(Protection of Personal Information Act No. 4 of 2013)
Document Version: 1.0
Last Updated: November 2025
Applies To: Impande Funeral Benefits, all staff, representatives, service providers and
policyholders.

1. Introduction
Impande Funeral Benefits (“IFB”, “we”, “us”, “our”) is committed to protecting the constitutional right to privacy and safeguarding personal information in accordance with the Protection of Personal Information Act (POPIA). This policy explains how we collect, use, store, share and protect personal information when providing funeral benefit services, as outlined in our brochure
Impande Funeral Benefit Brochure.

2. Purpose of this Policy
The purpose of this policy is to:
• Ensure lawful processing of personal information.
• Establish minimum security and operational standards.
• Promote transparency in how Impande Funeral Brenefits handles personal information.
• Protect the interests of our members, beneficiaries, employees, and partners.

3. Scope
This policy applies to:
• All IFB staff (permanent, temporary and contracted).
• All clients, members and beneficiaries.
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• All third-party service providers handling information on our behalf.
• All forms of personal data processed by IFB.

4. Definitions
• Personal Information: Any information identifying a natural or juristic person (e.g., ID number, name, contact details, address, financial information).
• Special Personal Information: Information relating to health, biometrics, religion, children, etc.
• Processing: Any operation on information including collection, storage, updating, sharing, destruction.
• Data Subject: The person to whom the personal information relates.
• Responsible Party: Impande Funeral Benefits.

5. The Information Officer In compliance with POPIA, IFB appoints an Information Officer (IO) responsible for ensuring operational compliance.
Information Officer:
Name: Siyamukela Kunene
Telephone: 010 502 0871
Duties of the IO include:
• Developing and enforcing POPIA policies and procedures.
• Handling PAIA and POPIA requests.
• Reporting data breaches to the Information Regulator.
• Training staff on data protection obligations.

6. Categories of Information Collected Impande Funeral Benefits may process the following personal information:
6.1 Member Information
• Full name and surname
• ID number / Passport number
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• Date of birth
• Contact details (phone, email, physical address)
• Employment details (optional)
• Premium and payment information
6.2 Beneficiary Information
• Names and surname
• Relationship to member
• ID numbers / DOB
• Contact details
6.3 Funeral Claim Information
• Death certificate
• Cause of death (natural, accidental etc.)
• Supporting documentation
• Details required to provide approved benefits (cash or groceries)
6.4 Website and Digital Information
• Forms completed online
• Cookies and device information (where applicable)

7. Lawful Grounds for Processing IFB processes personal information on the following bases:
• Consent: Voluntary agreement by the data subject.
• Contractual necessity: To administer funeral benefits and claims.
• Legal obligation: Compliance with FAIS, FICA and insurance regulations.
• Legitimate interest: Fraud prevention, risk assessment and customer service.

8. Purpose of Processing
Personal information is used for:
• Policy applications and administration
• Premium collection
• Beneficiary management
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• Assessing and paying claims
• Customer support and communication
• Regulatory compliance
• Fraud detection and prevention
• Internal record keeping
• Delivery of funeral groceries or cash equivalents (as per brochure) Impande Funeral Benefit Brochure

9. Sharing of Personal Information
IFB will only share personal information where necessary and lawful. Information may be shared with:
• Underwriters
• Financial service providers
• Funeral service partners and grocery suppliers
• IT service providers
• Payment service providers
• Regulators (FSCA, SARS, Information Regulator)
• Law enforcement (where required)
Impande Funeral Benefit does not sell personal information.

10. Cross-Border Transfer
IFB does not routinely transfer personal information outside South Africa. If required, transfers will only occur where the receiving country has adequate data protection laws or contractual safeguards.

11. Data Subject Rights
Data subjects have the right to:
1. Access their personal information.
2. Correct or update personal information.
3. Request deletion, where lawful.
4. Withdraw consent at any time.
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5. Object to processing.
6. Lodge complaints with the Information Regulator:
Information Regulator South Africa
Email: complaints.IR@justice.gov.za

12. Information Security Measures
IFB implements the following safeguards:
12.1 Technical Security
• Password-protected systems
• Encrypted storage and transfers
• Access control and role-based permissions
• Secure backup systems
12.2 Physical Security
• Locked cabinets for paper documents
• Controlled office access
• Secure offsite storage for archives
12.3 Administrative Security
• Signed confidentiality agreements
• Staff POPIA training
• Regular audits and compliance checks

13. Data Retention Policy
Personal information is retained:
• While a policy is active
• For the required statutory period thereafter (usually 5–7 years)
• Claims records may be retained longer for legal purposes
After expiry, data is securely destroyed.
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14. Children’s Information
IFB processes information of children only with the consent of parents or legal guardians and solely for the purpose of policy and benefit administration.

15. Direct Marketing
IFB only sends direct marketing:
• With the member’s consent
• With an option to opt-out at any time

16. Data Breach Procedure
In the event of a suspected or confirmed breach:
1. The IO is notified immediately.
2. Impact and risk are assessed.
3. Affected data subjects are informed.
4. The Information Regulator is notified.
5. Corrective actions are implemented.

17. Third-Party Operators
Third-party operators processing personal information on IFB’s behalf must:
• Comply with POPIA
• Sign a written operator agreement
• Implement adequate security safeguards

18. Amendments to this Policy
IFB may amend this policy from time to time to remain compliant with legislation and operational changes. Updated versions will be made available on request.
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19. Acceptance
By engaging with Impande Funeral Benefits and providing personal information, members acknowledge that they understand and accept the practices described in this policy.