Core Knowledge Training and Consultancy (Pty) Ltd processes learners' personal information in South Africa and for learners in Botswana. This policy sets out the standards we follow under the Protection of Personal Information Act 4 of 2013 (POPIA) and the Data Protection Act, 2024 of Botswana. It supports our Privacy Policy.
1. Laws that apply
- 1.1POPIA applies because we are a South African company. The Botswana Data Protection Act 2024 applies to the personal information of learners in Botswana, whose classroom runs at moodle.coreknowledge.co.bw. Where the two differ we apply the stricter standard.
- 1.2Responsible party / data controller: Core Knowledge Training and Consultancy (Pty) Ltd. Information Officer: George Mureithi, coreknowledgedigital@gmail.com.
2. The conditions for lawful processing (POPIA)
- 2.1Accountability: we are responsible for compliance and have appointed an Information Officer.
- 2.2Processing limitation: we collect only what is needed, lawfully, and directly from you where possible.
- 2.3Purpose specification: we collect for stated purposes (see the Privacy Policy) and keep records only as long as the retention schedule allows.
- 2.4Further processing limitation: we do not use information in ways incompatible with the original purpose.
- 2.5Information quality: we keep information accurate and let you correct it.
- 2.6Openness: we explain what we collect and why, and keep our PAIA manual available.
- 2.7Security safeguards: we apply the measures in our Information Security Standard and follow our Data Breach Response procedure.
- 2.8Data subject participation: you may access, correct and delete your information (clause 4).
3. Botswana Data Protection Act 2024
- 3.1For learners in Botswana we process personal data fairly, lawfully and for specified purposes, minimise it, keep it accurate and secure, and keep it no longer than necessary. We respect the rights of data subjects to access, correct, object and request erasure, and we notify the regulator and affected persons of serious breaches as the Act requires.
- 3.2We will register with, or notify, the Botswana Information and Data Protection Commission where the Act requires it, and will follow the Commission's guidance on cross-border transfers.
4. Data subject requests
- 4.1Send requests (access, correction, deletion, objection, restriction, portability where applicable) to coreknowledgedigital@gmail.com with the subject "Data request".
- 4.2We confirm your identity, record the request, and respond within thirty (30) days. If we need more time or must refuse part of a request, we tell you why and how to complain.
- 4.3There is no charge for ordinary requests; a reasonable fee may apply to repeated or manifestly excessive requests, as the law allows.
5. Operators and processors
- 5.1Anyone who processes information for us is bound by written terms to process it only on our instructions, keep it confidential and secure, and tell us promptly of any compromise. Our operators currently include Contabo (hosting, Germany) and Google (email and analytics), and a payment provider once billing opens.
6. Cross-border transfers
- 6.1Our classroom data is hosted in Germany. We transfer information across borders only where the recipient is bound by law, binding rules or an agreement that gives substantially similar protection (POPIA s72; equivalent rules in Botswana), or with your consent, or where it is needed to perform your contract. We review these arrangements at least once a year.
7. Governance
- 7.1Staff with access to learner data receive instruction on this policy. We review this policy at least annually and after any serious incident.