Privacy Policy

Semaphore Consulting (Pty) Ltd has a Data Security Compliance Program to ensure we operate in accordance with relevant laws and regulations in the event of a data breach.

What Will We Do in the Event of a Data Breach?

Semaphore Consulting (Pty) Ltd has a Critical Incident Response Team (which includes our Data Protection Officer, Developers, and Senior Management), and a Breach Response Plan that is reviewed annually.

Below is a high-level summary of the steps Semaphore Consulting (Pty) Ltd will take in the event of a suspected data breach.

Step 1 – Incident Detection and Preliminary Assessment

• Semaphore Consulting (Pty) Ltd users, employees and contractors can report suspected operational and security breaches to Semaphore Consulting Support via live chat, email or phone.
• Semaphore Consulting (Pty) Ltd will take immediate steps to conduct a preliminary investigation, where we will identify and classify the suspected breach.

Step 2 – Contain Breach

If the preliminary investigation confirms a suspected breach, we will take immediate steps to:

• Contain the breach.
• Limit distribution of the affected personal information.Limit possible compromise of other
• information.

Step 3 – Evaluate Risks Associated With the Breach

The next step is to undertake a reasonable and expeditious assessment to:

• Gather all relevant information on the breach.
• Make a decision, based on the investigation, about whether the breach is an eligible data breach.
• Determine who needs to be made aware of the breach.
• Document everything at each step.

Step 4 – Notification

Semaphore Consulting (Pty) Ltd will notify affected organisations and users as soon as possible once the facts are known, if:

• There is a chance of serious harm, or if a notification would give the users or customer organisation the ability to avoid serious harm.
• An incident is likely to cause humiliation or embarrassment for the individual.
• Their personal data was lost or stolen or viewed by the wrong people.
• If the user affected is a member of a group such as a school, Semaphore Consulting (Pty) Ltd will work with the organisation to decide on who communicates to the user (e.g. the parent).

Semaphore Consulting (Pty) Ltd will inform your countries relevant Privacy Commissioner (e.g. OAIC in Australia), of any eligible data breaches, providing ongoing updates on key developments.

Step 5 – Review to Prevent Future Breaches
In the event of a breach, Semaphore Consulting (Pty) Ltd will:

• Fully investigate the cause of the breach.
• Record an Incident Report.
• Report to the relevant Privacy Commissioner on outcomes and recommendations in the event of a notifiable breach.
• Implement recommendations from the investigation to prevent future breaches.

Contact Us

If you have any questions about this Data Breach Policy, please contact us:

• By email: help@xuno.com.au