Cims South Africa (Pty)Ltd (Cims) is committed to protecting and respecting your privacy. We hereby wish to notify you of its policy for processing personal information in terms of the Protection of Personal Information Act, 2013 (“POPIA”). Your right to privacy is important to us and we are committed to safeguarding and processing your personal information in a lawful manner.
1. Personal Information
Personal information is any information that can be used to reveal a person’s identity. Personal information relates to an identifiable, living, natural person, and where applicable, an identifiable, existing juristic person (such as a company), including, but not limited to information concerning: race, gender, pregnancy, marital status, national or ethnic origin, colour, age, physical or mental health, disability, language and birth of a person; information relating to the education or the medical, financial, criminal or employment history of the person; any identifying number, email address, physical address, telephone number, location information, online identifier or other particular assignment to the person; the personal opinions, views or preferences of the person; correspondence sent by the person 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 another individual about the person; the name of the person if it appears with other personal information relating to the person or if the disclosure of the name itself would reveal information about the person.
2. Processing
The act of processing information includes any activity or any set of operations, whether or not by automatic means, concerning personal information and includes: the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use; 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.
3. Responsible Party
Cims South Africa (Pty)Ltd is situated at 25A Eaton Avenue, Bryanston, 2152.
4. Information Officer
Name : Alicia Correia Designation : Head of Business Services Contact Number : (011) 463 8723 Email : enquiries@cimssa.co.za
5. Personal Information we collect
Cims processes your personal information for the purpose of providing you with the products and services that you have applied for either individually or have been offered to you through your insurance policy or through a corporate client in terms of a contract. The personal information may be collected by Cims, from yourself directly or verification agencies, service providers, outsource partners and consultants and other third parties. Cims also processes your personal information in terms of legislation and tax purposes.
You provide some of this personal information directly when you apply for the products and services either individually or through your insurance policy, when you communicate with Cims by calling our 24 hour call centre for assistance, in writing by email or post or contacting us with a query.
It is up to you what personal information we collect and you may decline to provide us with your personal information. However, if you choose not to provide us with your personal information which is necessary to provide you with the products and services, you may not be able to make use of the product or service.
Personal Information about children under the age of 18 will only be collected where it is necessary in order for your children to make use of the service and you have provided it to us. This personal information will not be used for any other purpose other than to provide you and your children with the full benefits of the product or service.
MEMBERS / POLICYHOLDERS
We will only use your personal information for a purpose you would reasonably expect, including
a) to confirm, verify and update your personal information details;
b) provide, administer and manage products and services
c) manage, administer and/or amend your insurance policies or membership details;
d) manage and administer claims;
e) to confirm the existence of a bank account;
f) compliance with a legal or statutory requirements or industry bodies that apply to Cims;
g) fraud detection and prevention;
a. where you have provided your consent
Type of Information processed :
The following types of information may be processed by Cims in terms of the information supplied by you in order to provide you with the product or service :
a) Name and surname, physical and postal address, contact details, email address, race, gender, pregnancy, marital status, identity document, passport information; nationality, marriage certificate, death certificate, physical or mental health, disability, language; medical history; location information; vehicle registration
THIRD PARTY SERVICE PROVIDERS
We process third party service providers’ personal information in order to approve and perform your contracts or transactions with Cims and in order for you to be placed on Cims network panel of third party service providers, to provide products and services to Cims members / policyholders. We will only process your information for a reasonable purpose in this connection, including:
a) to verify your identity or registration through company search engines;
b) to conduct credit reference searches;
c) to confirm, verify and update details
d) to verify the status of any FSP License;
e) to verify and confirm the possession of Professional Indemnity Insurance and Public Liability cover;
f) to confirm income and expenses to operate a business;
g) to verify ability to perform the services
h) to confirm compliance with SARS requirements;
i) to confirm the details of a bank account;
j) to confirm solvency status;
k) to monitor compliance with contractual obligations;
l) to confirm operational skill and ability and personal character details
m) to comply with a legal or statutory requirement or industry body that apply to Cims
n) B-BBEE status.
Type of Information processed :
The following types of information may be processed by Cims in terms of the information supplied by you in order to give effect to the purpose :
a) Company name, directors’ names and surnames, physical and postal address, contact details, email address, business plans, auditors’ information, company registration number, VAT number, shareholding details, business profile of company, Tax Certificate; B-BBEE certificate; insurance policies; FSP license; banking information.
CORPORATE CLIENTS
We process corporate clients’ personal information for agreed purposes and we ask you to only share personal information with us where it is strictly needed for those purposes. We will only process your personal information for a reasonable purpose in this connection, including:
a) for the purposes of providing proposals on our products and services;
b) meeting our contractual obligations with you or to take the necessary steps for the conclusion of a contract with you;
c) providing products and services to your policyholders / customers / employees;
d) managing our relationship with clients and prospective clients;
e) developing our businesses and services such as identifying client needs and improvements in service delivery.
