T L J Investments (Pty) Ltd is committed to protecting the privacy of personal information of our employees, customers and suppliers; also referred to as data subjects. The information you share with us, as a data subject, allows us to provide you with the best experience relating to our products and services.
It is important that, as a data subject, you take all necessary and appropriate steps to protect your data.
T L J Investments (Pty) Ltd has dedicated policies and procedures in place to protect all personal information collected and processed by us.
Please read below for more information on how we collect, process, use and disclose personal information.
Registered address:
378 Lauren Street
Lynnwood Park
Pretoria
0081
Information Officer contact details:
Name: Jaco de Bruin
Telephone Number: +27 12 361 3136
Email: jaco@tlj.co.za
Personal data may either be collected directly from you, as data subject, or it may be collected from other sources such as:
- employing company
- through the use of cookies on our website
- 3rd Party References
- online public profiles
- other online systems
Where information is not collected directly from you as a data subject, we will take reasonable steps to inform you of the fact that the information was collected and will be processed.
You must not send personal information about 3rd parties without consent. We will assume consent was provided although we may still request confirmation from the 3rd party. Where information about 3rd parties is provided by a data subject, or a connection is disclosed by a 3rd party with a data subject, that information may be taken into account with the data subject’s other personal information.
In order for us to provide you with the best service, we need to collect and process personal information from you. This information will consist of the following:
Personal information that we generally process regardless of how you contact us, or for whatever reason, includes:
- your full name and your contact details; and/or
- your home address, correspondence address (where different from your home address)
As an existing or new client\supplier\employee, we may collect the following information:
- financial information, including your bank account information;
- proof of identification in the form of copies of your Identity Document, passport, driving license or other identity documents such as utilities bills, etc.;
- personal information and contact information which you provide via correspondence with us;
- information relating to your use of our products or services;
Information obtained from others
At time, we collect additional information about you from third parties. The information obtained is collected from sources including
- employing company
- use of cookies on our website
- public and online profiles
- financial institutions
We mainly use the personal information we hold about you where it is necessary for us to perform our contract\transaction with you and\or to enable us to comply with legal obligations. Your personal information will also be used when it is in our legitimate interest. A legitimate interest is when we (and sometimes third parties) have a business or commercial reason to use your information. But even then, our legitimate interest must not unfairly go against what is right and in your best interest.
Prospective employees
In applying for a position at T L J Investments (Pty) Ltd you may provide us with personal information as part of the application process. We may also obtain personal information while performing the required background check, reference check and credit check if relevant.
The personal information obtained during this process includes:
Personal information | Purpose for processing | Legal basis for processing |
Gender | Provided for employment equity purposes. | The data subject consents to the processing. Processing complies with an obligation imposed by law on the responsible party. Processing is necessary for pursuing the legitimate interests of the responsible party or of a third party to whom the information is supplied. |
Disability | To determine how the data subject should be accommodated if the data subject is successful in the job application. Provided for employment equity purposes. | The data subject consents to the processing Processing complies with an obligation imposed by law on the responsible party. Processing is necessary for pursuing the legitimate interests of the responsible party or of a third party to whom the information is supplied. |
Language | Language is important to communicate with clients, your team, suppliers and other departments within the organization. It is important to know if the data subject can communicate effectively in the required language/s. | The data subject consents to the processing. Processing complies with an obligation imposed by law on the responsible party. Processing is necessary for pursuing the legitimate interests of the responsible party or of a third party to whom the information is supplied. Processing is necessary to carry out actions for the conclusion or performance of a contract to which the data subject is party. |
Educational History | Depending on the role the data subject has applied for, there will be a minimum level of education/qualifications required for the position. This information is required to determine if the data subject meets the required level of education for the role. | The data subject, consents to the processing. Processing complies with an obligation imposed by law on the responsible party. Processing is necessary for pursuing the legitimate interests of the responsible party or of a third party to whom the information is supplied. Processing is necessary to carry out actions for the conclusion or performance of a contract to which the data subject is party. |
Financial History | To ascertain earnings and expected salary and match it to the set budget. | The data subject consents to the processing. Processing complies with an obligation imposed by law on the responsible party. Processing is necessary for pursuing the legitimate interests of the responsible party or of a third party to whom the information is supplied. Processing is necessary to carry out actions for the conclusion or performance of a contract to which the data subject is party. |
Employment History | In order to ascertain the data subject’s work experience, employment history is required. Some roles require a minimum level of experience. Employment history information is used to match the data subject’s experience with these requirements. | The data subject consents to the processing. Processing complies with an obligation imposed by law on the responsible party. Processing is necessary for pursuing the legitimate interests of the responsible party or of a third party to whom the information is supplied. Processing is necessary to carry out actions for the conclusion or performance of a contract to which the data subject is party. |
ID Number | Used as the unique identifier of the data subject, as data subject names and other information might be the identical/similar. Used as confirmation of South African citizenship. | The data subject consents to the processing. Processing complies with an obligation imposed by law on the responsible party processing is necessary for pursuing the legitimate interests of the responsible party or of a third party to whom the information is supplied processing is necessary to carry out actions for the conclusion or performance of a contract to which the data subject is party |
