THE CITY OF JOHANNESBURG PRIVACY POLICY
Versions: 3
Last updated: 29 May 2014
1. INTRODUCTION Unless the context clearly indicates to the contrary, any capitalised term in this Privacy Policy shall bear the same meaning as defined in the CoJ Website Terms located on the left had side of the e-Services website screen and upon registration, which definitions shall be deemed to have been incorporated herein by reference.
2. COMPLIANCE WITH APPLICABLE LAW Protecting User privacy is of utmost importance to the CoJ. Accordingly, the CoJ has developed this Privacy Policy in order to safeguard the User’s personal information and to protect the confidentiality thereof. In so doing, the CoJ has paid particular attention to the Constitution of the Republic of South Africa Act, 108 of 1996, the Electronic Communications Act, 25 of 2002 and the Protection of Personal Information Bill of 2006 (currently before the South African Law Commission) and the common law so as to ensure compliance with all relevant statutory requirements and best practice under South African law.
3. NO LIABILITY FOR UNAUTHORISED DISCLOSURE While the CoJ will do all things reasonably necessary to protect the User’s rights of privacy whilst on the CoJ website, the CoJ cannot accept any liability whatsoever for unauthorised or unlawful disclosure of the User’s personal and confidential information made by third parties who are not subject to the CoJ’s control.
4. PERSONAL INFORMATION For purposes of this Privacy Policy, “personal information” includes the User’s initials, surname, first name, passport number/identity number, date of birth, gender, cellphone number, e-mail address, home telephone number, work telephone number, fax number, residential address, postal address, initial of spouse, first name of spouse, identity number of spouse, date of birth of spouse, name of a non-relative and contact number (required for purposes of registration) account numbers where accounts are transmitted via e-mail (required for purposes of meter readings), declaration of income (where a juristic person registers for the RSC levy service), the value of the User’s property (where the User makes use of the Valuation Service), vehicle registration number and date of offence (where a User wishes to pay a traffic fine online) and information pertaining to juristic persons (e.g. Company Name, Company registration number).
5. CONSENT TO COLLECTION By accepting the CoJ Website Terms, the User consents to the CoJ’s collection of personal information on an ongoing basis for the continued duration of the User’s relationship with the CoJ, subject to the limitations set out in this Privacy Policy.
6. COLLECTION OF PERSONAL INFORMATION The CoJ collects personal information where such personal information is necessary for the purposes mentioned in clause 4 and more generally, to provide a particular Service. In addition, the CoJ also collects personal information (i) where a User subscribes for the Corporate GIS newsletter, (ii) for purposes of improving its Service offering, (iii) for purposes of increasing Service efficiency, (iv) for purposes of communicating with Users, (v) providing the Services to Users, (vi) authenticating a User, (vii) providing a User with access to restricted pages on the Website and (viii) compiling non-personal statistical information about browsing habits, click patterns and access to the Website.
7. COOKIES The CoJ uses cookie technology which comprises tiny pieces of data or a small text file that is stored on a User’s computer hard drive and which contains information about a User, so that the next time a User visits the Website, the cookie reminds the CoJ of who the User is, enabling the CoJ to achieve its goal of providing a valuable online experience to all Users. A User is able to however, disable this cookie technology in its own Internet browser.
8. CUSTOMER DATA The User Data collected by the CoJ is used solely in connection with granting Users access to the Website and for purposes of monitoring the User’s use of the Website so as to limit or prevent breaches of security.
9. DISCLOSURE OF PERSONAL INFORMATION The CoJ will not disclose any personal information it collects to any third party without the User’s consent, other than to credit bureaus [correct?] and to other organisations where the CoJ is required to do so by law. The CoJ will also provide personal information to law enforcement authorities in response to subpoenas and other lawful requests where the CoJ believe that the disclosure of such personal information is necessary to identify, contact or institute legal proceedings against third parties who jeopardise the provision and rendering of the Services by the CoJ.
10. RETENTION OF PERSONAL INFORMATION All personal information is stored on the CoJ registration database until such time as the User elects to de-register itself from the Services. As such, all personal information will only be retained for as long as it is necessary to fulfil the purposes mentioned in clauses 4 and 6 above.
11. ACCURATE AND UP TO DATE The CoJ will use its best endeavours to keep the personal information it collects as accurate, complete and up to date as is necessary for the purposes mentioned in clause 4 and 6 above, and the CoJ shall, from time to time, request the User to update its personal information on the Website. Users are able to review or update any personally identifiable information that the CoJ holds on the User by accessing its account online or by e-mailing or phoning the CoJ. In order to better protect Users and safeguard personal information, the CoJ does take steps to verify a User’s identity before granting access to its account or making any corrections to its personal information. As part of its routine maintenance, the CoJ removes undelivered e-mail addresses from its database after a period of three months.
12. SECURITY The CoJ uses encryption, firewalls and other security technology and procedures to help protect the confidentiality of personal information and prevent unauthorized access or improper use thereof. All personal information will be stored and securely hosted and located in a secure environment.
