Data Protection Policy

The privacy policy of the Alliance Française of Johannesburg
Protection of Personal Information Act 4 of 2013

Website Privacy statement

Your privacy is important.How we process your personal information is explained in this statement. By visiting and remaining on our website you agree to our terms and conditions. If you do not agree to our terms and conditions, please leave our website now.

Information collection
Our service provider gathers information about your use of our website to improve and monitor the website. Our service provider uses advanced technology (cookies) to gather information about your operating system, browser version, domain name, IP address and frequency of landing on our home page. Your IP address tells us which server you use but does not identify you personally. You may disable the collection of cookies on your browser and you may browse the internet and our website incognito. It is a function easy to engage on your browser.

Categories of information we collect and process
If you register for our courses we collect the following categories of personal information:
Your name;
Your email address;
Your telephone number; (we prefer cellphone numbers to landline numbers); and,
Information listed in our applications for membership or course attendance.

We use your personal information to administer our class schedules and to allocate students to the appropriate level of tuition. Each class can accommodate a limited number of students for optimal learning. You are not obliged to supply any personal information that you want to keep private. If you subscribe to our courses and you do not wish to provide either your telephone number or email address, communication with you will be restricted to your preferred method. However, if you do not provide a method to communicate with you, we will not be able to process your application for our courses. Only with regard to children, do we request the date of birth so that we can group children into age appropriate courses. All personal information you give us depends on you consenting to give us that information.
Even after you have given us any personal information, you may request us to remove your personal information from our data base.

Unless you are a service provider to the Alliance française, we do not request your bank details. If you consent to giving us your bank details, we shall retain those details only for so long as is necessary to carry out the purpose for which you provided us the details. We do not collect personal information about you from other sources. If you have concerns about the personal information we request in our application forms, you may address these concerns to the responsible party of the Alliance. The details of the responsible party are set out at the end of this policy.

Information security
We keep your personal information on our secure servers at the Alliance. However, when you browse the Alliance française network, and you upload any personal information for the DELF, DALF and TEF courses, our provider for TEF is based in Canada and for the DELF and DALF in France. The Alliance also uses a learning management system, Arc-en-Ciel. The server for Arc-en-Ciel is based in France.

Canada has legislation similar to the Protection of Personal Information Act 4 of 2013 (“POPIA”). In Canada it is called the Personal Information Protection and Electronic Documents Act (“PIPEDA”. We are satisfied that our provider in Canada is secure. France is subject to the European Union legislation referred to as the General Data Protection Regulation (“GDPR”). Personal information under the GDPR is called personal data. We are satisfied that our providers in France are secure.

Our systems are not invulnerable to Zero Day attacks. (A Zero Day attack means the first type of attack of its kind.) So, we cannot guarantee that any personal information you communicate to us will be absolutely secure. However, we take all precautions reasonably available to protect your personal information.

Among the many things we do to secure your personal information we use the following essential protocols:
All our computers are updated regularly;
We employ firewalls and up-to-date anti-virus protection;
Our staff do not open links and documents from unsolicited emails;
So, if you are making contact with us for the first time, please do not send us PDF documents or open links in your emails.

If we suffer a breach of your personal information (by some form of hacking), we will immediately inform the Information Regulator of the breach. We will also let you know immediately the nature and extent of that breach, unless the Regulator requires us to wait for the completion of investigations into the breach. And, of course, to the best of our ability, we will close the attack vector immediately.

Retention of personal information
We keep your personal information for as long as you allow us to keep your information or the law requires us to keep your information. We prefer the shorter period.
So, if you request us to delete your personal information from our data base, we will do so immediately. However, if you do not request us to delete your personal information, we will keep your information for three years after your last contact with the Alliance française network or as stipulated by the statutory requirements below.

We base the three year limit on two statutes (Acts of Parliament) in South Africa:
• Prescription Act 68 of 1969 which has a three year prescription for debts; and,
• Basic Conditions of Employment Act 95 of 1997 which requires us to keep employment records for three years after any former employee has left our employ.

General policy concerning the use of personal information
The Alliance respects your privacy. The Alliance is committed to respect your privacy in accord with POPIA and will strive to apply the protections accorded personal information in both the GDPR and PIPEDA, mentioned above. The Alliance uses your personal information for two main purposes.

• First, to enter your details into the classes you attend at the Alliance. Our teachers need that information to conduct the classes.
• Second, we use your personal information to keep in touch with you via emails, SMSs and social media, on condition you consent to these communications.

The Alliance has an unsubscribe function on its emails in the event you no longer wish to receive our newsletter and other email communications. When you complete the applications for DELF, DALF or TEF, you will be interacting with servers based in France and Canada.

Information security and quality
The Alliance will protect the quality and integrity of your personal information at all times. You are also entitled to know what personal information the Alliance keeps about you. To request access to your personal information and to assist the Alliance to correct inaccuracies in your personal information please send an email to the Information Officer.
The details of the Information Officer are set out at the end of this policy.

Sharing of information
We will not share your personal information with any Alliance in our network.

CCTV
The Alliance has CCTV protection on its premises. The footage is kept by our service provider in terms of a written contract between the Alliance and the provider.

Clickstream data
The Alliance collects anonymous information from visitors to its website. The Alliance keeps track of the domains from which people visit its website, measures visitor activity on its website and, in particular, what interests visitors to our website the most.

Children
The Alliance’s website is not directed towards children. However, at times there are events and programmes aimed at children. The Alliance is committed to comply with all applicable laws aimed at the protection of children and in particular the protection of their personal information.

Questions and complaints
Q&Cs regarding this Privacy Statement may be sent to the head (Information Officer) of the Alliance. For the details, see below.

If you are unhappy with the way in which we address your questions and complaints, you also have the right to refer a complaint to the Information Regulator at:

4th Floor, JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
P.O Box 31533, Braamfontein, Johannesburg, 2017

Complaints email: complaints.IR@justice.gov.za
General enquiries email: inforeg@justice.gov.za

The Information Officer of the Alliance Française of Johannesburg is the head of the Alliance.
E- Mail address of head of the Alliance Française of Johannesburg:
director@jhb.alliance.org.za

The responsible party of the Alliance Française of Johannesburg is a sub-committee.
The email address of the responsible party is:
facilitymanager@jhb.alliance.org.za