Whistleblowing

INTRODUCTION
BDO South Africa (BDO SA) is a member of BDO International Ltd, a UK company limited by guarantee, and forms part of the worldwide network of independent legal entities, each of which provides professional services under the name “BDO”.
BDO is an international network of independent public accounting, tax and advisory firms (the “BDO network”), which perform professional services under the name of BDO (the “BDO member firms”). BDO International Limited (“BDOI”) is a UK company limited by guarantee. It is the governing entity of the BDO network.
Each of BDO and the member firms is a separate legal entity and has no liability for another such entity's acts or omissions. Nothing in the arrangements or rules of the BDO network shall constitute or imply an agency relationship or a partnership between BDOI and the member firms.
This privacy statement (“Privacy Statement”) applies only to the Tip Offs Solution (or the “the Application”) which is provided by BDO SA. (also referred to below as “we”, “us”, “our”) and not to the various separate websites as per each location where BDO is present it redirects you to.
By using the Application and submitting any personal information to us, you agree to the use by us of your personal information in accordance with the terms of this Privacy Statement.
This Privacy statement describes how BDO SA collects, processes, retains and discloses your Personal Information in accordance with the requirements of the Protection of Personal Information Act (“POPIA”), the General Data Protection Regulation (‘GDPR’), the Protected Disclosures Act 26 of 2000, and any other applicable laws or Regulations.
BDO is committed to protecting your privacy and to ensure that your personal information is collected and used properly, lawfully and transparently.
SHOULD PERSONAL INFORMATION BE COLLECTED
If you are using the Application to make a report of unethical or criminal conduct, you need to be able to interact with BDO SA in full confidence that your identity will never be known to BDO SA unless you choose to disclose this.

If you choose to disclose your identity to BDO SA, we will keep your identity in the strictest confidence. The only Personal Information from you that we process is Personal Information you specifically choose to give us when you make a report.

When we report the information you have provided to us to our Client, this report has been subject to a rigorous anonymization process that removes any identifying Personal Information that could reveal your identity.

This anonymized report is sent only to the people that the organization concerned have entrusted with the responsibility of receiving and responding to anonymous and confidential reports of unethical activity.

The organization concerned may share the anonymized report with a third party such as investigators or auditors, but we will never reveal information about your identity to such third parties.
PERSONAL INFORMATION, PROCESSING OF PERSONAL INFORMATION
When using the Application, we confirm that we do not collect any Personal Information that can be directly or indirectly linked to your identity, unless you choose to submit this. We do not ordinarily collect ‘sensitive personal information’ such as Personal Information relating to your health, religion, political beliefs, race or sexual orientation, except if you voluntarily share this information with us or unless we are required to do so by law.

Our third-party service providers have no access to information that you choose to submit to Whistle Blowing application.

BDO collect will collect Personal Information of its’ client’s in terms of the relevant services contract entered into and in terms of our Client Personal Information privacy statement (https://www.bdo.co.za/en-za/legal-privacy/privacy-statement-client-personal-information) or in terms of BDO’s website privacy statement (https://www.bdo.co.za/en-za/legal-privacy/website-privacy-statement). This does not extend to those who submit a report on the Application unless the individual voluntarily chooses to provide this information.
YOUR RIGHTS
Please let us know if any of your Personal Information that we have collected from you, through your voluntary disclosure, required amendment so that we can correct and update the Personal Information on our systems.
INFORMATION SHARING
In general, we do not disclose or share your Personal Information with third parties unless we have a lawful basis or legitimate purpose for doing so.
Other situations in which we may disclose your Personal Information to a third party, are:
1. Where feedback must be given to an employer (BDO client) regarding whistle blower reports received;
2. Where feedback must be provided in monthly reports to the BDO client;
3. Where an investigation must be instituted as a result of the whistle blower report;
4. where permitted by law, to protect and defend our rights and property; and
5. when required by law, and/or public authorities.
We have agreements and security measures in place to ensure that all third parties to whom your Personal Information is disclosed comply with the terms and provisions of POPIA and any other applicable laws. We ensure that third parties fully understand the duties and obligations they become encumbered with in retaining the privacy and integrity of your personal information.
INFORMATION SECURITY
We have implemented generally accepted standards of technology and operational security to protect personal information from loss, misuse, alteration or destruction. You may request a copy of our Information Security and Privacy Overview Policy from us using the contact details set out below.

We will retain your personal information in accordance with our Personal Information retention policy which sets out Personal Information retention periods required or permitted by applicable law.
INFORMATION TRANSFER
Where it is necessary, for the purposes of processing, your Personal Information may be transferred outside of South Africa in accordance with the appropriate Personal Information protection laws.

We anticipate that Personal Information may need to be transferred outside of South Africa for purposes of cloud storage, and where we do so, we will ensure that the necessary safeguards are in place to protect personal information.

When your personal information is transferred to a country whose Personal Information protection laws do not provide an adequate level of protection for your personal information, we use the European Commission's approved Standard Contractual Clauses in order to ensure that the appropriate mechanisms and safeguards are in place. If you wish to see a copy of the relevant mechanism that we use to transfer your personal information, please contact us using the contact details set out below.
RETENTION
We retain Personal Information for as long as is necessary to fulfil the purposes for which it was collected or to comply with legal obligations. Depending on the purpose, retention periods will vary. The criteria we use to determine retention periods include whether we are under a legal, contractual or other obligation to retain Personal Information including pursuant to Personal Information retention laws, as part of an investigation or for litigation purposes.
CONTACT US
If you have questions or concerns regarding the way in which your personal information has been used, or should you have any questions about this Privacy Notice, please use the contact details set out below and provide the details relating to your query.
CHANGES TO THE PRIVACY NOTICE
We may update this Privacy Statement from time to time. If we do, we will post the revised version on our website, with an updated revision date.
TERMINATION
Should you at any point wish to revoke any consent, please contact us and we will assist you accordingly.
CONTACT DETAILS
You can contact us at tippoffs@bdo.co.za

BDO Member firms

Each BDO Member firm renders professional services in a particular geographic area under licence and is subject to the laws and professional regulations of the particular country or countries in which it operates.

BDO Advisory Services Pty Ltd are duly authorised resellers of the Expose-It Application ‘the Application’.

Any Agreement entered into between a client and a BDO member firm is between the client and that BDO member firm only, and the following provisions will apply where, and to the extent, permitted by applicable law:

If a BDO Member firm as an authorised distributor (by BDO Advisory Services Pty Ltd) of the Application carries out any work for its own client in relation to the Application and to which the relevant Agreement applies, that BDO Member firm will do so as a distributor of the Application and will remain solely responsible to its Client, inclusive of the work carried out by that particular BDO Member firm.

All BDO Member firms are separate and independent legal entities from one another which cannot obligate each other. No BDO Member firm will accept any liability (whether in contract, delict, breach of statutory duty or otherwise) for another BDO Member firm that has contracted with its’ own client for this Application. These exclusions shall not apply to any liability, claim or proceeding founded on an allegation of fraud or wilful misconduct or other liability that cannot be excluded under applicable laws.

Custodian		Annemari Krugel
Version Control	2
Last Updated	13092021