Privacy Policy – SPT Computers CC – Payslip Delivery Services

Last updated: July 30, 2025

1. Introduction

This Privacy Policy explains how SPT Computers CC ("we", "us", "our") processes personal information as an Operator (Data Processor) for our client companies ("Responsible Parties") who use our software platform and services to deliver payslips to their employees via WhatsApp and other electronic means.

We process personal information in accordance with the Protection of Personal Information Act, 4 of 2013 (POPIA), the Basic Conditions of Employment Act (BCEA), and other applicable South African laws.

2. Company Information

3. What Data We Process

• Employee name and payroll identifier
• Employee WhatsApp phone number
• Payslip documents (PDF format) and related payroll information
• Message delivery and access logs (for security and audit purposes; logs are retained for up to 12 months, then securely deleted)

4. Purpose of Processing

We process personal information solely to provide payslip delivery services to employees of our client companies, in line with our contractual agreements with such companies. This includes:

• Delivering payslips and related payroll information via WhatsApp or other secure electronic means as instructed by our client (the employer)
• Assisting employers to comply with their legal obligations under South African labour law (specifically the BCEA, which requires employers to provide payslips to employees)

We do not use personal information for our own purposes or share it with third parties except as required to deliver the service (e.g., transmitting data to WhatsApp/Meta for message delivery).

Payslip documents are stored solely for the purpose of automated delivery and are not made accessible through the platform interface to any users.

5. Legal Basis and Compliance

Our processing of employee personal information is based on our clients’ (employers') instructions, in accordance with their employment contracts, company policies, and relevant laws including POPIA and the BCEA.

• The client company (employer) is the Responsible Party (Controller) and determines the purpose and means of processing.
• SPT Computers CC is the Operator (Processor), acting only on instructions from the employer and as required by law.
• It is the employer’s responsibility to obtain any required consent from employees for the use of their WhatsApp number or electronic delivery of payslips. Consent may be obtained through the employment contract, onboarding documentation, or official company communication, in line with POPIA and Meta/WhatsApp’s privacy policies.

6. Data Retention

We retain personal information only as long as instructed by our client companies, and/or as required by law for recordkeeping and audit purposes. Delivery and access logs are retained for up to 12 months, then securely deleted. When no longer needed, data is securely deleted or anonymised.

7. Data Security

All communication with third parties (such as SimplePay and WhatsApp) is encrypted using HTTPS (TLS). Payslip PDFs and personal data are stored on secure servers physically located within South Africa, outside of any publicly accessible web directories.

Payslip documents are not accessible to employees or employers via the platform; they are processed and delivered exclusively by SPT Computers CC on behalf of client companies. No public or user access is permitted to stored payslips, and only authorized SPT Computers CC technical personnel have access for operational and support purposes.

Strict access controls, logging, and regular security reviews are in place to prevent unauthorized access or disclosure.

Data Breach Notification: In the event of a data breach or unauthorized access, we will promptly notify the relevant Responsible Party (employer) as required by law.

8. Cross-border Data Transfers

Where required to deliver messages (e.g., via WhatsApp Cloud API, which may be hosted outside South Africa), personal data may be transferred outside South Africa. In such cases, we take steps to ensure that adequate data protection standards are maintained as required by POPIA.

9. Data Subject Rights

Under POPIA, employees (data subjects) have the right to:

• Access, correct, or request deletion of their personal information
• Object to processing under certain circumstances
• Lodge a complaint with the Information Regulator (South Africa)

Employees wishing to exercise these rights should contact their employer (the Responsible Party) directly. SPT Computers CC will assist its clients in responding to any such requests as required by law.

10. Changes to This Policy

We may update this policy from time to time. The “Last updated” date at the top indicates the latest version. Significant changes will be communicated to our client companies.

11. Contact Us

For any queries relating to this policy or how your personal information is processed by SPT Computers CC, please contact us at info@sptcomputers.co.za.
For any requests or concerns regarding your payslip or employment data, please contact your employer directly.

12. Consent for WhatsApp Communication

Our service requires that employees have consented to receive their payslips via WhatsApp. This consent is managed and recorded by the employer (our client) in compliance with POPIA and Meta/WhatsApp’s privacy policies. If you have questions about your consent status or wish to withdraw consent, please contact your employer directly.

13. Disclaimer

This Privacy Policy is for information purposes only and does not constitute a service agreement. All use of the Payslip Delivery Service is governed by the relevant service agreement or Terms & Conditions entered into between SPT Computers CC and its clients. Clients are responsible for complying with all legal requirements applicable to their business, including but not limited to employment and privacy laws.

For privacy information relating to all other SPT Computers CC products and services, please see our General Privacy Policy.