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The Click Foundation Trust a charitable trust registered in South Africa (master’s reference number IT 400/12) having its registered address at 9^th Floor, 90 Grayston Drive, Sandton, Johannesburg, (Click Foundation, we, us, our) is committed to protecting the privacy and security of your personal information.

Click Foundation was established in 2012 to find ways of using technology in education to pursue outcomes-based interventions that can meaningfully impact learners. The primary focus of the Click Foundation has therefore been the implementation of an online phonetics based English literacy and, more recently, mathematic programmes as well as teacher and facilitator training (Education Programme).

Click Foundation is committed to complying with the Protection of Personal Information Act 4 of 2013 (POPI) and to protecting your personal information and privacy.

This privacy notice sets out the basis on which any personal information Click Foundation collects from you, or that you provide to Click Foundation, will be processed by Click Foundation. Please read the following carefully to understand our practices regarding your personal information and how we will treat it.

INFORMATION WE COLLECT FROM STUDENTS, FACILITATORS AND TEACHERS

This is information that the Click Foundation collects and processes about you for the purposes set out in this notice, which information may include name, contact details, race, gender, age, identification number, luritis number, education (including results), nationality, language and disability (in so far as it is required for assisting you in the Education Programme).

In some instances, Click Foundation may receive your personal information from a third-party, the school you attend or work at, the department in charge of the district in which your school is located and/or the provincial education department. Furthermore, Click Foundation may collect your information from publicly available sources such as websites.

Click Foundation collects your personal information for the following purposes:

• to assess and/or verify your suitability for participation in the Education Programme;
• to facilitate your enrolment in the Education Programme and give you access to the education software;
• to assist you in completing certain modules of the Education Programme;
• to track training provided for SACE accredited training;
• to obtain YES funding so that we can provide funding to the schools to be put towards facilitator salaries;
• for analysis, evaluation and research regarding the Education Programme;
• to carry out Click Foundation’s obligations or enforce your obligations arising from any contracts entered into between you and Click Foundation;
• to provide you with the information and services that you request from Click Foundation and for Click Foundation to request information it may require from you;
• to measure compliance with laws including, but not limited to, the Broad Based Black Economic Empowerment Act 53 of 2003 (as amended); and/or
• to inform you about Click Foundation events or initiatives.

Sometimes we take photographs of students and teachers for the purposes of our website and social media pages. We do this to promote our organisation and the Education Programme. We will only do this with your consent and the consent of the legal guardian of the students, which you can withdraw at any time by contacting us (see details at the end of this notice).

INFORMATION WE COLLECT FROM THIRD PARTIES

We collect names and contact details of the schools and government departments we work with for the purposes of collaborating with you and providing the Education Programme and communicating with the you.

We collect names, contact details, financial, B-BBEE information and tax information from suppliers and professional service providers so that we can place orders/instruct you and make payment in respect of any goods or services we receive as well as to measure compliance with applicable laws. We do this on the basis of the intention of contracting with you or for the performance of a contract we have with you.

We collect names and contact details from supporters and funders on the basis that we have a legitimate interest in communicating with you, collaborating with you and to inform you about Click Foundation events or initiatives.

INFORMATION WE COLLECT FROM YOU WHEN YOU APPLY FOR A JOB

We process the information you provide in your curriculum vitae and supporting documentation/information during the recruitment process purely for the purposes of assessing your suitability for the role, for contacting you to progress your application and to take up any references you have provided. The basis for the processing of this information is a potential employment contract may be concluded, depending on the outcome of our assessment and we have a legitimate interest in finding candidates for roles that we have. In the event that you are successful, this data will form part of your employment record.

WHAT IF YOU DON’T PROVIDE THE INFORMATION?

Where possible, Click Foundation limits, to the best of its ability, the amount of personal information collected from you. However, please note that in order for a school, teacher, facilitator or student to participate in the Education Programme, certain information is required and accordingly participation is dependent on the Click Foundation being able to collect and process that information.

Furthermore, if you wish to be considered for recruitment or as a supplier or partner, we need your information in order to consider your application or to conclude a contract with you or fulfil our obligation under a contract we may already have with you.

WHO DO WE SHARE YOUR INFORMATION WITH?

Click Foundation may disclose your personal information to third parties, if it is under a duty to disclose or share your personal information in order to comply with any legal obligation; or in order to enforce any contractual terms and conditions and other agreements; or to protect the rights, property, or safety of Click Foundation.

Such third-parties include service providers (including IT suppliers, consultants, professional advisers and volunteers) and government departments and authorities.

All service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third party service providers to use your personal information for their own purposes. We only permit them to process your personal information for specified purposes and in accordance with our instructions.

SECURITY MEASURES IN PLACE TO PROTECT YOUR INFORMATION

Click Foundation has put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. These measures include, but are not limited to, policies and procedures to protect your information and IT security.

We have put in place procedures to deal with any suspected data security breach and will notify you and the Information Regulator of a suspected breach where we are legally required to do so.

HOW LONG DO WE RETAIN YOUR INFORMATION?

Click Foundation will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once the information is no longer required for the purposes for which we collected it we will retain and securely destroy your personal information in accordance with our Document Retention & Destruction policy or applicable laws and regulations.

RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

Under certain circumstances, you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Withdraw consent to us processing your personal information. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, or withdraw consent to us processing your information, please contact the Information Officer stipulated at the end of this notice in writing.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision making, unless we have a lawful basis for doing so and we have notified you. Click Foundation do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

CHANGES TO THIS PRIVACY NOTICE OR YOUR INFORMATION

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

Should your personal information change, please inform Click Foundation and provide Click Foundation with your corrected personal information as soon as reasonably possible to enable Click Foundation to update your personal information on its systems.

WHO CAN YOU CONTACT REGARDING YOUR PERSONAL INFORMATION AND THIS NOTICE?  

Should you have any queries regarding this privacy notice or would like to enforce any rights you may have under POPI, please contact us at:

If you wish to lay a complaint against us regarding the way we have processed your personal information you can do so at South African Information Regulator: http://www.justice.gov.za/inforeg/

July 2018, Version 1