eStudy (Pty) Ltd (“eStudy”, “we”, “us” or “our”) is committed to protecting the privacy and Personal Information of the individuals and organisations with whom we engage.
As a Digital Learning and Development company providing learning technology, learning services and learning programmes, we recognise the importance of processing Personal Information responsibly, lawfully and transparently.
eStudy has implemented a POPIA Compliance Framework to support compliance with the Protection of Personal Information Act 4 of 2013 (“POPIA”), the Promotion of Access to Information Act 2 of 2000 (“PAIA”), and their applicable regulations. Our compliance framework includes our PAIA Manual, Privacy Policy and POPIA Policy and is monitored and reviewed to support continual improvement.
The purpose of this notice is to provide our stakeholders with an overview of eStudy’s approach to privacy, Personal Information and data protection.
eStudy respects the right to privacy and is committed to protecting Personal Information entrusted to us.
Our POPIA Compliance Framework establishes the principles and standards that apply when Personal Information is collected, received, recorded, stored, used, shared, updated or otherwise processed by eStudy.
In accordance with our POPIA Policy, we are committed to:
These commitments form part of eStudy’s organisation-wide approach to privacy and Personal Information protection.
eStudy processes Personal Information in accordance with the eight conditions for lawful processing set out in POPIA.
These conditions relate to:
These principles guide how Personal Information is processed throughout eStudy. The eight-condition structure and eStudy’s security and access commitments are expressly reflected in the POPIA Policy.
eStudy has established a POPIA Compliance Framework which is maintained by the Information Officer and, where applicable, the Deputy Information Officer.
The framework includes the following key documents and measures:
Our POPIA Policy establishes the principles, responsibilities and standards applicable to the lawful processing and protection of Personal Information within eStudy.
The Policy applies throughout eStudy and governs Personal Information processed through both automated and non-automated means. It also applies to employees and other relevant parties where the exchange or processing of Personal Information is necessary.
Our Privacy Policy provides information regarding the Personal Information eStudy may process, the purposes for which information may be processed, how information may be used and shared, and the rights available to Data Subjects.
We encourage all individuals who interact with eStudy’s website, products and services to familiarise themselves with our Privacy Policy.
eStudy has implemented a PAIA Manual in accordance with the Promotion of Access to Information Act.
The PAIA Manual sets out the processes through which a person may request access to records and Personal Information held by eStudy, subject to applicable legal requirements and appropriate proof of identity. The POPIA Policy specifically recognises Data Subjects’ rights to confirm whether eStudy holds their Personal Information and to request access to relevant records or descriptions of that information.
eStudy’s Information Officer is responsible for encouraging compliance with the conditions for lawful processing of Personal Information and supporting the implementation, monitoring, maintenance and continual improvement of eStudy’s POPIA Compliance Framework.
The Information Officer is also responsible for dealing with applicable POPIA requests, working with the Information Regulator where required, supporting Personal Information Impact Assessments and facilitating internal awareness regarding POPIA and PAIA.
Information Officer
Name: Marne Eloff
Telephone: 012 997 0037
Email: Marne@estudysa.co.za
eStudy recognises the importance of identifying and managing privacy risks when implementing projects, systems or technologies that involve Personal Information.
Where required by our POPIA Policy, a Personal Information Impact Assessment (“PIIA”) is conducted to assess the nature of the Personal Information being processed, the purpose and lawfulness of the processing, potential risks to Data Subjects and the safeguards required to mitigate identified risks.
PIIAs may apply to projects involving new technology, biometric or surveillance tools, customer management systems, third-party or cloud platforms, and AI or algorithmic profiling involving Personal Information.
eStudy is committed to maintaining appropriate organisational and technical safeguards to protect Personal and Confidential Information from loss, damage, unauthorised destruction and unlawful access.
Where a third party or Operator processes Personal Information on behalf of eStudy, appropriate written agreements and safeguards are required in accordance with our POPIA Policy.
Employees may not share Personal Information with a third party or Operator without the appropriate contractual safeguards being in place.
Where eStudy becomes aware of a security compromise or has reasonable grounds to believe that Personal Information has been accessed or acquired by an unauthorised person, the matter is escalated and managed in accordance with POPIA and eStudy’s internal processes.
Protecting Personal Information is a shared responsibility.
eStudy conducts POPIA training and awareness for employees on at least an annual basis and incorporates POPIA awareness into the onboarding of new employees.
Ongoing awareness may also be supported through internal communications, short videos, posters and other awareness initiatives.
eStudy recognises the increasing use of Artificial Intelligence (“AI”) in the workplace and the importance of ensuring that AI is used responsibly.
Employees are prohibited from entering eStudy Personal Information, Data Subject Personal Information, or Confidential, Financial or Proprietary Information into unapproved AI systems.
The sharing of conversations from unapproved AI programmes is also prohibited in accordance with eStudy’s POPIA Policy.
Subject to POPIA, PAIA and applicable legal requirements, Data Subjects may have the right to:
Requests may be subject to verification of identity and must be submitted in accordance with the procedures set out in eStudy’s PAIA Manual.
eStudy’s POPIA Compliance Framework is monitored and maintained on an ongoing basis.
Our Information Officer monitors internal POPIA and PAIA compliance and relevant legal and regulatory developments. eStudy’s POPIA Policy is reviewed at least annually or where changes to applicable legislation or regulations require an earlier review.
eStudy takes the privacy and protection of Personal Information seriously.
Our approach to POPIA compliance is focused on responsible and lawful processing, transparency, appropriate security safeguards and continuous improvement.
We remain committed to maintaining a practical and effective POPIA Compliance Framework that supports our employees, customers, stakeholders and other Data Subjects whose Personal Information may be processed by eStudy.
For further information regarding how eStudy processes Personal Information, please refer to our Privacy Policy and PAIA Manual, or contact our Information Officer.
