Privacy Policy

Online Privacy & Data Protection Policy for Lebotha Consulting (Pty) Ltd

POPIA Compliant

Last Updated: 1 September 2025

Table of Contents
Section 1

Online Data Collection & POPIA Status

1.1. Statutory Alignment

This policy satisfies the mandatory digital disclosure requirements of the South African Protection of Personal Information Act No. 4 of 2013 ("POPIA").

1.2. Our Digital Role

When you input, type, or upload employee matrices into our portal for EEA2, EEA4, EEA12, or EEA13 execution, you remain the Responsible Party, and Lebotha Consulting acts strictly as the digital Operator. We process this information solely to power your analytical dashboard.

POPIA Notice: Under POPIA, you are the Responsible Party for employee data you upload. Lebotha Consulting processes this data strictly as an Operator on your behalf.
Section 2

Personal & Special Data Captured Online

By using this web portal, you actively consent to the digital collection and processing of the following categories of data:

Workforce Demographic Data

Race, gender, ethnic origin, and disability metrics uploaded via your portal spreadsheets.

Sensitive Financial Data

Remuneration tallies, basic salaries, variable bonuses, and individual package structures required for EEA4 inequality metrics.

Digital Footprint Data

IP addresses, login timestamps, browser types, and session tracking metrics captured securely via operational web cookies.

Special Personal Information: Under POPIA, race, gender, ethnic origin, and disability data constitute "special personal information" and receive enhanced protection under our security framework.
Section 3

Cloud Infrastructure & Cyber Security

3.1. Encryption Frameworks

All files uploaded to our portal are processed using secure HTTPS protocols and are stored using AES 256-bit encryption standards at rest.

3.2. Hosting Environment

Our web applications are hosted within secure, firewalled data center environments that maintain global compliance certifications (such as ISO 27001).

3.3. Zero Third-Party Sharing

Lebotha Consulting will never sell, lease, or distribute your corporate payroll structures or demographic breakdowns to any third-party marketing networks.

HTTPS Encryption AES 256-bit at Rest ISO 27001 Hosting Zero Data Sharing
Security Commitment: Your data is protected by enterprise-grade encryption both in transit (HTTPS) and at rest (AES 256-bit) within ISO 27001 certified data centers.
Section 4

Automated Account Deletion & Data Retention

4.1. Retention Windows

Following the successful close of the annual DEL online submission window, you may request the manual purging of your raw data files from our dashboard.

4.2. De-identification

Deactivated accounts will have their underlying data permanently de-identified, leaving only aggregated, anonymous macro-trends for system performance evaluation.

  • ▸ Manual Purging: Request deletion of raw data after DEL submission window closes
  • ▸ De-identification: Account deactivation permanently removes personally identifiable information
  • ▸ Anonymous Retention: Only aggregated macro-trends retained for system evaluation
Section 5

Digital Consent & Information Officer

By checking the privacy confirmation box on our portal, you affirm that your organization has secured the necessary internal permissions from your employees to upload their demographics and income details to our system.

Consent Confirmation: You confirm that your organization has obtained all necessary employee consents for data upload and processing in compliance with POPIA.

Contact Our Information Officer

To submit data access or correction requests, please contact our Information Officer at:

Information Officer

popia@lebotha.co.za

0800 123 456

Pretoria, South Africa

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