Version: 1.0
Effective Date: January 2026
Approved By: Managing Member
Applies To: All employees, consultants, intermediaries, service providers, and customers
of Impande Funeral Benefits.

1. Introduction
Impande Funeral Benefits (“IFB”, “we”, “us”, “our”) is committed to protecting the privacy
and personal information of all its customers, members, beneficiaries, employees, and
service providers. This Privacy Policy explains how we collect, use, store, share, disclose,
and safeguard personal information in accordance with the Protection of Personal
Information Act (POPIA) and other applicable laws of South Africa.
Protecting personal information is central to our values and essential for maintaining trust
with the families and communities we serve.

2. Purpose of this Privacy Policy
This Policy ensures that:
• Personal information is processed lawfully, fairly, and transparently
• Customers understand how their information is used
• IFB meets its regulatory obligations
• Clear guidelines exist for handling, retaining, and securing personal data
• All staff understand their responsibilities in relation to privacy

3. Scope
This Privacy Policy applies to:
Impande Funeral Benefits – Privacy Policy
Impande Funeral Benefits – Privacy Policy • Confidential • Page {page}
• All customers and members applying for funeral benefits
• All beneficiaries listed on policies
• All IFB staff, contractors, representatives, agents, intermediaries, and operators
• All third-party service providers who process personal information for IFB
The Policy applies to all personal information processed in physical, electronic, or digital
form.

4. Definitions
• Personal Information: Any information that can identify an individual (e.g., name,
ID, contact details).
• Special Personal Information: Sensitive data such as health status, biometric data,
children’s information, or religious beliefs.
• Data Subject: The individual whose personal information is being processed.
• Processing: Any operation involving personal information (collecting, storing,
updating, deleting, sharing).
• Responsible Party: Impande Funeral Benefits.
• Operator: A third-party service provider who processes personal information on
behalf of IFB.
• Information Officer: The individual appointed to oversee POPIA compliance.

5. Information We Collect
IFB collects the following types of information:
5.1 Member Information
• Full names and surname
• ID number
• Address
• Contact details
• Employment information (where applicable)
• Premium and payment information
• Application and policy details
Impande Funeral Benefits – Privacy Policy
Impande Funeral Benefits – Privacy Policy • Confidential • Page {page}

5.2 Beneficiary Information
• Names and surnames
• Relationship to the member
• ID numbers or dates of birth
• Contact information

5.3 Claims Information
• Cause of death
• Death certificate and supporting documents
• Proof of relationship or marital status
• Banking details for payout (if applicable)

5.4 Website & Digital Information
• Forms submitted online
• Cookies and usage data (if using the website)

5.5 Employee and Service Provider Information
• Payroll details
• Employment contracts
• Qualifications and background checks

6. How We Collect Personal Information
We collect information:
• Directly from customers, beneficiaries, or applicants
• From forms submitted online or in writing
• Through representatives or intermediaries
• From public databases (where lawful)
• From third-party operators (e.g., payment processors)
We do not collect information unlawfully or without consent.
Impande Funeral Benefits – Privacy Policy
Impande Funeral Benefits – Privacy Policy • Confidential • Page {page}

7. Legal Basis for Processing
We process personal information on the following grounds:
• Consent of the data subject
• Contractual necessity (e.g., to underwrite or administer a policy)
• Legal obligation (e.g., FAIS, FICA, POPIA)
• Legitimate interest (e.g., fraud prevention, customer service)

8. How We Use Personal Information
Personal information is used for purposes including:
• Policy administration
• Premium collection
• Claims assessment and payment
• Verification of beneficiary details
• Communication with members
• Regulatory reporting
• Delivery of funeral groceries or cash equivalents
• Internal record keeping
• Improving customer service
We do not use personal information for purposes unrelated to what was disclosed.

9. Special Personal Information
IFB may process sensitive data such as:
• Cause of death
• Children’s information
• Health-related information
This is only done:
• With explicit consent, or
• Where necessary for processing a claim, or
• As required by law
Impande Funeral Benefits – Privacy Policy
Impande Funeral Benefits – Privacy Policy • Confidential • Page {page}
We comply fully with POPIA requirements for handling sensitive personal information.

10. Sharing and Disclosure of Personal Information
We may share personal information with:
• Underwriters
• Funeral service partners
• Grocery suppliers (for funeral benefit delivery)
• Payment service providers
• IT system providers
• Regulators (FSCA, SARS, Information Regulator)
• Law enforcement (where legally required)
IFB never sells personal information.
All third parties receiving data must sign confidentiality agreements and comply with
POPIA.

11. Cross-Border Data Transfer
IFB does not routinely transfer information outside South Africa. If a transfer becomes
necessary, we ensure:
• The receiving country has adequate protections; or
• Appropriate contractual safeguards are in place; or
• The data subject provides consent

12. Data Subject Rights
Under POPIA, customers have the right to:
• Access their personal information
• Request correction or updating
• Request deletion (where lawful)
Impande Funeral Benefits – Privacy Policy
Impande Funeral Benefits – Privacy Policy • Confidential • Page {page}
• Object to processing
• Withdraw consent
• Lodge complaints with the Information Regulator
Information Regulator contact:
Email: complaints.IR@justice.gov.za

13. Data Retention Policy
Personal information is retained:
• For as long as the policy is active
• For the statutory retention period (typically 5–7 years)
• Longer where legally required for claims or disputes
After expiration, data is securely destroyed.

14. Security Safeguards
IFB uses technical, administrative, and physical security measures to protect information:
Technical
• Password protection
• User access controls
• Encrypted storage
• Secure backup systems
Physical
• Restricted access to offices
• Locked filing cabinets
• Secure destruction of documents
Administrative
• Confidentiality agreements
• POPIA compliance training
Impande Funeral Benefits – Privacy Policy
Impande Funeral Benefits – Privacy Policy • Confidential • Page {page}
• Regular audits

15. Direct Marketing
IFB only sends marketing messages:
• With the customer’s explicit consent
• With clear opt-out options
Customers may unsubscribe at any time.

16. Complaints and Queries
Complaints relating to privacy may be directed to:
Information Officer – Siyamukela Kunene
Tel: 010 502 0871
All complaints will be acknowledged and investigated promptly.

17. Updates to this Policy
This policy may be updated from time to time. Updated versions will be available on
request or published on our website.

18. Acceptance
By applying for membership or using our services, customers acknowledge and accept the
practices described in this Privacy Policy.