Froneman Law
Data Protection and Privacy Policy
Froneman Law is committed to processing personal information honestly, ethically, with
integrity, and always consistent with applicable laws and our values. Failure to proactively
identify, assess, manage, and mitigate privacy risks will lead to a high likelihood of people’s
privacy rights being breached and/or failure to comply with applicable privacy laws (e.g.
Protection of Protection Information Act – “PoPIA”).
To this end, this Data Protection and Privacy Policy regulates the conduct of all directors,
and employees of Froneman Law when they handle personal information.
1 Policy Statement
It is Froneman Law’s policy to protect the privacy and information of all its clients.
2 Purpose and objective of this Policy
2.1 The Purpose and objective of this policy is to:
2.2.1 define Froneman Law’s privacy vision and principles which must be implemented
consistently across Froneman Law to ensure conformance with the applicable
privacy laws (e.g. Protection of Protection Information Act – “PoPIA”).
2.3 This Policy sets out how the Froneman Law uses and protects the Personal
Information (defined below) that it collects, stores, processes, and disseminates from
and to its clients, employees, customers, and business partners.
3 Scope and Application
3.1 This Policy applies to the processing of all Personal Information throughout the
information life cycle, from the point of first collection of Personal Information until the
time that such information is destroyed, deleted, or de-identified.
3.2 This Policy must be adhered to by:
3.2.1 all employees, directors, and other staff of Froneman Law
3.3 Policy Monitoring
3.3.1 The director of Froneman Law is accountable for monitoring and implementation of
the Data Protection and Privacy Policy.
Froneman Law Privacy Vision and Principles
4.1 Froneman Law Privacy Vision: Froneman Law is recognized as a trusted guardian of
client privacy and is known for its innovative, fair, responsible, and proactive
approach to privacy. Our objective is to:
Froneman Law
Data Protection and Privacy Policy
4.1.1 Be open and transparent about the way we process personal information, provide fair
choices on how such data is processed, manage personal information responsibly,
and offer secure services to our clients.
4.2 Froneman Law Privacy Principles:
4.2.1 Accountability: We are accountable for living up to the privacy principles, including
when working with our partners and clients.
4.2.2 Fairness and lawfulness: We comply with privacy laws and act with integrity and
fairness.
4.2.3 Openness and honesty: We communicate clearly about our actions that may impact
privacy, we ensure our actions reflect our words and we are open to feedback about
our actions. We give people the ability to make simple and meaningful choices about
their privacy and allow clients, where appropriate, to access, update, or remove their
personal information.
4.3 How we manage and protect information
4.3.1 Responsible Data Management and Limited Disclosures: We apply appropriate data
management practices to govern the processing of personal information. We choose
partners who participate in the processing of personal information carefully and we
limit disclosures of personal information.
4.3.2 Security safeguards: We implement appropriate technical and organizational
measures to protect personal information against unauthorized access, use,
modification, or loss.
5 Policy Implementation
5.1 The director of Froneman Law is accountable for the effective implementation and
monitoring of this Policy
6 Terms Used in this Policy
Terms used in this Policy are defined in the below table:
Child-a person under the age of 18 (eighteen)
Means information (whether oral, written, or in electronic form) relating
to any client, including but not limited to (i) views or opinions of another
individual about the client; and (ii) information relating to the clients-
a. race, sex, gender, sexual orientation, pregnancy, marital status,
nationality, ethnic or social origin, colour, age, physical or mental
health, well-being, disability, religion, conscience, belief, cultural
Froneman Law
Data Protection and Privacy Policy
| affiliation, language, and birth. b. education, medical, financial, criminal, or employment history. c. names, identity numbers, and/or any other personal identifier, including any number(s), which may uniquely identify a client, e- mail address, physical address, cellular phone number, telephone number, or other particular assignment. d. personal opinions, views, or preferences. e. correspondence that is implicitly or expressly of a personal, private, or confidential nature (or further correspondence that would reveal the contents of the original correspondence). |
Process,
Any operation or activity or any set of operations concerning Personal |
7 Data Protection Principles
The Processing of Personal Information by Froneman Law and/or third parties must
adhere to the following privacy key principles:
7.1 Accountability: Froneman Law shall put in place measures to comply with applicable
privacy laws and principles contained in this Policy.
7.2 Processing Limitation: Personal information must be processed lawfully and
reasonably in that does not infringe on the privacy of the client.
7.3 Purpose specification: The Processing must be for a specific and explicitly defined
purpose.
7.4 Quality and transparency: The information processed must be complete, accurate,
and where necessary, kept updated. Clients must be made aware of the Processing.
7.5 Security: The integrity and confidentiality of the Personal Information must be
ensured.
8 Policy Violations
8.1 Non-compliance with this Policy constitutes misconduct and could, in the case of
employees of Froneman Law, result in disciplinary action in terms of Froneman Laws
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Data Protection and Privacy Policy
Disciplinary Procedure and Code and could lead to dismissal and/or further legal
action being taken against the responsible Froneman Law employee(s).