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Privacy Policy


Complete Specialized Retail Solutions (PTY) Ltd (hereafter “CSRS”) respects your privacy and your personal information. This Privacy Policy aims to let you know how the CSRS will treat any personal information that it may have about you and how you can access such personal information held. The CSRS will take all reasonable measures, in accordance with this Policy, to protect your personal information and to keep it confidential.


Personal information is “personal information” as defined in terms of section 1 of the Protection of Personal Information Act 4 of 2013 (“POPIA”). This is information relating to an identifiable, living natural person or existing juristic person. Please refer to POPIA for a detailed definition and various types or categories of personal information.


The CSRS only collects general personal information (some of which may be publicly available) and aims to only collect that personal information which is necessary for it to carry out its services and other membership benefits provided to you. The CSRS collects the following personal information:

Members – such as name, contact details, email, physical and postal addresses, company details, designations, professional experience, work experience (CVs) and qualifications. Member profiles provide for other information to be provided but this is voluntary information that can be provided at the discretion of the member.

Suppliers/Procurement – such as company name, address and contact details, banking details, VAT number and BEE certificate/level information.

Website – such as general website page analytics and usage information through the use of cookies (all such information is un-identifiable information for the purposes of POPIA, see CSRS Cookie Policy for further detail); as well as in some instances website user (i.e. non- member) name and contact details for access to specific CSRS content/services not freely available to the general public.

Employees – all applicable employee information required to be kept from a labour law perspective and running of the organisation. Such information relates to internal employees and not external clients. As such the rest of this Policy will not cover Employee Information as this is dealt with in CSRS internal HR Policies. Furthermore, external parties (unless with applicable court orders or legal reasons) shall not have access to such Employee Information.


Your personal information is obtained directly from you either via online forms on our website, email communications, and on occasion telephonically (only under specific circumstances and at your request).


The CSRS collects personal information for the following purposes:

a. To process your membership application and to provide you with services offered and requested.

b. To understand your specific needs and requirements, and in order to improve the CSRS member benefit, service and value offering.

c. To provide you with CSRS communications in relation to the services being rendered, and keeping you informed of governance related updates.

d. To provide you with CSRS related benefit/marketing material due to your past interaction and use of the CSRS services.

e. To ensure payment to suppliers for services procured. f. For health and safety purposes.

g. For statistical, historical and/or reporting purposes.

The CSRS will always ask for your permission before it uses your personal information for any purpose not disclosed above or unrelated to the operations/services of the CSRS and its use in the ordinary course of business.


The personal information collected is used only by the CSRS and its employees in the rendering of its organisational purpose and services. Only in instances where the sharing of personal information to recipients outside of the CSRS is necessary in order to fulfil a CSRS obligation or service will such information be provided.


As part of the member benefits provided to CSRS Members, the CSRS may be required to provide third party service providers with minimal Member personal information (such as for example: name, membership number, contact details) in order to provide such Member Benefits. Personal information provided to third party service providers for such purposes, will be limited to only that information which is absolutely necessary in order for the member to enjoy such benefit which he/she is entitled to. No further information will be provided and third party service providers are prohibited from using Member details for any other purpose other than providing the Member benefit or for statistical and historical purposes.

Your privacy is important to us. The CSRS will therefore not sell, rent nor provide your personal information to unauthorised entities or to third parties for their independent use without your consent. The CSRS will release your personal information to a party if it believes that CSRS is required by law or by a court or statutory body to do so. The CSRS will also disclose your personal information if the CSRS believes that it is necessary to prevent or lessen any unlawful or harmful actions and to protect and defend legitimate business interests, rights or property of the CSRS.


The CSRS values the information that you choose to provide to us and will therefore take reasonable steps to protect your personal information from loss, misuse or unauthorised alteration. The CSRS conducts regular security testing of its servers and ensures that its employees are trained around protection of personal information to ensure that your personal information is used correctly and protected.

