescribes what COMENSA may and may not do with it.
- As COMENSA is accountable for living up to the principles set out in POPIA, it has in place privacy compliance measures which it uses to monitor and enforce its compliance with these principles.
- When complying with POPIA, COMENSA will ensure that it acts with integrity and fairness and will always balance the rights of both, data subjects and COMENSA’s, in an objective manner.
1. Purpose and objectives
- COMENSA is the national non-profit professional representative body of Coaches and Mentors in the Republic of South Africa. It comprises a Head Office and Provincial Chapters set up in various jurisdictions. To understand its objects and services please view the various links on the website.
- ‘The principal place of business is 250 Hall Street, Die Hoewes, Centurion, 0046.
- The Information Officers may be reached at one of the following email addresses :
2. Details and Contact Information of COMENSA
- This Privacy Policy applies under several different circumstances and may, in relation to COMENSA, include the following examples (which are not exhaustive):
- When using any of its products or services;
- When applying to be a volunteer or for employment;
- When supplying services and/or providing any personal information to fulfil the service contract;
- When data subjects are operators of COMENSA’s clients, if applicable; and/or
- When any information is collected from or shared with any third parties.
- This Privacy Policy applies to COMENSA’s website, applications, and online services, social media platforms as well as any publications or newsletters that COMENSA may publish.
- Some personal information may be shared with operators/contractors in order to deliver COMENSA’s services and products. If this is the case, they are bound by and adhere to this policy as well.
3. Application
- COMENSA collects information that is directly and voluntarily provided to it.
- COMENSA will collect personal information from the data subject when :
- Any person engages or supplies COMENSA with or uses their services,
- A data subject communicates with COMENSA via forms, email or uses any other channel, not specifically mentioned here.
- Any person uses the online self- serve platform,
- A person subscribes to newsletters or responds to advertisements, competitions or requests for information.
- The information that data subjects provide may include current and historical personal information including name, contact details, title, identification, employment, positions held, enquiry/complaint details and information about the organisation with which the data subject is affiliated.
- Information may also be sourced from employers, regulatory authorities, recruitment agencies, credit ratings agencies, information or service providers, public records and other third parties.
- COMENSA may also collect personal information through other dealings, including through any contact made in person, by telephone, email or online.
4. The Information COMENSA Collects
- COMENSA may also collect information about data subjects from public sources including social media platforms.
- COMENSA advises data subjects to familiarise themselves with the respective privacy policies that apply to these platforms. Note that COMENSA will process any information from these sources in accordance with the law.
5. Information Collected from Other Sources
- COMENSA does not collect children’s personal information without the consent of their parents or guardians. If a data subject is under the age of 18, the data subject should not provide any personal information to COMENSA without the written consent of their parent or guardian.
- COMENSA reserves the right to ask for proof of consent or proof of age if it suspects that it is engaging with a child under the age of 18 years.
6. Children’s Personal Information
- COMENSA use personal information to :
- provide products and services
- send membership or credentialing renewal notices
- respond to enquiries
- send invitations to COMENSA events
- send updates and newsletters on the latest developments within COMENSA and in the coaching and mentoring industry
- enable seamless payment to our suppliers.
- COMENSA will not further process personal information without first assessing whether:
- The further processing is compatible with the reasons the data subject initially provided the information; or
- The data subject has consented to further processing of personal information; or
- If it is in accordance with the law.
- COMENSA will not contact a data subject for unsolicited marketing purposes either telephonically, by mail, SMS or email if the data subject has not opted in to receive these communications. It may however contact its members and data subjects who have consented to be on its mailing lists. Data subjects who wish to no longer receive communication have the option to opt out.
7. What COMENSA uses the Personal Information For
- When a data subject responds to an application for a vacancy, either as an employee or volunteer, a curriculum vitae (“CV”) which contains personal and special personal information is usually provided to COMENSA.
- COMENSA may request further personal and special personal information about education, employment, race and state of health. As part of the application, the data subject must provide their consent to use of the information to fulfil any recruitment testing assessments and activities which may be required from employers under applicable laws.
- These will include the option to carry out various screening checks and to consider the data subject for other positions. In order to conduct the screening checks COMENSA may share aspects of the personal information with inter alia: academic institutions, credit bureaus, medical providers, professional and trade associations, law enforcement agencies, referees and your current and previous employers.
- COMENSA may also gather additional information from publicly available resources such as LinkedIn, Facebook or other social or professional media platforms and collate this with the information that the applicant data subject provided to COMENSA. Where consent is not explicitly provided, COMENSA reserves the right not to progress the application.
- COMENSA will keep the personal information for as long as it is necessary during the recruitment process.
