South Africa Privacy Centre

Introduction
 

This privacy notice provides a high-level overview of how we use and share personal information across TransUnion. You can find more detailed information at the TransUnion Privacy Centre or in other privacy information you may have received.

In this Privacy Notice, any reference to TransUnion includes any of the entities listed below:

1.  TransUnion Africa Holdings (Pty) Ltd, 2012/035271/07

2.  TransUnion Africa (Pty) Ltd, 1992/007124/07

3.  TransUnion Analytic and Decision Services (Pty) Ltd, 1992/000475/07

4.  TransUnion Auto Information Solutions (Pty) Ltd, 2000/018558/07

5.  TransUnion Credit Bureau (Pty) Ltd, 2004/007773/07

In Brief

TransUnion strives to protect privacy as we collect, use, process, disclose, transfer and retain personal information.

If your personal information is used unlawfully or infringes on your privacy, you have the right to object.

This notice covers the following topics:

1. Who we are and how to contact us
2. How we use personal information
3. Where we get personal information
4. How long we keep personal information
5. Our legal basis for handling personal information
6. Who we share personal information with
7. Where we store and send personal information
8. How the personal information is used
9. Your rights concerning your personal information
10. Where to lodge a complaint
     

1.  Who we are and how to contact us
 

Information for Good^®
 

We are in an era of rapid digital transformation where consumers demand more access to seamless, personalised products and services online. But the currency of personal information that fuels this platform economic boom poses threats to individuals and endangers corporate security.

Now more than ever — and likely more so in the future — consumers and corporates need new levels of trust and transparency.

As a global information and insights company, TransUnion seeks to make trust possible. We do this by curating an accurate and comprehensive picture of each consumer so they are safely and reliably represented in the marketplace. This enables businesses and consumers to transact with confidence and achieve great things. We call this Information for Good.

We are a group of companies with registered offices at TransUnion, 10th Floor, 11 Alice Lane, Sandton, Johannesburg, 2196.  Although we are part of a larger group, this notice covers only the activities of TransUnion companies within the Republic of South Africa.

Contact details

Contact us about personal information issues, including the contents of this notice via:

• Post: PO Box 4522 Johannesburg 2000
• Telephone:   Contact Centre: 0861 482 482
• Email: TUAPrivacy@transunion.com

Please refer to our Customer Service Privacy Notice for information on how we handle your personal information with complaints and enquiries.
 

2.  How we use personal information
 

TransUnion limits the use and disclosure of personal information to the terms of the National Credit Act 34 of 2005 (NCA), Protection of Personal Information Act 4 of 2013 (POPIA) or any other applicable laws.

Unless we have your consent or the law permits us, we will not sell, rent or lease your personal information to others. We will not use or share your personal information in ways unrelated to the circumstances described below.

Unless permitted by the laws or with your consent, we do not use any personal information concerning religious or philosophical beliefs, race or ethnic origin, trade union membership, political persuasion, health, sex life or biometric data.
 

Products and services

Many of our products and services rely on personal information. For example:

Credit reporting: TransUnion compiles consumer credit information in credit reports from applications to (for example) credit providers or services providers for credit or services.

Direct marketing: When you visit a TransUnion Site, we may invite you to sign up for information, promotional offers and marketing.

You can sign up for our news during the online ordering process by ticking the opt-in box, "I want to receive news and information on products to help me manage my debt better."

If you consent, TransUnion will access, use, process and analyse your personal information, your consumer credit information, Internet activity and marketing data to provide personalised offers from TransUnion.

Digital marketing: To provide relevant products and services to consumers, we enable business partners to use our data and technology to create, deploy and measure targeted digital advertising programs.

Advertising: We may use domestic or overseas third-party advertising companies to serve ads on TransUnion Site or on other sites which we use for advertising. We may also use third-party analytical tools to personalise advertisements and enhance the visitor experience.

Market research: Participation in market research activities is optional. When you opt-in, we use your information to improve the experience of our products and services. Third parties assisting with market research can keep non-personal aggregated data for our research purposes.

Business products: We may use personal information to promote and market relevant products, services and special offers from us and our affiliates.

Customer service: We may use personal information to identify customers, process transactions and provide quality service.

Recruitment: We use personal information when we receive an employment application.

Business operations
 

We may use personal information for our internal operations, such as:

Names, contact details and other information from consumers who contact us to deal with their enquiries. See our Customer Service Privacy Notice for more.

Employee information (including employment and educational history, background checks and performance appraisals) to manage our relationship.

CCTV cameras in public areas of our business premises for the safety of staff and visitors, and the security of our information and assets.

Biometric information to manage access to our business premises, in order to ensure the safety of staff and visitors, and the security of our information and assets.

Legal and regulatory purposes, such as responding to complaints or enquiries about how we have used personal information.

In addition, we may aggregate anonymised data to provide advertising performance analytics to business partners.

