Privacy Notice (POPIA) & Community CCTV Programme
This notice explains how Ghosthome (the Responsible Party) processes personal information under the Protection of Personal Information Act, 2013 (POPIA), including our community street-camera programme.
1) Who we are & scope
Support: support@ghosthome.co.za • Privacy requests: privacy@ghosthome.co.za
2) What we collect
2.1 Website & customer data
- Contact details (name, email, phone), account credentials, billing/delivery addresses.
- Billing & payment metadata (invoice details; we do not store full card numbers).
- Support correspondence and call notes.
- Device & usage data: IP address, browser/OS, pages viewed, cookie preferences, diagnostics.
2.2 CCTV programme data
- Video images of public streets/sidewalks and vehicles in view; no audio is recorded.
- Event metadata: timestamps, camera ID, AI event types (e.g., person/vehicle), audit logs.
- Access control: name, email/phone, role, access times, activity logs.
2.3 Sensitive categories we avoid
- No facial recognition or biometric identification.
- Privacy masks applied to avoid filming into windows/private yards.
3) Sources of personal information
- Directly from you (accounts, subscriptions, support).
- Automatically via our website/app (cookies, logs).
- From cameras positioned on private property aimed at public streets/sidewalks.
- From third parties you authorise (payments, identity/anti-fraud checks).
4) Why we process data & legal grounds (POPIA)
| Purpose | Example activities | Lawful basis |
|---|---|---|
| CCTV programme | Community safety, incident response; resident live view; night person alerts 23:00–04:00; evidence on lawful request | Legitimate/public interest in safety; legal obligation for lawful disclosures |
| Account & billing | Manage subscriptions, invoices, payments, service notices | Contract; legal obligation (tax/accounting) |
| Service operations & security | Platform administration, troubleshooting, preventing abuse, audit logging | Legitimate interest; legal obligation (security, fraud prevention) |
| Marketing (optional) | Our own updates; no third-party ads | Consent where required; opt-out anytime |
5) Sharing & disclosures
We share personal information only when necessary and with safeguards:
- Operators (processors): hosting, email/SMS, payments, CCTV platforms, maintenance — under written operator agreements and confidentiality.
- Law enforcement / insurers / legal advisers: where required or permitted by law, or to establish/exercise/defend legal claims.
- HOA partners: on a need-to-know basis, per programme rules (may act as joint RP).
Residents cannot export or publicly share footage. Exports are restricted to the IO/authorised staff on written request with a lawful basis (e.g., SAPS case number).
6) Cross-border transfers (POPIA s72)
If a provider stores or processes data outside South Africa, we ensure an appropriate ground under POPIA s72 (adequate protection, binding agreements, or your consent). Where feasible, CCTV footage is stored locally and accessed securely.
7) Retention (how long we keep data)
| Record type | Default retention | Notes |
|---|---|---|
| CCTV footage | 7 days | Extended only under legal hold (e.g., SAPS case #) or ongoing investigation. Auto-purge enforced. |
| CCTV audit logs (user access/actions) | 12 months | Security/audit. |
| Resident live-view accounts | Life of account + 12 months | Audit & dispute resolution. |
| Billing & invoices | 5 years | Tax Administration Act. |
| Support tickets | 3 years | Service history. |
| Website server logs | 30 days | Security & troubleshooting. |
| Cookie preferences | 12 months | Remember your choices. |
| Marketing opt-out list | As long as needed | Minimal data to honour opt-out. |
| Legal holds | Until matter closes | Overrides defaults. |
8) Security
We implement reasonable and appropriate measures: role-based access; unique accounts; MFA for admins; encryption in transit; hardened servers; patching; privacy masks; no audio recording; strict export controls; and operator contracts with security obligations. We maintain a breach-response plan and will notify the Information Regulator and affected persons where required.
9) Your rights (POPIA)
- Access your personal information we hold.
- Request correction/deletion of inaccurate, irrelevant, excessive or unlawfully obtained information, or deletion of records we are no longer authorised to retain.
- Object to certain processing (including direct marketing) and opt-out at any time.
- Complain to the Information Regulator (details below).
How to make a request
- Access requests: email privacy@ghosthome.co.za.
- Correction/Deletion requests: email privacy@ghosthome.co.za (we accept Form 2 or clear written requests).
10) Cookies & similar technologies
- We use essential cookies (sign-in, security, fraud prevention) and optional analytics/marketing cookies (with your consent where required). Manage preferences via our banner or your browser.
- We don't sell personal information and don't track you across unaffiliated websites for third-party targeted advertising.
11) The CCTV programme (extra transparency)
- Operating window: resident live view at any time; person alerts 23:00–04:00 by default (adjustable on request).
- Access controls: live-view only (no timeline, no export, no PTZ) for residents. All activity is logged. Misuse leads to removal and may be reported to the Regulator/PSiRA (if applicable).
- Placement & masking: cameras on private property view public streets/sidewalks; permanent privacy masks prevent filming into private areas.
- No audio & no facial recognition. AI may classify events (person/vehicle) without biometric identification.
- Signage: entry-point signs state purpose, Responsible Party/Operator, retention, and IO contact. Sample sign text is available on request.
12) Requests for CCTV footage
Residents do not receive direct exports. Where legally justified, exports are performed by the Information Officer (or authorised delegate) on written request with sufficient particulars (e.g., date/time, location, incident description, SAPS case number). We may refuse or redact where disclosure would violate rights of others or legal restrictions.
13) Children & vulnerable persons
Our services are intended for adults. Resident access is limited to persons 18+. We do not knowingly allow minors to use the live-view service. Camera placement and masking aim to minimise intrusion.
14) Impact assessments & governance
We conduct proportionate risk/impact assessments (DPIA-style) for CCTV deployments, covering necessity, proportionality, risks, and mitigations (e.g., masking, retention, access limits, signage). A summary may be provided to partners on request.
15) Complaints & regulatory contacts
Information Officer
Ian Jansen van Rensburg • ian@ghosthome.co.za • +27 79 495 0855
Information Regulator (South Africa)
Website: inforegulator.org.za • Tel: 010 023 5200 • Toll-free: 0800 017 160 • Email: enquiries@inforegulator.org.za
Address: Woodmead North Office Park, 54 Maxwell Dr, Woodmead, Johannesburg, 2191
16) Changes to this notice
We may update this notice from time to time. We'll change the "Last updated" date above and, if material changes are made, notify you via the website or email.