- If the applicant is successful, COMENSA will retain the personal information in accordance with South African labour law legislation.
- If the applicant is unsuccessful or withdraws the application, COMENSA will dispose of information safely and securely.
- These processes will apply to both, employees and volunteers.
8. Information Provided due to a Vacancy or Volunteerism
- COMENSA may also be legally or contractually obliged to collect information from data subjects to conduct business, for example, where COMENSA is required by law to gather personal information for labour, health, tax, BBBEE, FICA, SAQA and NQF requirements.
- Suppliers may be required to provide personal information for overall legal compliance including processing of payments/ accounts, identity checks, reference checks, assessment of financial records, bank account numbers, taxpayer compliance status and contact details verification.
- Where relevant, COMENSA may advise of the details that COMENSA are required to collect.
- Data subjects may also request the reason for such collection of information.
9. Legal or Contractual Obligations to Collect Information
- COMENSA’s offices may be monitored by CCTV cameras for safety and the prevention of crime. The footage is stored in a secure location by a third-party service provider.
10. CCTV cameras
- COMENSA will not use or share personal information with any person outside of COMENSA unless it is for a business purpose.
- COMENSA will not use or share personal information with any person outside of COMENSA unless it is for a business purpose.
- In order to deliver products and services and for the efficient running of business, COMENSA uses third-party service providers/operators. At times, COMENSA will share data subjects’ personal information with these third-party service providers/ operators. For this reason, COMENSA signs confidentiality/operator agreements and ensures that they operate under strict requirements aimed at keeping personal information secure and confidential and that the said information is used for the purpose for which it is provided. To access COMENSA’s current service provider’s Privacy Policy, Click here.
- COMENSA may also share personal information with banking institutions and credit providers, and governmental, judicial, regulatory and law enforcement bodies and agencies, if required.
11. Sharing of Information
- COMENSA will not retain data subjects’ personal information for longer than is necessary unless consent has been received or it is required by law or it is for the purposes of a contract. Personal Information that is no longer required is securely disposed of or is deidentified as soon as reasonably practicable after it is no longer authorised to be retained.
12. Retention of Records
- COMENSA has taken every reasonable and affordable measure, to keep personal information in a secure, reliable and protected place, free from unauthorised access.
- COMENSA regularly monitors its information technology systems for possible vulnerabilities and cyber-attacks. To this end, COMENSA deploys reasonable security safeguards.
- Although COMENSA has measures in place to minimise security threats, COMENSA cannot guarantee data breaches will not happen and therefore also encourages data subjects to have their own security measures in place.
- In the unlikely event of personal information being compromised, COMENSA will follow the guidelines and processes provided by POPIA.
13. Security
- COMENSA also has a self-serve platform which enables data subjects who are registered as members or Friends of Comensa to upload, view, amend their personal information.
- Data subjects may, via the COMENSA website and through an email link elect to be added to the respective mailing lists for communication on the COMENSA initiatives available.
- Data subjects may, also at any time and at no cost, elect to update their preferences or stop receiving the communication by clicking the “unsubscribe” link on the email.
- Data subjects also have the right to know what personal information COMENSA have about the said data subject, to correct it, request its deletion and to determine if COMENSA has shared the personal information with third parties.
- Data subjects may also object to the processing of their personal information. Any of these requests must be in writing on the prescribed form. It may take up to 5 working days to respond to a request and a small fee may be charged.
- If a data subject or member requires a deletion of their personal information, COMENSA may need to terminate all agreements with that data subject as COMENSA cannot maintain relationships without having some personal information.
- COMENSA also retains the right to refuse to delete some personal information if the information is required to be kept in terms of the membership contract, by law or if COMENSA is required it to protect its rights.
14. Data Subjects Rights
- Should a data subject require more information on COMENSA’s Privacy Policy, or needs to submit a request, please contact COMENSA’s Information Officer, as per details above.
- POPIA mandates the Information Regulator to oversee that COMENSA manages personal information in a responsible manner that respects data subject’s privacy. While COMENSA make every effort to assist data subjects, should you have any further queries or be unhappy, you may contact the Information Regulator whose contact details may be found at https://www.justice.gov.za/inforeg/contact.html.
15. Contact Details
- From time to time, COMENSA may amend this policy to accommodate changes in its business and/or if legislative amendments require change.
16. Updated Policy
COMENSA is committed to protecting personal information and adhering to POPIA.
Privacy Policy for COMENSA
Comensa is accountable for the processing of personal information of a data subject in a safe and responsible manner. This Privacy Policy explains why and how COMENSA collects, uses and stores personal information. The processing of personal data must be transparent and secure, and in conformity with the Protection of Personal Information Act 4 of 2013 (“POPIA”).
