Data Governance Policy

Effective Date: 31 July 2026

This policy is available on request from the Information Officer. Copies of all compliance documents are available at paymentsclub.co.za/compliance or by emailing privacy@paymentsclub.co.za") }}") }}.

1. Purpose

This Data Governance Policy defines the framework for managing data as a strategic asset at The Payments Club. It establishes the principles, roles, and responsibilities for ensuring data quality, security, compliance, and effective use across the organization.

2. Data Governance Principles

  • Accountability: Clear ownership and responsibility for data assets
  • Transparency: Open communication about data practices
  • Data Quality: Ensuring accuracy, completeness, and timeliness
  • Security: Protecting data from unauthorized access and breaches
  • Compliance: Adhering to POPIA and other applicable laws
  • Privacy by Design: Integrating privacy considerations into all systems and processes

3. Roles and Responsibilities

3.1 Information Officer

  • Overall accountability for data governance
  • Oversight of POPIA compliance
  • Handling data subject requests and complaints
  • Ensuring policies are updated and implemented

3.2 System Administrators

  • Technical implementation of data governance controls
  • Security monitoring and incident response
  • Backup and recovery procedures
  • Access control management

3.3 Data Owners

  • Responsibility for specific data sets
  • Ensuring data accuracy and quality
  • Authorizing data access
  • Reviewing data retention requirements

3.4 All Members and Staff

  • Compliance with data governance policies
  • Reporting data quality issues
  • Protecting data in their possession
  • Using data only for authorized purposes

4. Data Quality Management

  • Accuracy: Data must be accurate and reflect the true state of affairs
  • Completeness: Data must be complete and not missing required fields
  • Timeliness: Data must be updated promptly when changes occur
  • Consistency: Data must be consistent across systems
  • Validation: Data must be validated at point of entry
  • Cleanup: Regular data cleansing to remove duplicates and errors

5. Data Classification

  • Public: Information that can be freely shared (e.g., event details, public policies)
  • Internal: Information for internal use only (e.g., internal communications)
  • Confidential: Information requiring protection (e.g., member contact details)
  • Restricted: Highly sensitive information (e.g., passwords, audit logs)

6. Access Control

  • Role-based access control (RBAC) for all systems
  • Least privilege principle — access only what is necessary
  • Regular access reviews
  • Multi-factor authentication for administrators
  • Access logging and monitoring

7. Data Sharing and Transfer

  • Data sharing only with legitimate business need
  • Third-party data processing agreements required
  • Cross-border transfers subject to POPIA requirements
  • Consent obtained for sharing with partners or sponsors
  • Data minimization — share only what is necessary

8. Incident Response

  • Immediate containment of data breaches
  • Investigation and root cause analysis
  • Notification to affected individuals and Information Regulator
  • Remediation and prevention of recurrence
  • Documentation and lessons learned

9. Policy Review

This policy will be reviewed annually and on any material change to processing or systems. The latest version is always published on our website.

Last Updated: 31 July 2026

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