This privacy note articulates the parameters in the collection, processing, storage, distribution, and destruction of personal information by Wise Eye Reading Academy CC and Wise Eye Reading Academy International (PTY) Ltd (hereafter referred to as Wise Eye) as aligned to the POPI Act, No 4 of 2013. It provides what must and must not be done with your collected personal information that Wise Eye becomes privy to. This privacy note must be adhered to by all key individuals, including prospective Principal Members/Agents/Wise Eye reading therapists, parents/guardians and service providers where applicable.
Wise Eye is a reading programme with products from 6 months to adults. Wise Eye Head Office is based in Pretoria, South Africa. Wise Eye currently has more than 60 Principal Members national and international in countries like Mauritius, Namibia, and Zambia.
The structure works through a system of Memorandum of Agreements between the Business Holder (Wise Eye) and the Principal Member or Agent to open a Wise Eye reading centre in a specific area.
Wise Eye Reading Academy has personal information about you because you have expressed interest in opening a Wise Eye reading centre, applied to become a Wise Eye therapist, you are a parent or public member asking for information to enrol a child or adult in the programme.
2. Our commitment is to:
Keep personal information about you safe and private;
- Not use personal information for any purpose other than in connection with your expression of interest in opening a Wise Eye reading centre, or parents interested in registering your child/children in one of our Centres, or any other purpose we expressly communicate to you;
- Make it easy for you to approach us if you have any concerns or questions relating to the holding of personal information;
- Not providing personal information to others save where legally required to do so, otherwise specified in this Privacy Notice or otherwise to assist us with our tasks.
3. How information is collected from you
We may collect information from you:
- verbally (whether face to face or by telephone),
- by the completion of paper documents, or
- by electronic means such as through email or interaction with our website.
Please ensure that all personal information is accurately provided as the information which is held is only as accurate as the information provided in the first place.
If any of the personal information provided changes, please notify us as soon as possible to update the personal information.
4. What personal information will Wise Eye collect from you?
If you only make an enquiry about opening a Wise Eye reading centre or becoming a Wise Eye reading therapist working for a centre, we may need no more than basic contact details such that we can provide further information to you. Such details are likely to include your name, address, phone number and email address.
If you apply to open a Wise Eye reading centre or to become a Wise Eye reading therapist working for a centre, in addition to the basic contact details, we will need more detailed information. This is likely to include documentation to prove your identity, such as identity documents, driving license etc.
We may, in some cases, collect vetting and financial information which may not be gained directly from you. This may include police clearance, information about convictions including spent convictions, credit checks and other financial information such as evidence of solvency, Court Judgments and information about other business interests, including directorships.
We will also require information concerning your education and employment history, including a CV and reference checks.
If you open a Wise Eye reading centre, we will retain the information referred to above, and we will gather information relevant to the administration and performance of your centre.
5. To whom will Wise Eye provide personal information?
Wise Eye’s employees have access to the information for the following purposes:
- Statistical purposes and to assist it in refining and further developing (i) Instructor training and (ii) the materials and instruction techniques.
- Monthly statements and invoices (includes all financial obligations).
- Product development.
- Opening new Wise Eye centres.
- Training to become a Principal Member/Agent/Wise Eye reading therapist.
- Buying and selling of Wise Eye products.
- Advising on business systems and therapy procedures.
No personally identifiable data is retained any longer than 60 months following the ending of a Memorandum of Agreement, and the data will only be processed in a statistical manner.
We will ensure that appropriate technical and organisational measures are in place such that this data is shared and stored securely.
6. What about outsourcing by Wise Eye?
Wise Eye may work with other contractors to efficiently and effectively administer and run our business and provide various services. This may include:
- For IT needs including to establish, develop and maintaining relevant databases including the data collection system and to enable effective communication with Wise Eye reading centres/Principal Members/Agents/Wise Eye reading therapists; and,
- For purposes such as record keeping and accounting, printing and training.
- For legal counsel per the Memorandum of Agreement between the Business Holder and the Principal Member or Agent.
In doing so, we may provide your personal information to such contractors. Still, we will take measures to ensure that the contractors handle your personal information securely and do not use your personal information for their own purposes. This might include the transfer of personal information outside of South Africa. If this is the case, we will take security measures to protect the integrity and security of the data.