- When data subjects have day-to-day dealings with COMENSA, some personal information may be obtained.
- ‘Personal information’ is defined in POPIA. In essence it refers to any information that can be used to identify a data subject. A data subject is any person, living or juristic, to whom the personal information relates and that engages with COMENSA.
- POPIA is aimed at protecting data subjects’ personal information and prescribes what COMENSA may and may not do with it.
- As COMENSA is accountable for living up to the principles set out in POPIA, it has in place privacy compliance measures which it uses to monitor and enforce its compliance with these principles.
- When complying with POPIA, COMENSA will ensure that it acts with integrity and fairness and will always balance the rights of both, data subjects and COMENSA’s, in an objective manner.
1. Purpose and objectives
- COMENSA is the national non-profit professional representative body of Coaches and Mentors in the Republic of South Africa. It comprises a Head Office and Provincial Chapters set up in various jurisdictions. To understand its objects and services please view the various links on the website.
- ‘The principal place of business is 250 Hall Street, Die Hoewes, Centurion, 0046.
- The Information Officers may be reached at one of the following email addresses :
2. Details and Contact Information of COMENSA
- This Privacy Policy applies under several different circumstances and may, in relation to COMENSA, include the following examples (which are not exhaustive):
- When using any of its products or services;
- When applying to be a volunteer or for employment;
- When supplying services and/or providing any personal information to fulfil the service contract;
- When data subjects are operators of COMENSA’s clients, if applicable; and/or
- When any information is collected from or shared with any third parties.
- This Privacy Policy applies to COMENSA’s website, applications, and online services, social media platforms as well as any publications or newsletters that COMENSA may publish.
- Some personal information may be shared with operators/contractors in order to deliver COMENSA’s services and products. If this is the case, they are bound by and adhere to this policy as well.
3. Application
- COMENSA collects information that is directly and voluntarily provided to it.
- COMENSA will collect personal information from the data subject when :
- Any person engages or supplies COMENSA with or uses their services,
- A data subject communicates with COMENSA via forms, email or uses any other channel, not specifically mentioned here.
- Any person uses the online self- serve platform,
- A person subscribes to newsletters or responds to advertisements, competitions or requests for information.
- The information that data subjects provide may include current and historical personal information including name, contact details, title, identification, employment, positions held, enquiry/complaint details and information about the organisation with which the data subject is affiliated.
- Information may also be sourced from employers, regulatory authorities, recruitment agencies, credit ratings agencies, information or service providers, public records and other third parties.
- COMENSA may also collect personal information through other dealings, including through any contact made in person, by telephone, email or online.
4. The Information COMENSA Collects
- COMENSA may also collect information about data subjects from public sources including social media platforms.
- COMENSA advises data subjects to familiarise themselves with the respective privacy policies that apply to these platforms. Note that COMENSA will process any information from these sources in accordance with the law.
5. Information Collected from Other Sources
- COMENSA does not collect children’s personal information without the consent of their parents or guardians. If a data subject is under the age of 18, the data subject should not provide any personal information to COMENSA without the written consent of their parent or guardian.
- COMENSA reserves the right to ask for proof of consent or proof of age if it suspects that it is engaging with a child under the age of 18 years.
6. Children’s Personal Information
- COMENSA use personal information to :
- provide products and services
- send membership or credentialing renewal notices
- respond to enquiries
- send invitations to COMENSA events
- send updates and newsletters on the latest developments within COMENSA and in the coaching and mentoring industry
- enable seamless payment to our suppliers.
- COMENSA will not further process personal information without first assessing whether:
- The further processing is compatible with the reasons the data subject initially provided the information; or
- The data subject has consented to further processing of personal information; or
- If it is in accordance with the law.
- COMENSA will not contact a data subject for unsolicited marketing purposes either telephonically, by mail, SMS or email if the data subject has not opted in to receive these communications. It may however contact its members and data subjects who have consented to be on its mailing lists. Data subjects who wish to no longer receive communication have the option to opt out.
7. What COMENSA uses the Personal Information For
- When a data subject responds to an application for a vacancy, either as an employee or volunteer, a curriculum vitae (“CV”) which contains personal and special personal information is usually provided to COMENSA.
- COMENSA may request further personal and special personal information about education, employment, race and state of health. As part of the application, the data subject must provide their consent to use of the information to fulfil any recruitment testing assessments and activities which may be required from employers under applicable laws.
- These will include the option to carry out various screening checks and to consider the data subject for other positions. In order to conduct the screening checks COMENSA may share aspects of the personal information with inter alia: academic institutions, credit bureaus, medical providers, professional and trade associations, law enforcement agencies, referees and your current and previous employers.
