CS Morritt is committed to safeguarding and protecting Personal Information.
This Policy includes CS Morritt cc (together “CS Morritt”, “we” or “us”).
The term “Personal Information” referred in this Policy shall bear the same meaning as that contained in the Protection of Personal Information Act No. 4 of 2013 (“POPI”).
“Our People” includes our directors, employees and contractor staff.
We require our People to follow this Policy, as well as those of our Suppliers authorised to manage Personal Information on our behalf.
CS Morritt collects Personal Information from a range of individuals in the context of our business activities including our People; job applicants; representatives of our suppliers, customers, contractors and subsidiaries; shareholders; users of our website; and visitors to our operational and office sites.
We may use personal data provided to us for any of the purposes described in this Policy or as otherwise stated at the point of collection.
How and what types of personal information do we process
The Personal Information we may collect depends on our relationship with you. We will limit the types of personal information we process to only that to which you consent, and which is necessary for our legitimate business interests.
Broadly speaking, we collect Personal Information about you in the following ways:
CS Morritt may ask you to voluntarily supply Personal Information to us, electronically or otherwise. For example, we may ask you to provide your contact details when you submit enquiries to us through the “Contact Us” page on our website or ask to receive information from us.
Certain of your personal information may be required to provide a service or product to you.
When you visit our website, or use our products and services, we may collect information automatically from your device.
In some cases, information can be collected from other sources, including publicly available sources, such as public databases where permitted by law or from a third party, such as through your representatives, contractors who provide services to us, or other third parties who are entitled to share that information. In addition, where you have expressed an interest in career opportunities with CS Morritt, we may obtain Personal Information provided to us by HR practitioners, hiring managers and recruitment advisors.
Types of Personal Information we may collect
We reserve the right to collect personal information such as:
- Personal details (e.g. name, identity number, address)
- Contact details (e.g. phone numbers, email address)
- Employment details (e.g. job title, employer name)
- Other information necessary in the circumstances, including from any communications you send us.
Under privacy laws, certain categories of Personal Information are considered particularly sensitive or special and therefore need additional protection. This includes information about racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, trade-union membership, health or medical conditions, genetic or biometric information, sexual orientation, or criminal convictions and offences. CS Morritt will only collect, manage and use your sensitive Personal Information where we have obtained your explicit consent or where we have other lawful grounds to do so under applicable law.
Use of personal information
We use your personal information to:
- Carry out background checks prior to accepting you as a customer or employee.
- Contact you regarding services or products we are supplying to you.
- Ensure that our records are kept accurate and up to date where you or your employees, including contractors visit our sites.
- Ensure we produce accurate invoices and supporting documentation for services or products supplied to you.
- Comply with legal obligations: To fulfil a contractual obligation, we have with you. Health and Safety obligations while you are on our sites.
- To meet our legitimate business interests so that we are able to provide services or products which are requested by you in a manner as expected and agreed upon.
Retention of personal information
We will retain your personal information for no longer than is necessary in the circumstances, considering the purpose for which the information was collected and for which it is used and where we have an ongoing business need to do so.
In addition, we may retain your personal information for the time periods required to comply with an applicable law.
We may hold your Personal Information in electronic or in hard copy form. We may keep this information at our own premises, or at sites managed by our service providers.
How do we disclose personal information
In general, we do not share your personal information with third parties (other than service providers acting on our behalf) unless we have a lawful basis for doing so.
We rely on third-party service providers to perform a variety of services on our behalf, such as website hosting, electronic message delivery, payment processing, data analytics and research. This may mean that we have to share your personal information with these third parties. When we share your personal information in this way, we put in place appropriate measures to make sure that our service providers keep your personal information secure.
Your Personal Information may be disclosed between related entities within the CS Morritt Group and used by those entities for the same purposes for which we are entitled to use it.
In appropriate circumstances, we may also disclose your Personal Information to the following categories of third parties:
- Auditors, legal and other professional advisors and share registries
- IT and other service providers
- Government and law enforcement authorities
- Financial institutions
- HR practitioners, hiring managers and recruitment advisors (including relevant to Personal Information provided to us via our job vacancy website and for the purpose of considering you for career opportunities with CS Morritt)
- Other third parties where disclosure is required by law
- To any other person with your consent to the disclosure.
We take reasonable steps to protect the confidentiality and security of your Personal Information when it is disclosed to a third party, and seek to ensure the third party deals with your information in accordance with our instructions, applicable privacy laws, and only for the purpose for which it is disclosed.
Will my personal information be disclosed or transferred overseas?
In some cases, the third parties to whom CS Morritt may disclose your Personal Information may be located outside your country of residence (for example, in a cloud service, system or server), and may be subject to different privacy regimes. This includes our own related entities.
Where required by applicable law when we disclose Personal Information overseas, we will take appropriate safeguards to protect your Personal Information and that the recipient will handle the information in a manner consistent with this Policy and all applicable privacy laws.
For more information on the transfer of Personal Information and the safeguards CS Morritt has in place, please contact us using the details below contained in this Policy.
What are cookies? Cookies are small data files that are placed on your computer or mobile device when you visit a website to track the number of visitors to our website, collect information (where available) about your computer or mobile device for system administration purposes, to evaluate our website’s effectiveness and improve your experience.
Cookies set by the website owner (in this case, CS Morritt) are called “first party cookies”. Cookies set by parties other than the website owner are called “third party cookies”. CS Morritt does not use any third-party cookies.
We use first party cookies for several reasons. Some cookies are required for technical reasons in order for our websites to operate, and we refer to these as “essential” or “strictly necessary” cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our websites. This information is used anonymously and in aggregate and is collected and logged for statistical and security purposes. Cookies are not used by us to identify who you are or to send you advertising.
How can I control cookies?
Limitation of our responsibility
We are not responsible for, give no warranties, nor make any representations in respect of the privacy policies or practices of linked or any third-party websites.
You can request access to your Personal Information held by us, or request that it be updated or corrected, at any time, by contacting us at the details below.
Access to personal information
Please refer to CS Morritt’ Access to Information Manual for more information on how to access your Personal Information. You can find the manual at https://csmorritt.co.za/csmorritt_paia_manual.pdf (PDF)
Who can I contact if I have a question or a complaint?
If you have a question, concern or complaint regarding the way in which we handle your Personal Information, or if you believe that CS Morritt has failed to comply with this Policy or breached any applicable laws in relation to the management of that information, you can make a complaint.
Any question, concern or complaint should be made in writing to:
Information Officer: Shirley Morritt
Physical address: Wydan Business Park, No. 58, Road No. 5, Unit No. 4, Brentwood Park, Benoni
Telephone number: +27 72 614 7044
Policy review and updates
We will review this Policy periodically and update it from time to time, or when relevant regulatory changes occur. CS Morritt reserves the right to amend this Policy or add provisions to it at any time by publishing an updated version on its website.