1. Introduction
Traiman Consultants ("we", "us", "our") is committed to protecting your personal information and
respecting your right to privacy. This Privacy Policy explains how we collect, use, store, and
share your personal information in accordance with the Protection of Personal Information Act,
2013 (POPIA), and other applicable South African legislation.
By engaging our services or using our website, you acknowledge that you have read and understood
this Privacy Policy. If you do not agree with any part of this policy, please do not provide us
with your personal information.
2. Responsible Party
For the purposes of POPIA, Traiman Consultants is the responsible party in respect of the
personal information we process. Our contact details are:
3. Personal Information We Collect
We may collect and process the following categories of personal information:
3.1 Information you provide directly
- Full name, identity number, and date of birth
- Contact details (email address, telephone number, physical address)
- Tax reference numbers and VAT registration numbers
- Banking and financial information (bank account details, transaction records, financial statements)
- Employment and payroll information (salary details, IRP5 certificates, leave records)
- Company registration details and directorship information
- Any other information you provide to us in the course of our engagement
3.2 Information collected automatically
- IP address, browser type, and device information when you visit our website
- Pages visited and time spent on our website
- Cookies and similar tracking technologies (see Section 10)
3.3 Information from third parties
- Information from SARS, banks, auditors, or other parties relevant to providing our services
- Credit information from credit bureaus, where applicable and with your consent
4. Purpose of Processing
We process your personal information for the following purposes:
- Providing accounting, bookkeeping, payroll, tax, and advisory services as agreed in our engagement
- Preparing and submitting statutory returns (VAT, PAYE/EMP201, EMP501, provisional tax)
- Preparing financial statements, management accounts, budgets, and forecasts
- Processing payroll and related compliance submissions
- Liaising with auditors, SARS, and other relevant authorities on your behalf
- Communicating with you about our services, your accounts, and relevant deadlines
- Complying with legal and regulatory obligations
- Managing our business relationship with you, including invoicing and collections
- Improving our website and services
5. Legal Basis for Processing
Under POPIA, we process your personal information on one or more of the following grounds:
- Consent: You have given us specific consent to process your personal information for a defined purpose
- Contract: Processing is necessary to fulfil our obligations under a service agreement with you
- Legal obligation: Processing is required to comply with South African law (including the Tax Administration Act, Income Tax Act, and VAT Act)
- Legitimate interest: Processing is necessary for our legitimate business interests, provided these do not override your rights and interests
6. Sharing of Personal Information
We do not sell your personal information. We may share your personal information with the
following parties, only to the extent necessary:
- SARS: For filing tax returns, PAYE submissions, and VAT returns on your behalf
- Your auditors or independent reviewers: When liaising for annual audits, reviews, or compilations
- Your banking institutions: For payment processing and reconciliation purposes
- Regulatory bodies: Where required by law or regulation
- Cloud service providers and software platforms: For accounting software, payroll processing, and secure document storage (all bound by appropriate data processing agreements)
- Professional advisors: Our own legal or professional advisors, where necessary
Where we share personal information with third parties located outside of South Africa, we
ensure that adequate safeguards are in place as required by POPIA, including confirming that
the recipient is subject to comparable data protection legislation or binding agreements.
7. Retention of Personal Information
We retain your personal information only for as long as is necessary to fulfil the purposes
for which it was collected, or as required by law. Specific retention periods include:
- Tax records: A minimum of 5 years from the date of submission, or as required by the Tax Administration Act
- Payroll records: A minimum of 5 years as required by the Basic Conditions of Employment Act
- Financial records: A minimum of 5 years as required by the Companies Act, 2008
- General correspondence and engagement records: For the duration of our engagement plus 5 years
Once information is no longer required, it will be securely destroyed, deleted, or
de-identified in accordance with POPIA.
8. Security of Personal Information
We are committed to protecting the confidentiality and integrity of your personal information.
We have implemented appropriate technical and organisational measures, including:
- Encryption of sensitive data in transit and at rest
- Access controls limiting personal information to authorised personnel only
- Secure cloud-based storage with reputable providers
- Regular review and updating of our security practices
- Secure disposal of physical and electronic records
In the event of a data breach that may result in risk to you, we will notify the Information
Regulator and affected data subjects as required by POPIA.
9. Your Rights Under POPIA
As a data subject, you have the following rights under POPIA:
- Right of access: You may request confirmation of whether we hold personal information about you and request access to that information
- Right to correction: You may request that we correct or update inaccurate, incomplete, or misleading personal information
- Right to deletion: You may request that we delete your personal information where it is no longer necessary for the purpose for which it was collected, subject to legal retention requirements
- Right to object: You may object to the processing of your personal information on reasonable grounds, or object to receiving direct marketing communications
- Right to withdraw consent: Where processing is based on consent, you may withdraw your consent at any time (this does not affect the lawfulness of processing before withdrawal)
- Right to lodge a complaint: You may lodge a complaint with the Information Regulator if you believe your personal information has been unlawfully processed
To exercise any of these rights, please contact us at
info@traiman.co.za. We will respond to your
request within a reasonable time, and no later than 30 days.
10. Cookies
Our website may use cookies and similar technologies to improve your browsing experience and
analyse website traffic. Cookies are small text files stored on your device. You may control
or delete cookies through your browser settings. Disabling cookies may affect the functionality
of certain parts of our website.
We may use the following types of cookies:
- Strictly necessary cookies: Required for the website to function and cannot be switched off
- Analytics cookies: Help us understand how visitors interact with our website by collecting information anonymously
11. Direct Marketing
We will not use your personal information for direct marketing purposes without your prior
consent. You may opt out of marketing communications at any time by contacting us at
info@traiman.co.za or by using the unsubscribe
mechanism in any marketing communication.
12. Children's Personal Information
We do not knowingly collect personal information from children under the age of 18 without
the consent of a competent person (parent or guardian). If we become aware that we have
collected personal information from a child without appropriate consent, we will take
steps to delete that information.
13. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or
applicable legislation. The updated policy will be posted on our website with a revised
effective date. We encourage you to review this page periodically.
14. Information Regulator
If you are not satisfied with how we handle your personal information, you have the right
to lodge a complaint with the Information Regulator (South Africa):
15. Contact Us
If you have any questions about this Privacy Policy, wish to exercise your rights under POPIA,
or need to report a data-related concern, please contact us: