Privacy Policy.

1.1“Data Subject” refers to any identifiable, living natural person or existing juristic person whose Personal Information is processed by KBT Debt Collections, including debtors, creditors, clients, employees, service providers, and representatives.

1.2“Employee” means any person employed by or providing services to KBT Debt Collections, including permanent, temporary, contractual staff, agents, and call-centre personnel.

1.3“KBT Debt Collections” means KBT Debt Collections (Pty) Ltd, Registration Number 2018/445601/07, hereinafter referred to as “KBTDC”.

1.4“Information Officer” means the person appointed by KBTDC in terms of section 56 of the Protection of Personal Information Act 4 of 2013 (“POPIA”), who bears overall responsibility for compliance with POPIA.

1.5“PAIA” means the Promotion of Access to Information Act 2 of 2000.

1.6“Personal Information” has the meaning ascribed to it in POPIA and includes, but is not limited to:

• Identifying information (names, ID numbers, registration numbers);
• Contact details (addresses, email addresses, telephone numbers);
• Financial and credit information;
• Employment and income information;
• Banking and payment information;
• Call recordings and correspondence;
• Legal, contractual, and litigation-related records.

1.7“POPIA” means the Protection of Personal Information Act 4 of 2013.

1.8“Processing” means any operation concerning Personal Information, including collection, recording, storage, dissemination, use, merging, restriction, erasure, or destruction.

1.9“Responsible Party” means the entity that determines the purpose and means of processing Personal Information. For purposes of this policy, KBTDC is the Responsible Party.

2.1This policy explains how KBTDC collects, processes, stores, and protects Personal Information in the course of providing debt-collection, credit-management, tracing, litigation support, and related services.

2.2This policy applies to all Personal Information processed by KBTDC, whether obtained directly from Data Subjects, clients, employers, credit providers, public records, or third parties.

2.3By engaging with KBTDC, you acknowledge and consent to the processing of Personal Information in accordance with this policy, subject to applicable legal limitations.

3.1KBTDC is committed to protecting the privacy, confidentiality, and integrity of Personal Information.

3.2KBTDC implements appropriate technical and organisational safeguards, including:

• Restricted access controls;
• Secure IT systems and password protection;
• Confidentiality undertakings by employees;
• Secure storage of physical and electronic records;
• Controlled access to call recordings and debtor files.

3.3Personal Information is processed strictly on a need-to-know basis.

4.1KBTDC may collect and process:

• Personal Information of debtors and representatives;
• Client instructions, mandates, and account information;
• Financial and credit data;
• Employment and income verification details;
• Correspondence, call recordings, and communication logs;
• Legal documentation relating to enforcement and litigation;
• Information obtained from tracing agents, credit bureaus, employers, or public sources.

4.2Where Personal Information of third parties is provided to KBTDC, the provider warrants that they are authorised to do so.

5.1KBTDC collects Personal Information:

• Directly from Data Subjects;
• From clients and employers;
• From credit providers and financial institutions;
• From public records, credit bureaux, and tracing services.

5.2Personal Information is processed lawfully and in accordance with POPIA, including where processing is necessary for:

• Performance of a contract;
• Compliance with a legal obligation;
• Legitimate interests of KBTDC or its clients;
• Establishment, exercise, or defence of legal rights;
• Debt recovery, enforcement, and litigation.

5.3Consent may be withdrawn where legally permissible, subject to the impact on KBTDC’s ability to perform its mandate.

6.1Personal Information may be shared:

• Internally within KBTDC;
• With clients who have mandated KBTDC;
• With attorneys, sheriffs, tracing agents, and counsel;
• With credit bureaux and employers where lawful;
• With courts, tribunals, and regulatory bodies.

6.2Disclosure to third parties is limited to what is necessary and lawful.

6.3Where information is transferred outside South Africa, KBTDC ensures appropriate safeguards are in place.

7.1Personal Information is retained only for as long as necessary to fulfil the purpose for which it was collected.

7.2Retention periods are aligned with:

• Legal and regulatory requirements;
• Prescription periods;
• Contractual obligations;
• Industry best practice.

7.3Records are securely destroyed once no longer required.

8.1Data Subjects have the right to:

• Request confirmation of whether KBTDC holds their Personal Information;
• Request access to such information;
• Request correction or updating of inaccurate data;
• Object to processing in certain circumstances;
• Request deletion or restriction where legally permissible.

8.2Requests must be submitted in writing to the Information Officer and may be subject to prescribed fees under PAIA.

10.1Any concerns regarding the processing of Personal Information may be directed to KBTDC’s Information Officer.

10.2Complaints may also be lodged with the Information Regulator of South Africa: