The Protection of Personal Information Act 4 of 2013 (“POPIA”) regulates how personal information of natural and juristic entities must be processed (“data subjects”) and sets out certain obligations that must be complied with when processing personal information.


1. What must Twilight Solutions do to ensure compliance with POPIA?
1.1. Accountability The responsible party must implement measures to ensure
compliance with the lawful processing conditions.
1.2. Processing Limitation The purpose of the processing of personal information must be
justifiable and must take place in a lawful, reasonable, and not excessive manner.
1.3. Purpose Specification Personal information must be collected and processed for a
specific and defined purpose.
1.4. Further Processing
Personal information may not be processed for a further purpose
where such purpose is not compatible with the original purpose of
the collection or where so authorised by the Information
1.5. Information Quality The responsible party must ensure the personal information being
processed is complete, accurate, not misleading and updated
where necessary.
1.6. Openness The responsible party must notify the data subject of its processing
1.7. Security Safeguards The responsible party must implement security safeguards to
ensure the integrity and confidentiality of the personal
1.8. Data Subject Participation Data subjects have certain rights in terms of their personal
information held by a responsible party, which includes requesting
access thereto and the correction or deletion thereof.

2. Twilight Solutions POPIA Compliance Programme:
2.1. Twilight Solutions compiled a robust POPIA Compliance Programme that is currently being
rolled out internally which addresses the abovementioned lawful processing conditions as well
as all other requirements set out under POPIA. In terms of the Twilight Solutions POPIA
Compliance Programme, Twilight Solutions has:
2.2. Reviewed its internal processes and created new processes to ensure compliance with the
lawful processing conditions, including processes related to the collection, storage, and
destruction of personal information.
2.3. Updated our internal policies to allow for the monitoring of compliance with the provisions of
2.4. Created a Privacy Policy, which will apply to Twilight Solutions, its dealers and any third parties
processing personal information on behalf of Twilight Solutions, requiring compliance with the
provisions of data privacy legislation, including POPIA, when processing personal information.
2.5. Reviewed and updated all our agreements to provide for data privacy and protection in
accordance with the requirements of POPIA.
2.6. Implementing new and updating current security safeguards to ensure the proper protection
of personal information processed by Twilight Solutions.
2.7. Created a process which allows data subjects to request access to, the correction or deletion
of their personal information held by Twilight Solutions.
2.8. Provided training to the various departments within Twilight Solutions to ensure they remain
aware and up to date of their obligations under POPIA.
2.9. Created a Privacy Policy to ensure data subjects may be knowledgeable of all Twilight
Solutions’ processing activities in relation to their personal information.
2.10. Improved Twilight Solutions’ security and data breach processes to meet the requirements of

3.1. The parties agree that personal information provided to Twilight Solutions staff or through its
website at www.twilightsolutions.co.za will be used only in accordance with the Twilight
Solutions privacy policy, found on the aforesaid website.
3.2. It is agreed that the Twilight Solutions privacy policy forms part of this POPIA Compliance
Notice. Further, that the client undertakes to acquaint himself/herself with the Twilight Solutions
privacy policy before proceeding and utilising the services of Twilight Solutions.
3.3. The client agrees that by providing his/her personal details to Twilight Solutions, he/she are
consenting to the use of this personal information in accordance with the Twilight Solutions
privacy policy, POPIA and other applicable data privacy legislation and internal policies.
3.4. In terms of the aforesaid privacy policy, Twilight Solutions undertakes to use your personal
information only for the purposes for which the information is essential and not to share or
further process your personal information without your consent.
3.5. If you require any further information regarding the Twilight Solutions data protection policy or
wish to exercise your rights in terms of POPIA, please send your enquiry to