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Key Guarantee: FieldControl operates strictly within the Republic of South Africa. All customer data, GPS clock-in logs, employee timesheets, and contractor records are stored in enterprise cloud infrastructure with zero unauthorized overseas transmission.
1. Purpose & Scope
This statement sets forth how FieldControl ZA (a product of TVB Network (Pty) Ltd, Reg. 2022/948210/07) collects, processes, protects, and retains Personal Information in compliance with the Protection of Personal Information Act, 2013 (POPIA).
2. Roles of Parties (Responsible Party vs. Operator)
- The Client (Employer / Contractor Agency): Acts as the Responsible Party who determines the purpose and means for collecting employee and subcontractor information.
- FieldControl / TVB Network: Acts as the Operator who processes personal information on behalf of the Responsible Party in accordance with contractual service level agreements.
3. Categories of Personal Information Processed
To enable field workforce dispatch, biometric clock-ins, and COIDA compliance, the following records are processed:
- Identity Details: Full name, South African National ID / Passport number, contact telephone number, and work email.
- Fleet & Trade Data: Field specialty trade, certified competencies, vehicle license registration plate, and driver authorization.
- Geofenced Location Telemetry: GPS coordinates (latitude, longitude, and horizontal accuracy) captured strictly at discrete clock-in, clock-out, or milestone events. FieldControl does not conduct 24/7 background passive tracking when workers are off-shift.
- Statutory & Wage Records: BCEA regular and overtime hours, hourly pay rates, approved timesheets, and contractor B-BBEE contributor levels.
- Safety & OHS Signatures: Digital signature bitmaps captured for customer job sign-off and OHS Act pre-work hazard assessments.
4. Lawful Grounds for Processing (Section 11)
Processing is carried out pursuant to:
- Performance of employment contracts and field service work orders.
- Statutory compliance with the Basic Conditions of Employment Act (BCEA) and Occupational Health and Safety Act (OHS Act).
- Protection of legitimate client interests regarding fraud prevention and verification of on-site service delivery.
5. Retention and Destruction Policy (Section 14)
- GPS Clock Logs: Retained for 90 days for client billing dispute resolution, after which detailed coordinates are archived or aggregated.
- Payroll & Timesheets: Retained for 3 years in accordance with BCEA statutory audit mandates.
- OHS Compliance Audits & Invoices: Retained for 5 years in accordance with SARS tax and Department of Employment and Labour inspection directives.
6. Security Measures & Technical Safeguards (Section 19)
- Enterprise Google Cloud BigQuery database encryption at rest (AES-256) and in transit (TLS 1.3).
- Role-Based Access Control (RBAC) with cryptographic session authentication (`TvbSSO`).
- Isolated per-business multi-database sharding (`biz_`) guaranteeing complete organizational segregation.
7. Data Subject Rights (Access, Correction & Objection)
Workers and contractors have the right under Sections 23 and 24 to request access to their personal information, request correction of inaccurate logs, or object to unlawful processing. Requests may be submitted via the employer's HR administrator or directly to our Information Officer:
Information Officer Contact:
TVB Network (Pty) Ltd • Attn: Information Officer
Email: privacy@tvbnet.co.za
Physical Address: Pretoria, Gauteng, 0002, South Africa
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