- COMENSA may also gather additional information from publicly available resources such as LinkedIn, Facebook or other social or professional media platforms and collate this with the information that the applicant data subject provided to COMENSA. Where consent is not explicitly provided, COMENSA reserves the right not to progress the application.
- COMENSA will keep the personal information for as long as it is necessary during the recruitment process.
- If the applicant is successful, COMENSA will retain the personal information in accordance with South African labour law legislation.
- If the applicant is unsuccessful or withdraws the application, COMENSA will dispose of information safely and securely.
- These processes will apply to both, employees and volunteers.
8. Information Provided due to a Vacancy or Volunteerism
- COMENSA may also be legally or contractually obliged to collect information from data subjects to conduct business, for example, where COMENSA is required by law to gather personal information for labour, health, tax, BBBEE, FICA, SAQA and NQF requirements.
- Suppliers may be required to provide personal information for overall legal compliance including processing of payments/ accounts, identity checks, reference checks, assessment of financial records, bank account numbers, taxpayer compliance status and contact details verification.
- Where relevant, COMENSA may advise of the details that COMENSA are required to collect.
- Data subjects may also request the reason for such collection of information.
9. Legal or Contractual Obligations to Collect Information
- COMENSA’s offices may be monitored by CCTV cameras for safety and the prevention of crime. The footage is stored in a secure location by a third-party service provider.
10. CCTV cameras
- COMENSA will not use or share personal information with any person outside of COMENSA unless it is for a business purpose.
- COMENSA will not use or share personal information with any person outside of COMENSA unless it is for a business purpose.
- In order to deliver products and services and for the efficient running of business, COMENSA uses third-party service providers/operators. At times, COMENSA will share data subjects’ personal information with these third-party service providers/ operators. For this reason, COMENSA signs confidentiality/operator agreements and ensures that they operate under strict requirements aimed at keeping personal information secure and confidential and that the said information is used for the purpose for which it is provided. To access COMENSA’s current service provider’s Privacy Policy, Click here.
- COMENSA may also share personal information with banking institutions and credit providers, and governmental, judicial, regulatory and law enforcement bodies and agencies, if required.
11. Sharing of Information
- COMENSA will not retain data subjects’ personal information for longer than is necessary unless consent has been received or it is required by law or it is for the purposes of a contract. Personal Information that is no longer required is securely disposed of or is deidentified as soon as reasonably practicable after it is no longer authorised to be retained.
12. Retention of Records
- COMENSA has taken every reasonable and affordable measure, to keep personal information in a secure, reliable and protected place, free from unauthorised access.
- COMENSA regularly monitors its information technology systems for possible vulnerabilities and cyber-attacks. To this end, COMENSA deploys reasonable security safeguards.
- Although COMENSA has measures in place to minimise security threats, COMENSA cannot guarantee data breaches will not happen and therefore also encourages data subjects to have their own security measures in place.
- In the unlikely event of personal information being compromised, COMENSA will follow the guidelines and processes provided by POPIA.
13. Security
- COMENSA also has a self-serve platform which enables data subjects who are registered as members or Friends of Comensa to upload, view, amend their personal information.
- Data subjects may, via the COMENSA website and through an email link elect to be added to the respective mailing lists for communication on the COMENSA initiatives available.
- Data subjects may, also at any time and at no cost, elect to update their preferences or stop receiving the communication by clicking the “unsubscribe” link on the email.
- Data subjects also have the right to know what personal information COMENSA have about the said data subject, to correct it, request its deletion and to determine if COMENSA has shared the personal information with third parties.
- Data subjects may also object to the processing of their personal information. Any of these requests must be in writing on the prescribed form. It may take up to 5 working days to respond to a request and a small fee may be charged.
- If a data subject or member requires a deletion of their personal information, COMENSA may need to terminate all agreements with that data subject as COMENSA cannot maintain relationships without having some personal information.
- COMENSA also retains the right to refuse to delete some personal information if the information is required to be kept in terms of the membership contract, by law or if COMENSA is required it to protect its rights.
14. Data Subjects Rights
- Should a data subject require more information on COMENSA’s Privacy Policy, or needs to submit a request, please contact COMENSA’s Information Officer, as per details above.
- POPIA mandates the Information Regulator to oversee that COMENSA manages personal information in a responsible manner that respects data subject’s privacy. While COMENSA make every effort to assist data subjects, should you have any further queries or be unhappy, you may contact the Information Regulator whose contact details may be found at https://www.justice.gov.za/inforeg/contact.html.
15. Contact Details
- From time to time, COMENSA may amend this policy to accommodate changes in its business and/or if legislative amendments require change.
16. Updated Policy
COMENSA is committed to protecting personal information and adhering to POPIA.
