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The company Accace Adept (PTY) LTD, with its registered office at Boundary Terraces, 1 Mariendahl Avenue, Newlands, Cape Town 7700, South Africa, with company registration number 2018/507049/07 (hereinafter “Accace Adept”) processes the following groups of personal data:
the personal data in relation to which Accace Adept is the controller as it determines the purpose and means of its processing;
the personal data in relation to which Accace Adept is the processor as it processes the respective data on behalf of its clients which determine the purpose and means of its processing.
Accace Adept processes the personal data in accordance with REGULATION (EU) 2016679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter as the “Regulation”).
In terms of the Regulation, Accace Adept has adopted the appropriate technical and organisational measures in order to ensure the protection of the personal data and the rights of the persons, whose personal data is processed (hereinafter as the “Data Subject”). In order to fulfill the obligation laid down by the Regulation, Accace Adept is obliged to inform the Data Subject about the details of the processing of the personal data.
Accace Adept as the Controller may collect the Personal Data for the following purposes:
Marketing
Purpose of personal data collecting: sending our newsletters about important and interesting business-related news, events invitations and other Accace Adept materials.
Legal basis: Art. 6 and 7 from the Regulation (GDPR) regarding the lawfulness of processing and consent; Recital 42 (GDPR) regarding the burden of proof and requirements for consent, and Recital 43 (GDPR) on freely given consent
Scope of personal data: name, surname, company, function, e-mail, phone number, interests (countries, business areas, material/communication type), CVs, other details that the user is including in the available message box
Recipients: IT services suppliers and administrative services in the premises of Accace Adept for the purpose of maintenance only
Transfer to third country: N/A
Storage period: for the period of consent of the data subject or for the period of the contractual relationship (for clients/partners/suppliers)
Data subjects: contact persons of Accace Adept´s clients, potential clients, individuals interested in receiving the information our company is offering (newsletters, events, informational or promotional materials, career and business opportunities)
Categories of processing: collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, alignment or combination, restriction, erasure or destruction
Job applicants
Purpose: keeping records of unsuccessful job applicants of the controller
Legal basis: consent (art. 6 para. 1 a) of the Regulation)
Scope of personal data: data stated in curriculum vitae and other accompanying documents
Recipients: IT services suppliers and administrative services in the premises of Accace Adept for the purpose of maintenance only
Transfer to third country: N/A
Storage period: for the period of 2 years
Data subjects: job applicants
KYC (Know Your Client)
Purpose: fulfilling of controller’s obligations resulting from legislation related to the prevention of legalization of proceeds from criminal activity and to the prevention of the terrorist financing.
Legal basis: compliance with a legal obligation (art. 6 para. 1 c) of the Regulation), especially with the Act No. 297/2008 Coll. on the prevention of legalization of proceeds from criminal activity and on the prevention of terrorist financing.
Scope of personal data: name, surname, personal number, eventually date of birth, address of permanent residence, eventually of temporary residence, nationality, eventually additional personal data required in terms of the special legal regulation stated above.
Recipients: directorate of the financial authority, law enforcement authorities, IT services suppliers, administrative services in the premises of the controller.
Transfer to third country: N/A
Storage period: during the contractual relationship and 5 years after its termination.
Data subjects: statutory bodies, proxy holders, contact persons, ultimate beneficiaries of the controller´s clients.
Contractual Documentation
Purpose: Administration of evidence of natural persons with whom a contract has been concluded, contact persons in case of contracts with legal persons and natural persons to whom the Power of Attorney has been granted.
Legal basis: contract (art. 6 para. 1 b) of the Regulation) legitimate interest (art. 6 para. 1 f) of the Regulation) – processing of contact data of the client´s employee for communication purposes.
Scope of personal data: degree, name, surname, maiden name, job position, address of permanent residence, address of temporary residence, phone number and e-mail, date of birth, type and number of identification card, bank account, signature.
Recipients: tax authorities, courts, Social insurance company, health insurance company, banks, IT services suppliers, administrative services in the premises of the controller.
Transfer to third country: N/A
Storage period: during the contractual relationship and 11 years after its termination.
Data subjects: employees of the controller, natural persons with whom a contract has been concluded or to whom the power of attorney has been granted, contact persons of the client.
Mail
Purpose: keeping records of recipients and senders of mail.
Legal basis: legitimate interest (art. 6 para. 1 f) of the Regulation) – to be informed on the date of the sent and received mail including the sender and recipient in order to protect the rights and interests of the controller.
Scope of personal data: degree, name, surname, signature, address, e-mail.
Recipients: IT services suppliers, administrative services in the premises of the controller.
Transfer to third country: N/A
Storage period: 5 years following the closure of the evidence for calendar year.
Data subjects: natural persons – senders and receivers of mails.
