Dear participating employers, CBCs and CFAs
POPIA promotes the protection of personal information, and all retirement funds must comply with it.
The Sanlam Umbrella Fund and its Sponsor and administrator, Sanlam, takes the protection of the personal information of our members, employers and our Fund very seriously. The Fund will only collect, use, and keep personal information if there is a lawful purpose for doing so.
POPIA requires that a “responsible party” that contracts with a person who processes personal information (an operator) conclude a written contract with the operator. This is to ensure that the operator is compliant with the requirements of the Act.
The offering provided by the Fund involves the processing of personal information by several stakeholders. Where a participating employer provides personal information relating to its employees to the Fund, the employer is the responsible party. As such, the employer is required to conclude a written agreement with the Fund. The roles are reversed when the Fund provides the employer with fund data.
We wish to remind stakeholders that the Fund already has a written agreement with each participating employer, generally known as the confirmation of acceptance document (the COA). In this document, the employer agrees to the terms and conditions of participating in the Fund set out in the Fund in Detail (TFID). The Fund has incorporated a chapter on the Protection of Personal Information Standards and Requirements in TFID available online. To this end, the employer and the Fund are compliant with POPIA, and no additional agreement is necessary.
The data protection chapter in TFID will also apply in those situations where the Fund shares fund data with representatives of the employer such as a CBC or members of a joint forum. Furthermore, forms, policies and documents have been updated accordingly.
Click here to read a summary of the requirements that participating employers, CBCs, CFAs and the members of the Joint Forums will be required to comply with.
The Sanlam Umbrella Fund