For more details on the kinds of data used for each purpose described, visit the TransUnion Privacy Centre to view our other privacy notices.

For more on our use of cookies, see our Cookie Policy.
 

3.  Where we get personal information
 

We get personal information directly from our business partners, suppliers, clients, site visitors, and product and services customers signing up for any of our products or services.

For more details on where we get personal information, visit the TransUnion Privacy Centre to view our other privacy notices.
 

4.  How long we keep personal information
 

Simply put, we keep personal information for as long as necessary. More technically, we retain it to fulfil the purpose(s) of its provision, to comply with applicable laws, and for as long as your consent to such purpose(s) remains valid after termination of our relationship.

5.  Our legal basis for handling personal information
 

Legitimate interests

The Protection of Personal Information Act (POPIA) allows personal information usage where necessary for legitimate purposes without undue adverse impact. We base most of our processing activities on the 'legitimate interests' condition. For more details, refer to the relevant privacy notices in the links above.
 

Consent

We sometimes rely on consent to process personal information, but this is relatively rare. Refer to the relevant privacy notices at https://www.transunion.co.za/legal/privacy-policy for more details.
 

Contracts

If you sign up for one of our online services, we need to use personal information to provide the services as set out in the Terms & Conditions. We also use this basis for processing some of our staff data. Refer to the privacy notice on the relevant website for details.
 

Compliance

We only access, use and disclose personal information without consent in exceptional circumstances where necessary to:

• Comply with the law or a legal process served on us
• Comply with requests for information from police or government authorities
• Protect and defend our rights or property (including the enforcement of agreements)
• Protect the public interest
• Act in urgent circumstances to protect the personal safety of our employees or members of the public
• Act on implied consent

We apply the above in terms of the NCA, POPIA and other relevant national legislation.
 

6.  Who we share personal information with
 

Our clients and resale partners
 

We share personal information with our clients for the purposes described above. Our clients have privacy notices providing details on how they use the data we supply.

These clients typically operate in the following sectors:

• Financial services (including banks, loans, credit cards, mortgages, pensions, and investments and savings providers)
• Insurance
• Retail (including car sales/leasing and online retailers)
• Telecommunications
• Marketing agencies acting for other organisations
• Auto dealers
• Commercial
• Collections

If our clients appoint an intermediary to act on their behalf, they too will receive the data.

Our group of companies
 

As stated, we share personal information among TransUnion RSA companies where appropriate. We have set out a list of current such companies below.

Service providers
 

Information may be shared by us and our clients to third parties that help us achieve the purposes described above. For example:

• Cloud-based services, such as Salesforce, help host, manage and analyse our databases.
• Cloud-based technologies, such as Microsoft Office 365, support our ordinary business operations.
• Printing companies to produce and send direct mail or other correspondence.
• Payment service providers to help with payments made by individuals.
• Market research companies to help us better understand our customers.
• A specialist sub-contractor operates our CCTV system.
• Services Providers that assist us with providing our services to you.

These service providers cannot use your information for their purposes or on behalf of other organisations unless you agree otherwise.

7.  Where we store and send personal information
 

We sometimes make use of Service Providers that are situated outside of South Africa, e.g. India, UK and US.  We will not transfer personal information to a country lacking laws that provide an adequate level of information protection — unless we have an agreement with the recipient requiring measures that offer a similar level of protection as POPIA in South Africa.
 

8.  How the personal information is used
 

We provide data and analytics that help our clients make decisions about lending and other matters, but their data, knowledge, processes and practices play a significant role in those decisions.

For example, when we sell our services to credit or loan providers, we do not decide whether they should grant you credit or a loan — this is for the lender to decide.
 

9.  Your rights concerning personal information
 

We outline your rights regarding the personal information we hold about you below.

Access: You can access all information that we hold about you by contacting us through TUAPrivacy@transunion.com

Correction/Destruction/Deletion: If the information we hold about you is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully, you have a right to ask us to correct it or delete it.

Objection to processing: You may object (on reasonable grounds) to processing your personal information unless legislation provides for such processing.

Objection to direct marketing: You may object to us using your personal information for direct marketing, and if you do, we will stop.

10.      Where to lodge a complaint
 

We strive to deliver the highest levels of customer service. However, if you are ever unhappy with us, please contact us so we can investigate.

• Location: 10^th Floor, 11 Alice Lane, Sandton, 2196
• Postal Address: PO Box 4522, Johannesburg, 2000
• Telephone: 0861 482 482

You can also contact our Information Officer or Deputy Information Officer at TUAPrivacy@transunion.com

You may complain to the Information Regulator:

• Physical Address: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg
• Postal Address: P.O. Box 31533, Braamfontein, Johannesburg, 2017
• Email: POPIAComplaints@inforegulator.org.za.
• Site: www.inforegulator.org.za