Accace Adept as the Processor shall process the Personal Data in the areas of the provision of the services based on the contract or any other legal act:
HR (including Recruitment services) and Payroll services
Purpose of personal data collecting: Provision of the services of the fulfilling of the obligations of the employer related to employment relationship or to similar labour relations
Legal basis: compliance with a legal obligation of the controller (art. 6 para. 1 c) of the Regulation) based on the local legislation and performance of contract (art. 6 para. 1 b of the Regulation) Scope of personal data: personal data required in terms of the special legal regulations stated in the local legislation
Recipients: Social insurance company, health insurance companies, tax authorities, supplementary pension insurance company, labour inspectorate, Labour offices, courts, law enforcement authorities, bailiff, payroll software providers, IT services suppliers, administrative services providers in the premises of Accace Adept for the purpose of maintenance only
Transfer to third country: N/A
Storage period: for the period of the contractual relationship with the controller and afterwards for 11 years
Data subjects: Candidates, employees of the controller, spouses of the employees, dependent children of the employees, parents of the dependent children of the employees, close relatives, former employees
Categories of processing: collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction
Accounting services
Purpose of personal data collecting: maintenance of accountancy of the controller according to local legislation
Legal basis: compliance with a legal obligation of the controller (art. 6 para. 1 c) of the Regulation) based on the local legislation
Scope of personal data: personal data required in terms of the special legal regulations stated in the local legislation
Recipients: Social insurance company, health insurance companies, tax authorities, accounting software providers, IT services suppliers, administrative services providers in the premises of Accace Adept for the purpose of maintenance only
Transfer to third country: N/A
Storage period: for the period of the contractual relationship with the controller and afterwards for 11 years
Data subjects: employees, statutory bodies and shareholders of the controller, external trainers and trainees
Categories of processing: collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction
Tax services
Purpose of personal data collecting: Provision of tax advisory services according to the local legislation
Legal basis: compliance with a legal obligation of the controller (art. 6 para. 1 c) of the Regulation) based on the local legislation
Scope of personal data: personal data required in terms of the special legal regulations stated in the local legislation
Recipients: Social insurance company, health insurance companies, tax authorities, accounting software providers, IT services suppliers, administrative services providers in the premises of of Accace Adept for the purpose of maintenance only
Transfer to third country: N/A
Storage period: for the period of the contractual relationship with the controller and afterwards for 11 years
Data subjects: employee, statutory body, shareholders of the controller, external trainers and trainees
Categories of processing: collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction
Legal and corporate services
Purpose of personal data collecting: Provision of legal services according to the local legislation
Legal basis: compliance with a legal obligation of the controller (art. 6 para. 1 c) of the Regulation) based on the local legislation, legitimate interest (Art. 6 para. 1 f) of the Regulation – for protection of the rights and interest of the controller in case of any claims and the performance of a contract (Art. 6 para. 1 b) of the Regulation)
Scope of personal data: all personal data processed by the controller in the necessary extent for fulfilling rights and obligations laid down by the valid legislation (based on the principle of proportionality)
Recipients: courts, public authorities, insurance companies, law enforcement companies, IT services suppliers, administrative services in the premises of Accace Adept for the purpose of maintenance only Transfer to third country: N/A
Storage period: for the period of the contractual relationship with the controller and afterwards for 11 years
Data subjects: Employees of the controller, natural persons performing the services to the controller upon the contract on cooperation, statutory bodies, proxy holders, clients – natural persons, contact persons of the clients, external trainers and trainees
Categories of processing: collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, alignment or combination, restriction, erasure or destruction
The Data Subject shall have the following rights in relation to the personal data processing:
Right of access by the data subject
It does not mean that the data subject should have direct access to the systems, however, the data subject should be informed what, where, for what reason, who is the recipient and period of storage for personal data proceeding and the copy of the personal data.
Right to object
The data subject can object any time the processing of personal data based on the public interest or legitimate interest of the controller, including profiling. Example: personal data processed for marketing purposes – the data subject can unsubscribe from receiving marketing materials.
Right to be forgotten
The data subject shall have the right to obtain from the controller the erasure of personal data in case the personal data is no longer necessary, the data subject withdraws consent, the data subject objects to the processing pursuant to Article 21(A) and there are no overriding legitimate grounds for the processing, the personal data have been unlawfully processed, etc.
Right to restrict the processing
In the regulation, there are four specific situations (art. 18 sec. 1 a) – d). Example: the data subject contested the accuracy of personal data and for a period of verifying, the personal data processing shall be restricted.
Right to data portability
The data subject shall have the right to receive the personal data concerning them, which they have provided to a controller in a structured, commonly used and machine-readable format and transmit the personal data to another controller.
Right to rectification
In case the personal data is inaccurate or incomplete.
Contact: Tatiana Valentová, Data Protection Officer | E-mail:
About Accace Adept South Africa
We are a joint venture between Accace and Adept Advisory, established to pursue a long-term strategy of providing innovative Business Process Outsourcing (BPO) and advisory services to clients in the United Kingdom and South Africa. We joined forces to augment each other’s valuable insight, knowhow and practices, whilst combining our experience in complementary fields of expertise.
About Accace Circle
Accace Adept operates internationally as Accace Circle, a co-created business community of like-minded BPO providers and advisors who deliver outstanding services with elevated customer experience and erase the borders of service delivery. Covering over 50 jurisdictions with nearly 2,500 professionals, we support more than 15,000 customers, mostly mid-size and international Fortune 500 companies from various sectors, and process at least 200,000 pay slips globally.
