This Notice explains how we obtain, use and disclose your personal information, as is required by the Protection of Personal Information Act (“POPIA”). Old Mutual SuperFund are committed to protecting your privacy and to ensure that your personal information is collected and used properly, lawfully and transparently.
This Notice sets out:
- Who we are
- What information we collect and from where we collect it
- The purposes for which we use your information
- Our aim to provide ongoing retirement benefit services
- To whom we disclose your information
- How we safeguard your information
- Your rights to access and correction of information
- Changes to this Notice
- How to contact us
- The Information Regulator’s contact details
WHO WE ARE
In this Notice, “Old Mutual SuperFund”, refers to one or more of the entities in the Old Mutual SuperFund Group that operate in South Africa.
THE INFORMATION WE COLLECT
We collect and process your personal information mainly to provide you with access to our services and products, to help us improve our offerings to you and for certain other purposes explained below.
When you include information about third parties (for example your spouse, beneficiaries and/or dependents), we will process their personal information for the activation of the benefit and to pursue their legitimate interest. We will furthermore process their information for the purposes set out in this Privacy Notice. You warrant that when you give us personal information about third parties, you have received their permission to share their personal information with us for the purposes set out in this Privacy Notice or any other related purposes.
The type of information we collect will depend on the purpose for which it is collected and used. We will only collect information that we need for that purpose.
We collect information directly from you where you provide us with your personal details, for example when you purchase a product or services from us or when you submit enquiries to us or contact us. Where possible, we will inform you what information you are required to provide to us and what information is optional.
We also collect information about you from other sources as explained below.
Website usage information is collected using “cookies” which allows us to collect standard internet visitor usage information.
HOW WE USE YOUR INFORMATION
We will use your personal information only for the following purposes:
- To provide products or services to you, to carry out the transaction you requested and to maintain our relationship;
- To provide you with information about offerings that will support and enhance your retirement benefits that you qualify for;
- For underwriting purposes;
- To assess and process claims;
- To conduct credit reference searches or verification;
- To confirm and verify your identity or to verify that you are an authorised user for security purposes;
- For operational purposes, and where applicable, credit scoring and assessment and credit management;
- For maintaining accuracy of your personal information;
- For purposes of claim checks (e.g. the Industry Life and Claims Register);
- For the detection and prevention of fraud, crime, money laundering or other malpractice;
- To conduct market or customer satisfaction research or for statistical analysis;
- For audit and record keeping purposes;
- In connection with legal proceedings.
We will also use your personal information to comply with legal and regulatory requirements or industry codes to which we subscribe or which apply to us, or when it is otherwise allowed by law (for example to protect Old Mutual SuperFund’s interests).
DISCLOSURE AND COLLECTION OF INFORMATION
We may disclose your personal information to our service providers who are involved in the delivery of products or services to you. We have agreements in place to ensure that they comply with these privacy terms.
We may share your personal information with, and obtain information about you from:
- Third parties for the purposes listed above, for example credit reference and fraud prevention agencies, law enforcement agencies, tracing agents;
- Other insurers to prevent fraudulent claims;
- Companies in the Old Mutual Group for the purposes listed above, or when we believe it will enhance the services and products we can offer to you, but only where you have not objected to such sharing. This includes supplementing the information that you provide to us with information we receive from other companies in the Old Mutual Group in order to offer you a more consistent and personalized experience in your interactions with Old Mutual SuperFund;
- Your employer or its broker;
- Your own broker when applicable.
We have a duty to take all reasonably practicable steps to ensure your personal information is complete, accurate, not misleading and updated on a regular basis. To enable this we will always try to obtain personal information from you directly. Where we are unable to do so, we will make use of verifiable independent third party data sources.
We may also disclose your information:
- Where we have a duty or a right to disclose in terms of law or industry codes;
- Where we believe it is necessary to protect our rights.
We are legally obliged to provide adequate protection for the personal information we hold and to stop unauthorised access and use of personal information. We will, on an ongoing basis, continue to review our security controls and related processes to ensure that your personal information is secure.
Our security policies and procedures cover:
- Physical security;
- Computer and network security;
- Access to personal information;
- Secure communications;
- Security in contracting out activities or functions;
- Retention and disposal of information;
- Acceptable usage of personal information;
- Governance and regulatory issues;
- Monitoring access and usage of private information;
- Investigating and reacting to security incidents.
When we contract with third parties, we impose appropriate security, privacy and confidentiality obligations on them to ensure that personal information that we remain responsible for, is kept secure.
We may need to transfer your personal information to another country for processing or storage. We will ensure that anyone to whom we pass your personal information agrees to treat your information with the same level of protection as we are obliged to.
YOUR RIGHTS: ACCESS TO INFORMATION
You have the right to request a copy of the personal information we hold about you. To do this, contact us at the numbers/addresses listed below and specify what information you would like. We will take all reasonable steps to confirm your identity before providing details of your personal information.
Please note that any such access request may be subject to a payment of a legally allowable fee and we will let you know what it is at the time of your request.
CORRECTION OF YOUR INFORMATION
In certain cases you have the right to object to the processing of your personal information. You also have the right to ask us to update your information, and ask us to correct or delete your personal information when it is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully. You may do this by contacting us at the numbers/addresses provided below.
Where we cannot delete your personal information, we will take all steps to make it anonymous. You agree that we may keep your personal information until you ask us to delete or destroy it. This is unless the law requires us to keep it.
We will take all reasonable steps to confirm your identity before making changes to personal information we may hold about you.
We would appreciate it if you would keep your personal information accurate.
CHANGES TO THIS NOTICE
Please note that we may amend this Notice from time to time. Please check this website periodically to inform yourself of any changes.
HOW TO CONTACT US
If you have questions about this Notice or believe we have not adhered to it, or need further information about our privacy practices or wish to give or withdraw consent, exercise preferences or access or correct your personal information, please contact us at the following numbers/addresses:
- SuperFund Service Centre: 0860 20 30 40
You have the right to complain to the Information Regulator, whose contact details are: