Who we are
The TSC (Tenure Support Centre – https://titledeed.org.za) started as a research project operated between 17point4 and CAHF. 71point4 (2017/282302/07) is the trading name for Thirty-Five Thousand Holdings (Pty). CAHF (the Centre for Affordable Housing Finance in Africa) is a Public Benefit Organisation (157-561 NPO) in South Africa, and collectively the project run by them is called the TSC going forward in this document.
The TSC values and respects the privacy of everyone who visits titedeed.org.za and with whom we engage during the course of our legitimate business interests as a company. Should we ask you to provide certain information by which you can be identified, you can be assured that it will only be used in accordance with this privacy statement. We process your personal data in accordance with South African Data Protection laws, and have suitable physical, electronic, security and managerial procedures in place to safeguard your data.
This privacy policy sets out how TSC collects, processes and protects your personal data, and our rights and responsibilities regarding your data.
Personal Data Collected
The following types of personal data is collected by the TSC:
• Personal data we receive from employees, prospective employees, subcontractors, partners and clients which could include information such as names, occupations, ages, gender, ID numbers, marital status, and income and expenditure patterns.
• Sensitive personal data collected by surveys required for certain projects. This might include: race/ ethnic background, religious beliefs, physical or mental health, sexual life, income and expenditure patterns. At the start of any survey, data subjects will be provided with information as to the reason this data is collected. They will also be required to consent to participating in the survey, and participation is always optional
• Other personal information as required to achieve the requirements of the project
• The time, date, location and topic of the project that the data subject participated in.
Note: the TSC conducts a wide variety of tenure support activities, including occupancy surveys, and the nature of the data collected will depend on the activity requirements. In line with the principles of POPIA, the TSC will always endeavour to collect the minimum amount of personal data to successfully complete any given outcome.
How Personal Data Is Used
Our use of your personal data will always be on a lawful basis and for our legitimate business purposes.
Personal data may be used for
• Research purposes
• Improving our products and services
• Internal monitoring and reporting
• Training
• Recruiting where you have applied for a position with us, including to contact you to discuss the role further
• Supplying our products and services to you
• Maintaining administrative and statutory records about our business with regard to SARS and any other regulatory requirements (applicable to full time staff only)
• Entering into a contract with you
• Enabling comments on the website
Period Of Data Retention
We only keep your personal data for as long as we need to, and to use it for the reason(s) it was originally collected. After this, we ensure that all personal data is deleted or securely discarded. The TSC stores your personal data for as long as necessary to achieve our business purposes, or as stipulated by the various storage periods provided by law. Please note that property transactions may have the requirement to retain data for up to 30 years.
Ways In Which Personal Data Is Collected
The TSC collects personal data through the following methods:
• From clients we work for
• Through surveys driven and conducted by TSC and its subcontractors. The surveys can be digital or face to face.
• From publicly available sources
Sharing Of Personal Data
We will never sell, share or rent your personal data without your prior consent.
Third Parties
Your data will not be passed on to third parties for advertising purposes.
In certain cases, we may provide service providers with your personal data in order for us to properly perform our duties.
We carefully select our service providers who uphold the high data management standards that are aligned with those set out under the relevant South African Laws, with a specific emphasis on data protection and data security standards.
Where we act as an operator on behalf of a client to collect data, we may pass on your data to our client. This will be disclosed to you at the time the data is collected, and we will obtain your consent to share the data.
International Transfer of Personal Information
The TSC is based in South Africa, but we leverage cloud based computing solutions that may be hosted outside of the domain of South Africa. The TSC will ensure that data policies and access control are retained to South African standards for all information that may be impacted.
Your Rights With Regards To Your Personal Data
You have the following rights with respect to your personal data:
• The right to be informed about our collection, use and storage of your personal data. This information is contained within this Privacy Policy
• The right to have access your data. You can request details about the personal data we have about you by requesting this in writing to info@titledeed.org.za. Certain conditions and exclusions apply to this right
• Should you consider your personal data to be incorrect, you may request for it to be corrected and rectified
• You have the right to have your personal data erased if the personal data is no longer required for the purpose for which it was originally collected or processed.
• If you originally gave consent for your data to be collected and held, you can withdraw your consent
• Where lawful to do so, we may not comply with certain enquiries or requests. Examples include if we have reason to believe the request could be harmful to others, is malicious, technically impossible, or involves a disproportionate amount of effort
• Under certain circumstances, you can request the restriction or suppression of processing your personal data.