Wise Eye will not provide personal information for use by anyone else unless:
- We have your specific consent;
- It is necessary for health and safety reasons;
- It is necessary to comply with child protection policies and procedures or otherwise in relation to child welfare and child protection; or,
- It is necessary for complying with any other obligations or duties Wise Eye Reading Academy has under the law.
7. For what will Wise Eye use personal information?
Wise Eye may use personal information for the following purposes:
7.1 To respond to enquiries and applications and to fulfil contractual obligations:
- To respond to enquiries or expressions of interest about opening a Wise Eye reading centre or becoming a Principal Member/Agent/Wise Eye reading therapist;
- To consider applications to open a Wise Eye reading centre. This will include consideration of suitability to open a centre and to work with children and undertaking verification and checks;
- To provide training, help and assistance to Principal Members/Agents/Therapists;
- To administer the Memorandum of Agreement between the Business Holder and the Principal Member or Agent;
- To consider the performance of the centre either individually or to consider the success of Wise Eye as a whole;
- Dealing with other operational issues arising from the Memorandum of Agreement, including disputes and complaints;
- To ensure the quality of the programmes and products provided;
- To direct all parents/guardians enquiries to the relevant Wise Eye centres.
7.2 To ensure vital interests:
In the unlikely event of concerns about your welfare, child welfare or child protection issues, relevant information may be provided to local or public authorities.
7.3 To comply with legal duties
Again, in very rare circumstances, Wise Eye may be required by child welfare or child protection issues to provide information to local or public authorities, including the police.
7.4 When legitimate interests apply
This falls into the following categories:
- This may include work undertaken in refining and improving the effectiveness of the reading programme and improving the student experience for the benefit of yourself, other reading centres and Wise Eye, and may include research and development and using information for education, training and development purposes;
- Communicating news in relation to the Wise Eye operation. This might include communicating details of further career opportunities, including other Wise Eye centres and information about developments at Wise Eye or reading centres which may be of interest or value in operating your Wise Eye reading centre and business; and
- Use your name and/or photograph to help promote your Wise Eye centre, for example, on Wise Eye’s website or your own reading centre page within the website, Facebook and/or Instagram.
Wise Eye will not communicate to you under this heading where there is any perceived detriment in receiving the communication.
If you have any concerns about Wise Eye processing personal information for legitimate interest purposes, please contact Wise Eye using the following email address: firstname.lastname@example.org
7.5 When you consent
There may be occasions when Wise Eye may wish to use personal information but will not do so without your specific consent. Where consent is requested, it will be sought separately.
It is likely to be in areas such as using your name, photograph and details of your reading centre in publicity material for Wise Eye generally (as opposed to your particular reading centre) or in case studies for training purposes.
If consent is given, it can be withdrawn at any time by notifying Wise Eye in writing or by email. This will also apply to all parents/guardians or students who are enrolled in our different Wise Eye reading centres.
8. What happens if you don’t wish to provide personal information to Wise Eye?
It depends upon the nature of the intended use. If, for example, you are enquiring about potentially opening a Wise Eye reading centre, we cannot respond to your request without basic contact information. If you are applying to open a Wise Eye reading centre, we need the information requested to consider that application.
If you are a Principal Member/Agent/Wise Eye reading therapist, we need the categories of information referred to in order to fulfil our obligations under the Memorandum of Agreement and to work effectively with you. Separate considerations apply, as outlined above, if the reason for proposed use comes under the heading of “legitimate interests”. Where consent is required, we will not process personal information without that consent. These consent procedures will also apply to parents/guardians and students.
9. For how long will Wise Eye keep the personal information?
Wise Eye will only retain personal information:
- For as long as necessary to fulfil the purposes it was collected for, as set out in this Privacy Notice;
- Concerning those that enquire or express interest about opening a Wise Eye centre but ultimately don’t, we would not usually keep that information for longer than 24 months after the last communication from you;
- If you are a Principal Member/Agent or Wise Eye reading therapist, we will keep the personal information whilst you remain Principal Member/Agent or Wise Eye reading therapist and then generally for five years after you have ceased to become a Principal Member/Agent or Wise Eye reading therapist. There may be occasions, for example, if there is a dispute or where child protection issues arise, where we may retain the personal information for a more extended period.