When you use the services or facilities provided by the CSRS, you may be given an access number, user name, password and/or personal identification number (“PIN”). You must always keep your user name, access card, password and/or PIN a secret and ensure that you do not disclose it to anyone. The CSRS shall not be held responsible for personal information accessed as a result of you providing someone your CSRS profile username and password.

Upon your request the CSRS will provide you with its records of the personal information you provided to us. For security reasons, this information will only be sent to the e-mail address on file for the subscriber username and password associated with it.

If you wish to object to the CSRS processing your personal information, kindly complete Form 1 (Annexure A) in terms of POPIA and send same to the Information Officer at the CSRS or to Objecting to the processing of your personal information, may result in services being stopped, access or implementation issues and/or other service inefficiencies and communications.


Personal information is stored on the CSRS servers located onsite and, in the cloud, (which in this case may be hosted outside of South Africa, see Clause 10 below) which is accessed by CSRS internal employees only. Personal information will only be retained for so long as necessary to carry out the function, Services required and/or for historical and statistical use by the CSRS.

Personal Information no longer required for the purposes of rendering services to you or after completion of services, will be destroyed. The CSRS undertakes to ensure that personal information shall not be stored for longer than 5 years, unless required to do so by law or other regulatory obligations and/or for historical record purposes. The CSRS however may maintain de- identified information for statistical purposes.


Your personal information may be stored on servers located outside of South Africa due to the CSRS’s Association Management System. The CSRS however undertakes to ensure that service providers used for such cloud servers and/or services are obliged to comply with the highest standards of data protection to ensure the security of your personal information.


The CSRS is not responsible for the content or the privacy policies of websites of other institutions to which it may link you to – mainly for information purposes and access to documents provided by such institutions. The use of other third-party websites and content is at your sole discretion. This Policy applies solely to information collected by the CSRS. The CSRS is not responsible for any representations or information or warranties or content on any website of any third party (including websites linked to the CSRS website). The CSRS does not exercise control over third parties’ privacy policies, and you should refer to the privacy policy of any third party to see how such party protects your privacy.


If you disclose any personal information to a third party, such as your client, employer or business partner or anyone other than the CSRS, you must be aware that the CSRS does not regulate or control how that third party uses your personal information. You should always ensure that you read the privacy policy of any third party.


It is your responsibility to ensure that the personal information provided to the CSRS is true, correct and accurate at all times. You may update and correct your personal information at any time either yourself via your online CSRS profile, via email communications to the CSRS by sending an e-mail to or through completing and sending Form 2 (Annexure B) in terms of POPIA to the Information Officer at the CSRS or The CSRS does not vet or check the information provided to it, and thus will not be held responsible for any incorrect or outdated information it may and which may be used to provide you with relevant and important communications.

If you would like your Personal Information deleted by the CSRS, kindly also use Form 2 (Annexure B) and send same to the Information Officer at the IoDSA or to Deleting your Personal Information may impact the services being used, offered or access there to.


See the CSRS PAIA Manual for detailed information around your rights to access information held by the CSRS and applicable steps to follow.


The CSRS may change this Policy at any time. The most current version of this Policy will be displayed on the CSRS website. If you use this website or any of the services or facilities offered by the CSRS after the CSRS has displayed a change to this Policy, you will be deemed to have read and agreed to the change.


This Policy will be governed by the laws of the Republic of South Africa. Specifically, the CSRS undertakes to comply with the provisions of POPIA and the Promotion of Access to Information Act No.2 of 2000 (“PAIA”).
In so far as the CSRS collects and uses personal information relating to European Citizens (who may elect to be CSRS Members), the CSRS undertakes to uphold and comply with the data protection obligations in terms of the General Data Protection Regulation (GDPR) (EU) 2016/679 so far as it applies to the CSRS and in a proportionally manner based on the type and amount of information held. For more information on the GDPR see The European Commission website


You consent to the jurisdiction of the South African courts for any dispute which may arise out of this privacy policy.