Data Security
The TSC has put in place reasonable physical, electronic and administrative procedures to safeguard the personal information we collect. Only authorised employees have access to your data in order to perform their duties. However, despite all the reasonable measures in place to protect your data from unauthorised access (e.g. hackers), we cannot fully guarantee this, and your use of our services demonstrates your assumption of that risk.
SECURITY Breach
Although reasonable steps are taken to secure data, data breaches cannot be completely ruled out. The TSC thus has a comprehensive “Incident Response Policy” that aims to effectively and efficiently identify, report, escalate, respond to, and evaluate any security compromises or other related incidents that occur in the organisation.
Website Privacy Policy
The TSC respects the privacy of visitors to its websites. This privacy policy explains how we collect, use, disclose and protect personal data submitted through the website.
Audience
This policy applies to you if you are:
• a visitor to our website;
• a subscriber to our mailing list;
Data we collect
Personal information includes:
• certain information that we collect automatically when you visit our website;
• certain information collected on registration;
• certain information collected on submission; and
• optional information that you provide to us voluntarily
Common examples of the types of personal information which we may collect and process include your:
• identifying information – such as your name, surname, organization and role;
• contact information – such as your email address;
Note: The TSC’s website uses cookies that collect data from users. These cookies will be explained in Section 4 of this document.
Communication By Email
If you provide us with your email address, we may communicate with you by email. We will not pass on your email address to any third parties without your consent.
Social Media / Third Party Plug ins
The TSC websites may contain links to third party websites that provide more information about TSC:
Third Party Website links that may be contained in our website include:
• Pintrest
• 71Point4
• CAHF
The corresponding icons associated with these social media providers work as external links, so that no information is transferred to one of these providers without clicking on one of the icons.
The TSC does not control these websites and we are not responsible for information you post or comments you make on these sites. The TSC recommends that you review the privacy policies on the social media platforms you use before making remarks or observations in order to fully understand how your information will be used, what information related to you will be in the public domain, and how you can limit this.
We remind you that any comments made about TSC, its products or services on any online platform or community will be shared with the members of that platform or community and may furthermore be accessible by the general public. Extra care should be taken to ensure that any comments made on these platforms are not insulting, offensive or defamatory.
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
Cookies policy
We may place small text files called ‘cookies’ on your device when you visit our website. These files do not contain personal data, but they do contain a personal identifier allowing us to associate your personal data with a certain device. Many websites use cookies and you can find out more about them at www.allaboutcookies.org.
Why Do We Use Cookies?
We use cookies to:
• improve how our website performs;
• understand who our audience is, so that we can provide content most relevant to you;
• allowing third parties to provide services to our website
The types of cookies we use
We use different types of cookies on our website. These are placed on our website by third parties. These cookies may be deleted from your device at different times, such as at the end of your browsing session (when you leave the website) or after a pre-set amount time, or they may persist on your device until you delete them.
We use the following types of cookies on our website:
• site analytics cookies – these are cookies that monitor how our website is performing, and how you interact with it. We use them to know how best to improve our website or services.
• third party cookies – these are cookies that some of our business partners use on our website. We have no access to or control over them. Information collected by any of these cookies or widgets is governed by the privacy policy of the company that created it, and not by us.
Our cookies
You can see the cookies we use in the following table:
| COOKIE NAME | Cookie Type | Cookie Function |
|---|---|---|
| _ga | Analytics | This cookie is installed by Google Analytics. The cookie is used to calculate visitor, session, campaign data and keep track of site usage for the site’s analytics report. The cookies store information anonymously and assign a randomly generated number to identify unique visitors. |
| _gid | Analytics | This cookie is installed by Google Analytics. The cookie is used to store information of how visitors use a website and helps in creating an analytics report of how the website is doing. The data collected including the number visitors, the source where they have come from, and the pages visited in an anonymous form. |
| _gat | Third Party | This cookie is installed by Google Universal Analytics to throttle the request rate to limit the collection of data on high traffic sites. |
Deleting cookies
Your internet browser generally accepts cookies automatically, but you can often change this setting to stop accepting them. You can also delete cookies manually. You can read how to do this at https://www.digitaltrends.com/computing/how-to-delete-cookies/ .
Deleting or no longer accepting cookies will have no impact on our website performance.
Website Content Creation Tools
This website is created using content tools like WordPress which leverages themes and third party content in order to delivery information and services. In some cases, when comments are left, or other functionality is utilised, an anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. These operate under their own privacy policy which can be found here: https://automattic.com/privacy/.
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
How You Can Contact Us
For more information about our Privacy Policy or associated practices, please contact the TSC:
Email: info@titledeed.org.za