- In some circumstances, you have the right to request the erasure of personal information held. This will be addressed below.
- Any personal information related to parents, guardians and students that are no longer required after referral to a Wise Eye centre, hardcopies of such Personal Information will be safely and securely archived for three months. After that, it will safely be destroyed, and all Personal Information held electronically on the Wise Eye’s system will be deleted after 12 months.
- Any personal information related to parents, guardians and students that are no longer required due to the fact that the student or parent is no longer a part of a Wise Eye centre, hardcopies of such Personal Information will be safely and securely archived for a period of 3 months. Thereafter, it will safely be destroyed, and all Personal Information held electronically on the Wise Eye centre’s system will be deleted after 12 months.
10. Your rights concerning the information held about you
- Access – the right to make what is known as a Subject Access Request for a copy of the personal information which we hold about you. If you make such a request, we are required, in most circumstances, to provide a copy of the personal information without charge and within 30 days.
- Correction — it is important that you keep Wise Eye up to date with any changes to the personal information provided. Subject to that, you have the right to ask Wise Eye to correct or complete any inaccurate or incomplete data held about you. Evidence may be required of the new information provided.
- Erasure — you are entitled to ask Wise Eye to delete or remove personal information held where there is no good reason for Wise Eye to continue to keep it. It may not always be possible to comply with your request due to ongoing obligations related to personal information. However, where this is the case, you will be informed and told why it is not possible to comply with the request.
- Objection to processing — you may object to Wise Eye processing personal information. There are some circumstances in which it will not be possible to comply with your request, for example, if it is necessary to process the information in connection with Wise Eye’s obligations, which have been explained to you in this document. If you object to Wise Eye processing information that has been processed for Wise Eye’s legitimate interests, we won’t continue to process it for that purpose without your agreement.
- Restriction of processing — you may ask Wise Eye to suspend the processing of personal information in the following situations:
- If you want the data accuracy to be established;
- Where the use of the personal information is unlawful, but you do not want it to be erased;
- Where you need the data to be held by Wise Eye in case you need it to establish, exercise, or defend legal claims; or
- You have objected to the use of the data by Wise Eye, but Wise Eye needs time to determine whether it has overriding legitimate grounds to process it.
- Request the transfer of information — sometimes rights apply to request a transfer of personal information held to other organisations. This right only applies to personal information processed by automated means and is held either because it was necessary for the performance of the contract with you and/or is processed based upon your specific consent.
11. Keeping personal information safe
Wise Eye has put in place appropriate security measures to prevent personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Access to personal information is limited to those employees and contractors who need to know the personal information in connection with the purposes conveyed to you and will only be processed (i) upon instructions from Wise Eye and (ii) in accordance with procedures put in place to deal with any suspected breach of the requirements under the POPIA. You and/or the POPI Information Officer referred to below will be notified of any potentially significant breach.
12. What happens if you want to complain?
Violations of this Policy and the POPI Act will be dealt with by Wise Eye Head Office first. Then, if it is not resolved within 30 days of reporting the breach, the Principal Member/Agent/Wise Eye reading therapist has the right to forward the violation to the Information Regulator. A data subject who has a complaint against Wise Eye, either concerning its conduct or this Policy, may refer a complaint to the Information Regulator in terms of sections 63(3) and 74 of POPIA.
You have the right to complain to the Information Regulator. You can do this by contacting the Information Regulator’s Office directly. Full contact details, including a helpline number, can be found on the Information Regulator’s website (http://www.justice.gov.za/inforeg/)
- It is not anticipated that any personal information will be transferred outside of Wise Eye, save where expressly set out in this Privacy Notice. We will notify you if this position changes.
- Wise Eye does not anticipate using automated decision-making concerning the personal information provided.
- This Privacy Notice may be updated from time to time. The latest Privacy Notice will be displayed on the Wise Eye Public Website.
13. If you have any questions, who do you ask?
Please contact Wise Eye using the following details:
Wise Eye Reading Academy CC
Office 50, Zambesi Junction Shopping centre, 522 Breed street, Montanapark, 0182
Tel: 012 751 2830 Email: email@example.com
Date: 30 June 2021