Privacy Notification
Electronic Communications
This disclaimer applies to any electronic message (like email, whatsapp, facebook messenger or SMS) passing through the information system (including its contents, any attachments and all subsequent messages or attachments) of Spotlight Trust. If there is a conflict between this disclaimer and any other, this one will prevail.
The recipient
Messages are intended for the named recipient only. If that is not you and you have received the message:
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Please notify the sender using the contact details contained in the message. If this is not possible, then using the quickest means possible (telephone 083 559 3023). You must delete the message you received once you have notified the sender.
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You must not forward, copy or otherwise transmit or disseminate the message or any of its contents to any person other than the named sender.
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You may not print, save or store the message or any of its contents in electronic or physical form.
Confidentiality
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The message is confidential, unless specifically stated or if this is manifestly clear from the context (such as press releases and other official statements).
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If you are not certain whether the message is confidential, please check with the sender.
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Do not disclose it to anyone else. Only the person to whom the message was sent may use it.
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Do not add the sender’s email address or number to a database for the purposes of direct electronic marketing without their consent.
Copyright notice for message content
We own the content of our messages (and this message disclaimer). It is protected by copyright and other intellectual property laws. We reserve all rights we do not expressly grant.
Legal requirements related to message
By communicating with us electronically, you consent to receiving messages from us electronically and agree that any agreement, notice, disclosure or other message transmitted electronically satisfies any legal requirement, including that it be “in writing”. Unless otherwise agreed, we are only deemed to have:
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received a message once we have confirm receipt orally or in writing; and
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sent a message once reflected as “sent” on our message server logs.
We are not responsible
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We have taken all reasonable precautions to ensure that no malicious software (malware) is in our message to you.
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We recommend that you virus check all messages you receive.
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While we use our best endeavours to prevent loss or damage to third party systems, we are not responsible or liable for any harm, damages, or loss (including any lost profits, business interruption, loss of programs or other data on information handling systems, or data corruption) arising from this message, including:
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from malicious software (malware),
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if someone else changes an message,
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for corruption of data, or any “denial of service”,
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for the non-delivery or incorrect delivery of any message,
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its effect on electronic devices, or
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its transmission in an unencrypted medium.
Interception and Monitoring
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We reserve the right to intercept, monitor, review or disclose all messages.
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Employees do not have any privacy right in the creation of, sending of, receipt of or storage of information (e.g. message messages, internet pages) on the systems of the organisation.
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If you do not want your message to be read by us, you must not communicate with us by message.
Enquiries
If you have any questions or concerns arising from this disclaimer, please contact Spotlight Trust on 083 559 3023
Privacy Notification for collecting information
Effective Date: 1 September 2020
The new Protection of Personal Information Act, 2014 (POPI) came into effect on 1 July 2020. It builds on existing data privacy rules, strengthening in many key areas and non-compliance potentially results in severe financial penalties.
Spotlight Trust is highly committed to maintaining high standards of information security, privacy and transparency, whether as a Responsible Party or as an Operator in terms of POPI.
We take our responsibilities in relation to the protection and security of our data and that of our employees, volunteers, delegates, patients, vendors and partners incredibly seriously and the changes being introduced to ensure POPI compliance are part of a continuous, ongoing process that has always been central to what we do.
Application of this Privacy Notification?
This POPI Privacy Notification explains how Spotlight Trust, referred to as “Spotlight,” “we,” “our,” or “us”) handles Personal Information and can include Personal Information about others where you share their Personal Information with us. It details how we collect Personal Information, why we collect it, and to whom we may share it. This Privacy Notification also discloses your Personal Information rights. It applies to all your Personal Information, including Personal Information stored electronically or in hard copy and Special Personal Information, which includes Personal Information about racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership, and the processing of genetic information, biometric information for the purpose of uniquely identifying a natural person, information concerning health or information concerning a natural person’s sex life or sexual orientation, and information relating to criminal behaviour.
What Personal Data may we collect about you?
Spotlight collects and processes your Personal Information, which can come directly from you or from third parties with whom we contract or provide services or for compliance reasons. Personal Information includes all information that identifies you or can be used to identify you.
