1. INTRODUCTION

SpecCon Holdings (Pty) Ltd is a training and skills development company committed to protecting personal information in accordance with the Promotion of Access to Information Act (PAIA) and the Protection of Personal Information Act (POPIA). This document outlines how we collect, use, store, and provide access to information.

2. PURPOSE

This policy gives effect to the constitutional right of access to information and ensures that personal information is processed lawfully, transparently, and securely.

3. CONTACT DETAILS

Information requests or POPIA-related queries may be directed to:

4. INFORMATION WE COLLECT

SpecCon Holdings collects and processes information necessary for its operations, including:

• Client and training records
• Employee and HR records
• Financial and administrative information
• Learning and Development Data
• Website usage data (e.g. cookies)

5. PURPOSE OF PROCESSING

Personal information is processed to:

• Deliver training and related services
• Manage client and contractual relationships
• Comply with legal and regulatory obligations
• Maintain internal records and business operations

6. LEGAL COMPLIANCE

SpecCon Holdings maintains records in accordance with applicable South African legislation, including PAIA, POPIA, the Companies Act, Labour legislation, and tax laws.

7. ACCESS TO INFORMATION

Requests for access to records must be made in terms of PAIA. The South African Human Rights Commission provides guidance on this process (www.sahrc.org.za).

8. INFORMATION SECURITY

We take reasonable technical and organisational measures to protect personal information against loss, misuse, or unauthorised access.

9. DISCLOSURE OF INFORMATION

Information may be shared where required by law or with authorised third parties in the normal course of business, subject to confidentiality and data protection requirements.

10. DATA SUBJECT RIGHTS

Individuals have the right to request access to, correction, or deletion of their personal information, subject to applicable legal limitations.

11. LEGISLATIVE RECORDS

SpecCon Holdings also keeps record as stipulated in (Section 51(1)(d) of the act) in accordance with the following legislation:

• Basic Conditions of Employment Act, No. 75 of 1997
• Broad-Based Black Economic Empowerment Act, No. 53 of 2003
• Companies Act, No. 71 of 2008
• Compensation for Occupational Injuries and Diseases Act, No. 130 of 1993
• Constitution of the Republic of South Africa, No. 108 of 1996
• Copyright Act, No. 98 of 1978
• Electronic Communications and Transactions Act, No. 25 of 2002
• Employment Equity Act, No. 55 of 1998
• Income Tax Act, No. 58 of 1962
• Labour Relations Act, No. 66 of 1995
• Occupational Health and Safety Act, No. 85 of 1993
• Promotion of Access to Information Act, No. 2 of 2000
• Promotion of Equality and Prevention of Unfair Discrimination Act, No. 4 of 2000
• Protected Disclosures Act, No. 26 of 2000
• Skills Development Act, No. 97 of 1998
• Skills Development Levies Act, No. 9 of 1999
• Unemployment Insurance Act, No. 63 of 2001
• Unemployment Insurance Contributions Act, No. 4 of 2002
• Value-Added Tax Act, No. 89 of 1991

12. RECORD SHIELD

In terms of legislation Section 51(1)(e) description of the subjects on which SpecCon Holdings (Pty) Ltd holds records and the categories of records held on each subject.

• Client Service Records

  Includes client service records and Service Level Agreements (SLAs).

• Company Secretarial Records

  Share registers and shareholder agreements. Other statutory company documentation.

• Corporate Governance Records

  Code of Conduct. Internal policies and governance frameworks.

• Finance and Administrative Records

  Invoices, financial documents, and agreements. General administrative documentation.

• Human Resource Records

  Payroll information. Leave records and employee-related data.

• Learner Data

  Learner qualification, SETA Certificates, ID and Bank Details as per SETA Requirements. POE file for up to 5 years.

• Information Technology Records

  Equipment registers. Website traffic and IT system data.

• Learning and Development Records

  Training materials and guides. Training records and performance statistics.

• Operations Records

  Biometric access records. PABX (telephony) management data. Insurance, liability, and travel-related documents.

• Marketing and Communication Records

  Branding development materials. Client communication and relationship management. Communication strategies.

• Sales Records

  Sales proposals. Quotations and related sales documentation.