POPIA Compliance

Your privacy matters to us. Learn how Sleepwise CPT (Pty) Ltd protects and manages your personal information in compliance with the Protection of Personal Information Act (POPIA).

Maintaining Trust & Compliance

Introduction

In this document, references to "the business", "we", "us", or "the Group" are to Sleepwise CPT (Pty) Ltd and its subsidiary companies.

We recognise our accountability in terms of the Protection of Personal Information Act (POPIA), to all our clients, suppliers, service providers and other third parties when processing their personal information.

To maintain a trust relationship with our Stakeholders, we are committed to complying with both the spirit and the letter of POPIA, other privacy protection legislation, and to always act with due skill, care, and diligence when dealing with personal information.

Important: We will only process your personal information for purposes set out below and we will therefore only request information that is relevant and necessary for such processing. Your failure/refusal to provide this information could prevent or cause a delay in the fulfillment of our obligations to you.

What is Personal Information

Personal Information according to POPIA, means information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, including, but not limited to:

  • a Information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language, and birth of the person
  • b Information relating to the education or the medical, financial, criminal, or employment history of the person
  • c Any identifying number, symbol, e-mail address, telephone number, location information, online identifier, or other particular assignment to the person
  • d The biometric information of the person
  • e The personal opinions, views, or preferences of the person
  • f Correspondence sent by the person that would reveal the contents of the original correspondence
  • g The views or opinions of another individual about the person
  • h The name of the person if it appears with other personal information relating to the person or if the disclosure of the name itself would reveal information about the person

Where and When We Collect Personal Information

1

Patients

  • Directly from patient
  • Directly from referring doctor
  • Referral document from Doctor
  • JOT Forms completed by patient
  • Invoicing
2

Suppliers

  • Invoices
  • Directly from supplier

When We Process Your Personal Information

We will only process your personal information for lawful purposes relating to our business if the following circumstances apply:

You have consented thereto
A person legally authorised by you, or a court, has consented thereto
It is necessary to conclude or perform under a contract we have with you
The law requires or permits it
It is required to protect or pursue your, our, or a third party's legitimate interest
You are a child, and a competent person (such as a parent or guardian) has consented thereto on your behalf

Special Personal Information

Special personal information refers to the following categories of information:

  • Religious and philosophical beliefs
  • Race
  • Ethnic origin
  • Trade union membership
  • Political beliefs
  • Health including physical or mental health, disability, and medical history
  • Biometric information
  • Criminal behaviour where it relates to the alleged commission of any offence or the proceedings relating to that offence
When We Process Special Personal Information

We will process special personal information only when you have consented to the processing, it is necessary to exercise or defend a right or obligation in law, or for other legally permitted purposes that would not adversely affect your privacy.

What Information We Collect

PATIENTS

PURPOSE:
  • Contact patient for sleep study
  • JOT Forms to Medical Aid + Doctors
  • Spreadsheet (manually kept)
DATA ELEMENTS:
  • Name and Surname
  • ID Number
  • Contact Details (address, phone, email)
  • Medical Aid Details
  • Health Information for sleep study

SERVICE PROVIDERS / SUPPLIERS

PURPOSE:
  • To receive goods/services
  • To contact Supplier
  • Audit & Record keeping
DATA ELEMENTS:
  • Information on supplier invoices
  • Bank details
  • Name and contact details

How We Share Your Information

Third-Party Service Providers

  • Regulatory bodies
  • Law enforcement agents
  • Government agencies
  • IT Service Provider
  • Accountant / Auditors
  • Medical Practitioners
  • Medical Aid
Legal Disclosures

We may need to share your information when we believe it is required by law, legal process or to help protect the rights and safety of you, us, or others. We attempt to notify members about legal demands for their data when appropriate in our judgment unless prohibited by law or court order or when the request is an emergency.

We may dispute such demands when we believe, at our discretion, that the requests are overbroad, vague, or lack proper authority, but we do not promise to challenge every demand.

Your Rights and Obligations

Data Retention

We keep most of your personal information while we still have a purpose, we need to provide you with services or where we are legally obligated to do so. We will also keep your information where you have agreed for us to do so, or have given your consent that we are allowed to do so.

We keep some of your information even after our business relationship has terminated, if it is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our other user agreements, or fulfill your request to object to our processing of your information.

You have rights in connection with your personal information. You have many choices about how your information is collected, used, and shared. In certain circumstances, by law, you have the right to:

Request Access to Your Information

You will be able to ask us what information we have about you as well as ask for a copy of this information. This should be done on request to sleepwize.cpap@gmail.com. There are some exemptions, which means you may not always receive all the information we process. When we can give you a copy it might be done at a certain fee, which will also be communicated to you at the time of your query.

Change or Correct Information

You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Delete Information

You can ask us to delete or remove personal information under certain circumstances.

Object to Processing

You can do this where we are relying on your legitimate interest, public interest, or our legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your data for direct marketing purposes.

Request Restriction of Processing

You can ask us to suspend the processing of personal data about you, for example, if you want us to establish its accuracy or the reason for processing it.

Withdraw Consent

Where you have given your consent for specific processing and you want to retract your consent. Retracting your consent does not invalidate the information we lawfully processed while we had your consent to do so.

Other Important Information

🔒 Security

We have put in place appropriate security measures to prevent your data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal information on a business need-to-know basis, and subject to a duty of confidentiality.

🌍 Transborder Information Transfers

We do not share any of our patients, suppliers, service providers and other third parties' information across borders.

📝 Changes to Our Privacy Notice

Changes to the privacy notice apply to your use of our services. We may modify this privacy notice from time to time, as required by changes in legislation. When material changes are made, we will provide notice through our services, or by other means, to provide you the opportunity to review the changes before they become effective.

You acknowledge that your continued use of our services after we publish our changes to this privacy notice means that the collection, use, and sharing of your personal information is subject to the updated privacy notice.

Contact Information

For any queries regarding your personal information or this privacy policy

Information Officer

Anna-Marie Holder

sleepwize.cpap@gmail.com

Deputy Information Officer

Mariska Holder

sleepdepartmentcpt@gmail.com

Information Regulator

Lodge a Complaint

POPIAComplaints@inforegulator.org.za

JD House, 27 Stiemens Street
Braamfontein, Johannesburg, 2001

General Queries:
enquiries@inforegulator.org.za

PAIA Complaints:
PAIAComplaints@inforegulator.org.za

Download Policy Document

Download our complete POPIA compliance policy document for your records

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POPIA Compliance Policy

Complete policy document detailing our privacy practices and compliance measures in accordance with the Protection of Personal Information Act