E-mail Address | Required to effectively communicate/correspond with the data subject. | The data subject consents to the processing. Processing complies with an obligation imposed by law on the responsible party. Processing is necessary for pursuing the legitimate interests of the responsible party or of a third party to whom the information is supplied. Processing is necessary to carry out actions for the conclusion or performance of a contract to which the data subject is party. |
Physical Address | Required to communicate with the data subject. Also used to determine where the data subject resides as geographical location is relevant. | The data subject consents to the processing. Processing complies with an obligation imposed by law on the responsible party. Processing is necessary for pursuing the legitimate interests of the responsible party or of a third party to whom the information is supplied. processing is necessary to carry out actions for the conclusion or performance of a contract to which the data subject is party. |
Telephone Number | Required to effectively communicate with the data subject. | The data subject consents to the processing. Processing complies with an obligation imposed by law on the responsible party. Processing is necessary for pursuing the legitimate interests of the responsible party or of a third party to whom the information is supplied. Processing is necessary to carry out actions for the conclusion or performance of a contract to which the data subject is party. |
Employees
We must process personal information of our employees for various legal and employment purposes. The information that we process include the following:
Personal information | Purpose for processing | Legal basis for processing |
Language | Language is important to communicate with clients, your team, suppliers and other departments within the organization. It is important to know if the data subject can communicate effectively in the required language/s. | The data subject consents to the processing. |
Educational History | Track data subject’s career growth. | The data subject consents to the processing. |
ID Number | Used as the unique identifier of the data subject, as data subject names and other information might be the identical/similar. Used as confirmation of South African citizenship. | The data subject consents to the processing. |
Bank Details | Used to process salary payments into data subject’s bank account. | The data subject consents to the processing. |
E-mail Address | Required to effectively communicate with the data subject. | The data subject consents to the processing. |
Physical Address | Required to communicate with the data subject. Also used to determine where the data subject resides as geographical location is relevant. | The data subject consents to the processing. |
Telephone Number | Required to effectively communicate with the data subject. | The data subject consents to the processing. |
Location Information | Used for project tracking purposes. | The data subject consents to the processing. |
Customers
In order for us to provide you with the best service, we need to collect and process personal information from you as a customer. This information will include the following:
Personal information | Purpose for processing | Legal basis for processing |
Language | To communicate effectively with the data subject | Processing is necessary to carry out actions for the conclusion or performance of a contract to which the data subject is party. |
ID Number | Used as unique identifier of the data subject as some of the name and surnames are identical. | Processing is necessary to carry out actions for the conclusion or performance of a contract to which the data subject is party. The data subject consents to the processing. |
E-mail Address | Required to effectively communicate with the data subject. | Processing is necessary to carry out actions for the conclusion or performance of a contract to which the data subject is party. The data subject consents to the processing. |
Physical Address | Required to effectively communicate with the data subject and to locate data subject when required. | Processing is necessary to carry out actions for the conclusion or performance of a contract to which the data subject is party. The data subject consents to the processing |
Telephone number | Required to effectively communicate with the data subject. | Processing is necessary to carry out actions for the conclusion or performance of a contract to which the data subject is party. The data subject consents to the processing |
Location information | Used to identify the location of projects. | Processing is necessary to carry out actions for the conclusion or performance of a contract to which the data subject is party. The data subject consents to the processing. |
Suppliers
We must process personal information of suppliers for various legal and business purposes. The information that we process include the following:
Personal information | Purpose for processing | Legal basis for processing |
Educational History | To confirm that the data subject is qualified to provide required services to the organization. | The data subject consents to the processing. Processing is necessary to carry out actions for the conclusion or performance of a contract to which the data subject is party. |
Employment History | To confirm the experience of the data subject as it has relevance to the services required by the organization. | The data subject consents to the processing. Processing is necessary to carry out actions for the conclusion or performance of a contract to which the data subject is party. |
ID Number | Unique identifier of data subject. | The data subject consents to the processing. Processing is necessary to carry out actions for the conclusion or performance of a contract to which the data subject is party. |
E-mail Address | Contact information is used to communicate with the data subject. | The data subject to the processing. Processing is necessary to carry out actions for the conclusion or performance of a contract to which the data subject is party. |
Physical Address | Contact information to communicate with the data subject. Locate data subject when required. Geographical locations of suppliers are relevant to the organizational needs. | The data subject consents to the processing. Processing is necessary to carry out actions for the conclusion or performance of a contract to which the data subject is party. |
Telephone Number | Contact information is used to communicate with the data subject. | The data subject consents to the processing. Processing is necessary to carry out actions for the conclusion or performance of a contract to which the data subject is party. |
Your personal information will be kept confidential at all times, however, you agree and consent that T L J Investments (Pty) Ltd may:
- Communicate with you in relation with the service or product being provided (per email, fax, telephone or through any other relevant or secured electronic communication platform).
