Privacy Policy
PURPOSE AND SCOPE
Moore South Africa (Pty) Ltd (“Moore SA”) comprises a network of member firms, companies and practitioners that provide accounting, audit, tax, advisory and other professional services throughout South Africa. A list of member firms can be requested by using the contact details provided in this policy.
The member firms form part of an international network offering similar services. Moore Global Network Limited, based in the United Kingdom, and each member of the global network, is a separate and distinct legal entity with no authority to bind or obligate any other member.
This privacy policy relates to Moore SA and each separate member firm in South Africa. Each entity is responsible for its own privacy-related obligations. References to “we”, “us”, “our” or “the firm” refer to the relevant individual member firm or Moore SA, depending on the context.
This policy explains how and why we collect and process personal information. Due to the nature of our business, we routinely handle the personal information of clients, prospective clients and other individuals who interact with us. Any such person is referred to as a “data subject”.
We may collect and process personal information for any legitimate purpose, including offering sound and professional services, maintaining and developing our business, safeguarding our operations and protecting our legitimate interests (collectively, the “Moore Purpose”). We commit to processing personal information lawfully and in a reasonable manner in accordance with the Protection of Personal Information Act 4 of 2013.
THE DATA SUBJECT’S CONSENT
We may collect, process, disclose, store or otherwise handle personal information as set out in this policy or as required to fulfil the Moore Purpose.
If you have concerns about how your personal information may be treated, please refrain from engaging with us or from using our websites or services.
Where permitted or required by law, we may process personal information without the data subject’s knowledge or permission, provided that sufficient grounds of justification exist and we act in accordance with this policy.
WHY WE COLLECT PERSONAL INFORMATION
Personal information refers to information relating to an identifiable, living natural person or, where applicable, an identifiable juristic person. The type of information collected depends on the data subject’s relationship or interaction with us.
We may process identity information, contact information, financial information, employment records, and education or qualification records.
In general, we collect and process personal information for any legitimate purpose connected to the Moore Purpose. This includes performing requested services, undertaking related activities, carrying out background and know-your-client checks (as required by law or industry practice), conducting conflict checks, recruiting staff, managing employment-related processes and undertaking marketing activities.
Although the provision of personal information is voluntary, we reserve the right to decline to transact with any person who fails to provide information we request and deem necessary. The same applies where consent is withdrawn or where a data subject objects to processing.
In certain circumstances, we are legally obligated to collect and process personal information, including under the Financial Intelligence Centre Act of 2002 and laws related to Anti-Money Laundering, Counter-Terrorism Financing and Counter-Proliferation Financing.
HOW WE COLLECT PERSONAL INFORMATION
Personal information is usually collected directly or indirectly from a data subject or their representatives. Collection may occur through electronic communications, meetings, telephone calls and general interactions. All electronic communications are subject to our Moore SA Disclaimer.
We may gather information from a data subject’s website, social media profiles and other public platforms. We may also collect information from third parties such as employers, recruiters, background-check providers and public sources. These checks may include identity, criminal record, credit history, employment history, academic qualifications and integrity assessments.
We assume that all personal information supplied to us is provided lawfully and accept no liability where information was supplied to us in contravention of any law.
We may act as an operator on behalf of responsible parties, such as when performing outsourced payroll services. It is the responsibility of the party providing the information to ensure that it is supplied lawfully.
We may monitor activity on our IT systems and website, collecting information about users and their interactions to fulfil the Moore Purpose. Cookies may also be used. The Moore SA Cookie Policy is available separately.
SAFEGUARDS AND STORAGE
Personal information may be stored physically or electronically, including in cloud-based systems. Our servers may be located around the world.
We take reasonable and appropriate measures to secure personal information but cannot guarantee absolute security.
We retain personal information for as long as necessary to maintain our relationship or contact with the data subject and for any additional period permitted or required by law. This enables us to maintain updated records, follow good record-keeping practices and comply with legal retention requirements.
DISCLOSURE OF INFORMATION
To carry out the Moore Purpose, our owners, managers, employees and consultants may need to review, verify, discuss, maintain and store personal information.
We may disclose personal information to third-party contractors, subcontractors, affiliates and service providers, including providers of IT services, recruitment platforms, website management, data backup, security and cloud services.
Where required by law, personal information may be disclosed to governmental authorities or regulatory bodies.
TRANS-BORDER INFORMATION FLOW
Personal information may be transferred to and stored in countries outside South Africa, including countries without specific data-protection laws.
We may disclose information to Moore Global Network Limited or members of the global Moore network for conflict and background checks.
In general, we will not transfer personal information to another country unless the data subject consents, the transfer is necessary for contractual purposes, the foreign country offers adequate protection, an agreement ensures adequate protection, or binding corporate rules apply.
DATA SUBJECT RIGHTS
We take reasonable measures to record personal information accurately and ensure it is complete and not misleading.
Data subjects have the right to access their information and to request correction, reduction or deletion, subject to reasonable limitations. Requests must be made in writing to the relevant information officer.
Data subjects may withdraw consent, request details of personal information held, request corrections or deletions, object to processing under certain conditions, object to direct marketing, be notified of security breaches and lodge complaints with the Information Regulator.
Information Regulator contact details:
JD House, 27 Stiemens Street, Braamfontein, Johannesburg 2001
PO Box 31533, Braamfontein 2017
Tel: 010 023 5207
Email: [email protected]
QUERIES
Each firm appoints its own information officer, responsible only for that firm. Contact details for each information officer can be obtained from Moore SA at [email protected].
REVISION HISTORY
We may update this policy at any time by publishing the latest version on our website. Changes will be reflected in the revision date. We encourage regular review.
Version — Revision Date — Effective Date
V1 — June 2021 — 30 June 2021
V2 — November 2023 — 10 November 2023