The information we process about you may include the following categories of Personal Information:
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Name & Surname
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Age and date of birth
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Demographic data
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Personal contact information (address, telephone, email address)
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HPCSA registration Numbers
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Communication and other personal preferences
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Payment related information
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Data collected from Cookies (on our website)
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Data collected from website/mobile device usage and analytics (on our website)
Where appropriate we make use of videos taken within therapy sessions conducted by members of the Spotlight Team. These videos are taken with the full knowledge and consent by the parent/child/guardian at the time of the recording. The use of these videos is with the full knowledge and consent of the parent/child/guardian and while all identifying information is removed from these videos the first name of the child is frequently used in the interaction and can not be removed. We take the confidentiality of these videos and the families they represent seriously and all delegates to our in person or online workshops are required to respect the confidentiality of these videos. No recording is allowed in our workshops and should any person recognize any of the children or parents in videos presented they are requested to keep this information confidential.
We may process your Personal Information for the following purposes
The volunteers and staff who provide training or managed memberships maintain records about your attendance at workshops, course or other events to ensure access to continued professional development points, discounts through Profectum Academy and other benefits to our training. health and any treatment or care you have received previously. These records help to provide you with the best possible healthcare.
Our records may be electronic, on paper or a mixture of both, and we use a combination of working practices and technology to ensure that your information is kept confidential and secure. Records which Spotlight hold about you may include the following information;
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Details about you, such as your address, contact details, professional registration numbers
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Any contact Spotlight has had with you
Transfer the information to a third country
We may transfer your information to a Cloud database outside your country of domicile, potentially including countries which may not require an adequate level of protection for your Personal Information compared with that provided in your country.
Recipient or category of recipients of the information
In order to deliver the best possible service, Spotlight will share information (where required) with –
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The occupational therapy association or other professional registration bodies for the awarding of Continued Professional Development Points
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Profectum Academy to allow the access to discounts where applicable
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Accounting Bureaux’s and / or bookkeepers.
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Disclosures authorized by law. There are limited situations where we are legally required to disclose your personal information without your consent. These situations include (but are not limited to) reporting infectious diseases and fitness to drive, or by court order.
How can you access, rectify or object to the personal information that you have given to us?
Even if we already hold your personal information, you still have various rights in relation to it. To get in touch about these, please contact us. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
Right to object: If we are using your information because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.
Right to withdraw consent: Where we have obtained your consent to process your personal information for certain activities (for example for a research project), or consent to market to you, you may withdraw your consent at any time.
Right to erasure: In certain situations (for example, where we have processed your information unlawfully), you have the right to request us to “erase” your personal information. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will Delete your information but will generally assume that you would prefer us to keep a note of your name on our register of individuals who would prefer not to be contacted. That way, we will minimise the chances of you being contacted in the future where your information are collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.
Right of data portability: If you wish, you have the right to transfer your information from us to another service provider. We will help with this.
Objections / Complaints:
Should you have any concerns about how your information is managed, please contact the Information Officer as below. If you are still unhappy following a review by Spotlight, you have a right to lodge a complaint with the Information Regulator as below.
Information Regulator:
Chief Executive Officer
Mr Marks Thibela
Address
33 Hoofd Street
Forum III, 3rd Floor Braampark
P.O Box 31533
Braamfontein, Johannesburg, 2017
Tel No
+27 (0) 10 023 5200
Complaints
Website
https://www.justice.gov.za/inforeg/contact.html
If you are happy for your data to be used for the purposes described in this privacy notice, then you do not need to do anything. If you have any concerns about how your data is shared, then please contact Spotlight Information Officer.
If you would like to know more about your rights in respect of the personal data we hold about you, please contact the Information Officer as below.
Information Officer
Cheryl Fisher
Address
100 Algernon Road, Norwood
Tel No
083 559 3023
Email Address
Changes
It is important to point out that we may amend this Privacy Notice from time to time. If you are dissatisfied with any aspect of our Privacy Notice, please contact Spotlight Data Protection Officer.