Type of Information processed :
The following types of information may be processed by Cims in terms of the information supplied by you in order to give effect to the purpose :
a) Company name, directors’ names and surnames, physical and postal address, contact details, email address, business plans, sales strategy; company registration number, VAT number, shareholding details, business profile of company.
6. Recipients of the personal information
The following persons may be recipients of the personal information that is being processed by Cims:
a) Staff members of Cims
b) Third party service providers
c) Underwriting managers
d) Underwriters
e) 3rd Party Compliance Officer
f) B-BBEE consultant and verification agency
g) Outsource partners
h) Credit agencies
7. Personal Information where we need your consent
We will ask you for your medical information to share with medical and ambulance personnel in order to provide you with the service.
8. Processing for Legitimate Business Purposes
We process your personal information for a legitimate business purpose. A legitimate business purposes means the interests of Cims in conducting and managing our business to enable us to provide you with the products and services and the most secure experience. We do not use your personal information for activities where our interests are overridden by the impact on you. You have the right to object to this processing if you wish and if you wish to do so please contact our Information Officer. If you do object, this may affect our ability to carry out the tasks for your product or service where we are processing your personal information for a legitimate business purpose.
9. Why we share your personal information
We share your personal information with third party service providers in order to provide you with your product or service, if we have a legitimate business purpose for doing so, or if you have given us your explicit consent to do this.
9.1 Sharing your personal information with partners and selected third parties
The entities Cims will share your personal information with are selected third parties who require the information in order to provide you with the required services. The failure to furnish the requested personal information may result in the service being terminated or declined, no insurance policy being issued or no service provider agreements being concluded.
The third parties must take precautions to ensure that as the recipients of your personal information they will treat your personal information confidentially and with the required measures and protocols.
Personal information may be hosted on servers and processed by recipients and third parties, which may be located outside of South Africa.
Cims will only process personal information that it requires to give effect to the purpose of collection and further compatible purposes and in the course of Cims’ business.
9.2 Sharing your personal information for compliance purposes
Additionally we reserve the right to access and disclose your information in order to comply with applicable laws, to comply with lawful requests from governments, law enforcement agencies or parties whose request we reasonably consider to be justified in connection with any allegations by any party about your abuse of our services, to operate our systems properly or to protect ourselves or our users from any of the scenarios mentioned in this section, this includes protecting the rights of Cims through the enforcement of the terms governing the products and services and protecting our customers from spam or activity which may defraud users of our products and services.
10. Your Rights
10.1 Right to rectification
You can update and amend your personal information held by us if inaccurate or incomplete by emailing us at enquiries@cimssa.co.za.
10.2 Right of access, restriction of processing and erasure
If you would like to see the personal information we process on you, restrict the processing of your personal information or have it deleted you can contact our Information Officer who will investigate the matter and take you through the necessary steps to provide you with the personal information you requested or to delete it. If you would like it deleted, in particular any personal information which is necessary for us to process to provide you with the product or service, you will no longer be able to use the product or service. If applicable, our Information Officer will explain any circumstances where we are unable to erase your personal information and situations where you can restrict the processing of your personal information. Our Information Officer will respond to your query within 30 days of receiving your request.
11. Security
Securing your personal information is very important to us. Personal information is held in a secure environment and (except for law enforcement authorities in limited circumstances), only those Cims employees or other persons who need access to your personal information in order to perform their duties are allowed such access. We have implemented all necessary and reasonable technical and organisational measures to protect your personal information including data protection, confidentiality of accessing personal information, IT controls, etc.
12. Other important information
12.1 Transfers
As part of the services offered to you, the information you provide to us could be transferred to countries outside of South Africa for the purposes of providing you with a service. If we transfer your personal information outside South Africa in order to provide you with a service, we will take steps with the aim of ensuring that your privacy rights continue to be protected, as outlined in this privacy policy and in accordance with POPIA.
12.2 Retention
We retain your personal information for as long as you continue to use the product or service for the purposes explained in Section 5 above. When you cease your membership of the product or service, we will retain your personal information for as long as necessary to comply with our legal obligations, to resolve disputes and defend claims. In particular, we will retain call recordings, the personal information you supplied when joining the product, including complaints, claims (for insurance products) and any other personal information you supplied during the duration of your contract with us for your product or service for a period of 5 years from termination or expiry of your service in line with industry standards for the defense of contractual claims.
12.3 Complaints
If you have a concern about your personal information or a question about this Privacy Statement please contact the Information Office by email at enquiries@cimssa.co.za . If you are not happy with the response you receive or believe your personal information has not been used in accordance with this privacy statement and therefore not processed in line with applicable laws, you may lodge a complaint with the Information Regulator on email inforreg@justice.gov.za. We would, however, appreciate the chance to deal with your concerns before you approach The Information Regulator, so please contact us in the first instance.