Privacy Policy Implementation Guide

1.Purpose & Overview

• Goal: Ensure compliance with GSS’S Privacy Policy & the Protection of Personal Information Act (POPIA)

• Scope: Covers all GSS employees, third-party providers & affiliates.

2. Definition & Key Terms

• Define terms like Data Subject, Responsible Party & Data Breach for clarity, aligning with both PAIA Manual & Privacy Policy.

3. Collecting Personal Information

• Collect information directly when possible.

• Ensure that all data collection complies with legal requirements & Data Subjects are informed of the purpose.

4. Processing Personal Information

• Process data only when there’s a legal basis & for disclosed purposes – if you need to gather personal information, remember to ensure that consent is given, expressly or implied.

• Allow Data Subjects to withdraw consent if processing is based on consent.

• Use secure systems & workflows to document processing activities.

5. Data Accuracy & minimization

• Accuracy: Follow PAIA guidelines to verify & update personal data regularly,

especially for employment or customer information.

• Minimization: Only collect & retain the minimum amount of data necessary.

Privacy Practices for Data Security

6.6.1 Password Protection & Access Control

• Use unique, strong passwords for all systems & documents containing sensitive data.

• Restrict data access to employees on a “need-to-know” basis, using unique user ID’s for accountability.

6.2 Data Encryption

• Encrypt sensitive data files & emails when sharing or storing them.

• Require password-protected attachments for sensitive information shared by email .

6.3 Devices & Network Security

• Install antivirus data files & emails when sharing or storing them.

• Conduct regularly vulnerability scans & monitor networks as outlined in the PAIA

Manual to detect threats.

6.4 Physical Security Measures

• Restrict physical access to areas where data is stored with keycards or biometric controls.

• Implement a clear-desk policy & lock all sensitive files when not in use.

6.5 Secure disposal of Data

• Shred or securely delete all data no longer needed, according to retention policies outlined in PAIA Manual.

• For digital data, follow secure erasure techniques to prevent data reconstruction.

6.6. Backup & Recovery

• Ensure data backups are stored securely, tested regularly & capable of swift recovery in case of data loss.

6.7 Regular Audits & Monitoring

• Conduct routine audits or access logos & compliance with privacy practices.

• Record & investigate any access irregularities, aligning with PAIA compliance

requirements.

7. Data Breach Response

• Follow established procedures for detecting & addressing breaches, including

notifying affected parties are required by POPIA & the PAIA Manual.

8. Third-Party Data Shipping & Cross-Border Transfers

• Ensure third-party compliance with GSS’s privacy standards by formal agreement,particularly for data storage or processing outside South Africa.

9. Data Subject Rights

• Facilitate secure verification process to protect against unauthorized access requests.

10.Employee Training & Awareness

• Conduct training on privacy best practices, including phishing & social engineering awareness, as outlined in the PAIA Manual.

• Emphasize the importance of reporting security incidents or breaches promptly.

11.Policy Updates & Contact Information

• Regularly update the privacy practices & inform employees of changes.

• Include contact details for the Information Officer for questions & data requests.