- Obtain and\or verify any relevant personal information, from any person or institution, necessary to comply with the agreement between you and T L J Investments (Pty) Ltd.
- Disclose personal information to regulatory or government agencies in accordance with the relevant legislation or directives.
- Use personal information to market new or other products of the company which may be suitable or relevant to you.
Where we talk about the legitimate interests of T L J Investments (Pty) Ltd. or third parties, this may include, however not be limited to:
- Assessing your suitability for employment, products, services or transactions with T L J Investments (Pty) Ltd.
- Right to freedom of expression or information, including in the media.
- Prevention of fraud, misuse of company IT systems.
- Physical security, IT and network security.
- Internal Investigations.
- Compliance with our legal obligations.
When relying on the legitimate interest basis for processing your personal data, we will balance the legitimate interest pursued by us and any relevant third party with your interest and fundamental rights and freedom in relation to the protection of your personal data to ensure it is appropriate for us to rely on legitimate interests, as well as to identify any additional steps we need to take to achieve the right balance.
T L J Investments (Pty) Ltd may transfer personal data to third parties, including to data processors within and outside of South Africa, for the Processing Purposes as follows:
- Regulators, Authorities, and other third parties. As necessary for the Processing Purposes described above, personal data may be transferred to regulators, courts, and other Authorities (e.g., Tax and Law Enforcement Authorities), Financial Institutions (e.g., banks), Independent External Advisors (e.g., Auditors), Insurance Providers, Pension Fund and benefits providers, Internal Compliance and Investigation teams (including External Advisers appointed to conduct internal investigations).
As necessary for the Processing Purposes described above; personal data may be shared with one or more third parties, whether affiliated or unaffiliated, to process personal data under appropriate instructions.
The Data Processors may carry out instructions related to recruitment, workforce administration, IT system support and maintenance, payroll and compensation, training, compliance, business transaction and other activities, and will be subject to contractual obligations to implement appropriate technical and organisational security measures to safeguard the personal data, and to process the personal data only as instructed.
Individuals screened for COVID 19
The personal information collected is necessary to comply with the COVID 19 screening as required by the Disaster Management Act and supplementary regulations and directives. This information will be kept confidential unless disclosure is required by law. e.g. should a positive case be identified.
This information will be stored for a period of 12 months and thereafter be destroyed.
If you do not provide the information as required, we can limit or refuse you access to the premises.
The premises of T L J Investments (Pty) Ltd is monitored by CCTV footage. This footage is only processed for security purposes and not shared with any person or entity outside the company. CCTV footage is retained for a period of 12 months after which it is destroyed.
Where the legal basis for us processing your personal information is consent, it will be in agreement with you. We accept that consent is given by you when personal information is provided or shared voluntarily with us.
This consent may be withdrawn at any time, however this withdrawal of consent will not make processing we undertook before your withdrawal unlawful. You will not suffer any detriment for withdrawing your consent.
You may withdraw your consent by contacting our Information Officer, whose details are provided herein as part of this privacy policy.
Where the legal basis for processing is for the proper performance of the contract, and you fail to provide us with the information, or request us to stop processing this information, it may create limitations on our performance of the contract or agreement.
In processing your personal information, we may share it with third party processors under an Operator’s Agreement. These include, but are not limited to:
- Payment processors;
- Email management and distribution tools;
- Data storage providers;
- Server hosts;
- Third Party Service providers;
As an operator, these service providers will not be able to process or use your data for any reason other than to provide the service as required by us. They also need to implement proper safeguards to ensure the personal information is secured at all times.
We may transfer and store personal information we collect from and about you, to and in countries other than South Africa. These countries may not have the same data protection laws as South Africa, and in these instances we will only transfer the information if we have consent from you, and/or it is necessary for the performance or conclusion of a contract between us.
Countries we may transfer data to includes:
Foreign country | Reason for transfer of data |
United States of America | Data is stored in this country. |
European Union | Data is stored in this region. |
United Kingdom | Data is stored in this country. |
T L J Investments (Pty) Ltd is required to comply with various different legislative retention periods, which leads to different retention requirements. As such we have opted for the longest retention period required from us, for legal purposes, and apply this to all our data. Your personal information will be kept for a period of seven (7) years, in order for us to comply with all legal requirements.
You have the following rights under the Protection of Personal Information (POPI) Act:
- Request access to your personal information.
- Request a correction or deletion of personal information.
- Object to the processing of personal information.
- Lodge a complaint to the Information Regulator.
If you want to exercise any of the rights described above, or are dissatisfied with the way we have used your personal information, please contact our Information Officer.
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