Unified Privacy AND DATA PROTECTION NOTICE
At Fraser Alexander (“FA”) is committed to respecting your privacy and protecting your personal information (personal data). Safeguarding the information entrusted to FA is central to FA’s values and is essential to maintaining the trust of stakeholders.
This Unified Privacy and Data Protection Notice (“Notice”) explains how FA processes personal information when individuals engage with FA through FA’s digital platforms, physical locations or any part of FA’s global operations. Because FA operates across multiple jurisdictions, this Notice is designed to apply internationally, with local variations where required by applicable law.
For purposes of this Notice, “processing” refers to any activity involving personal information, including its collection, storage, use, transfer or deletion.
WHO CONTROLS YOUR PERSONAL INFORMATION
FA is made up of several legally registered entities. Each entity may act as an independent responsible party (controller) depending on the nature of the interaction.
Global Headquarters (Primary Contact Point)
Fraser Alexander (Pty) Ltd
19 9th Street, Building 2, 2nd Floor, Suite 3
Houghton Estate, Rosebank
Johannesburg, South Africa
Tel: +27 11 929 3600
Email: infosec@fraseralexander.com
Group Entities
The FA Group comprises multiple entities that operate in different jurisdictions. Each entity is responsible for complying with the applicable local privacy and data-protection laws. A full and current list of FA entities and regional contact details is available on request.
FA maintains a coordinated global privacy function to promote Group-wide standards, although this does not replace the accountability of each individual responsible party (controller).
PERSONAL INFORMATION WE COLLECT
The personal information FA collects depend on the individual’s relationship with FA and the context of the interaction. The categories below provide a general overview of the types of information FA may process.
Identifiers and Contact Details: FA may collect basic identifiers and contact information such as names, contact details and, where required, identification numbers, as well as professional information relevant to engagement with FA.
Digital and Technical Information: When FA’s digital platforms are used, FA may collect technical information related to devices, system settings and interactions with FA’s websites or online services, including information obtained through cookies and similar technologies.
Operational, Security and Safety Information: For operational, safety and security purposes, FA may process information such as access records, CCTV footage, location-related information where appropriate and biometric information where legally permitted.
Human Resource and Workforce Information: If an individual engages with FA as an employee or job applicant, FA may process information necessary for recruitment, employment, payroll, performance management, development and workplace health or safety requirements.
Financial and Transactional Information: Where relevant to a business relationship, FA may process financial or transactional information required to facilitate payments, procurement activities or other contractual arrangements.
Media and Communication Information: FA may process photographs, video recordings and other media arising from FA operations or events, as well as information provided through surveys, feedback or other communication channels.
Where the provision of personal information is mandatory due to legal or operational requirements, FA will inform individuals accordingly and explain any implications of not providing such information.
HOW WE COLLECT PERSONAL INFORMATION
FA collects personal information through digital platforms including its website, online services, newsletter subscriptions and digital submissions used to support internal processes or external interactions. FA also collects personal information through physical interactions at FA premises, including during employment processes, security procedures such as CCTV and access control, and other direct engagements where personal information may be required.
WHY WE PROCESS PERSONAL INFORMATION
FA processes personal information only as permitted by applicable law, for purposes that are necessary, reasonable and relevant to FA operations. The subsections below outline the primary purposes for which FA processes personal information.
Service Delivery and Operations: FA processes personal information to provide, maintain and improve FA’s services, and to support stakeholder relationships and operational engagements necessary for FA’s organisational activities.
Safety, Security and Compliance: FA processes personal information to ensure the safety and security of FA’s sites, including through access controls and monitoring systems. FA also processes information as necessary to comply with statutory, regulatory and operational requirements.
Employment and Human Resource Management: For individuals engaged with FA in a workforce capacity, FA processes personal information to support recruitment, onboarding, remuneration, performance management, development and other legitimate human-resources functions, as well as compliance with labour, health and safety obligations.
Contractual and Legal Purposes: FA processes personal information where necessary to fulfil contractual obligations, administer agreements and support FA’s governance, audit and legal responsibilities. This includes processing required to meet internal, statutory or regulatory requirements.
Communication and Engagement: FA processes personal information to share operational or service-related updates and to support engagement activities such as surveys, feedback processes or other interactions aimed at improving FA’s services or stakeholder experiences. FA does not share personal information for marketing purposes without a lawful basis or, where required, explicit consent.
Legal Bases for Processing: Depending on the context and jurisdiction, FA may rely on various legal bases for processing. These may include consent, the performance of a contract, compliance with legal or regulatory obligations, the protection of vital interests or FA’s legitimate interests, provided such interests are balanced against the rights of individuals. Processing may also occur on any other basis permitted under applicable law.
CROSS-BORDER TRANSFERs
As a global organisation, FA may transfer personal information between FA entities or to trusted third parties located outside the country where the information was collected. These transfers occur only where appropriate safeguards are in place to ensure adequate protection of personal information. Safeguards may include Intra-Group Data Transfer Agreements, Standard Contractual Clauses, binding corporate rules or contractual commitments requiring equivalent protection standards
SHARING OF PERSONAL INFORMATION
FA may share personal information with operators (processors) that perform services or functions on FA’s behalf, including information and technology service providers, professional advisers or contractors. FA may also share personal information with regulatory bodies or law-enforcement agencies where legally required, or with other FA entities where necessary for legitimate business purposes. All operators are contractually required to implement appropriate security and confidentiality measures. FA does not sell personal information.
SECURITY SAFEGUARDS
FA implements a combination of technical, organisational and physical measures to protect personal information from unauthorised access, loss, misuse or disclosure. These measures include access controls, authentication mechanisms, cybersecurity practices, secure-storage protocols, physical-security measures and regular privacy and security awareness training. In the event of an incident involving personal information, FA will follow its incident-response procedures and notify affected individuals and the Information Regulator (or equivalent supervisory authority) where required by law.
RETENTION OF PERSONAL INFORMATION
FA retains personal information only for as long as necessary to fulfil the purposes for which it was collected or as required by legal, regulatory, contractual or operational obligations. When personal information is no longer required, FA securely deletes, anonymises or archives it in accordance with FA’s retention and disposal procedures.
YOUR PRIVACY RIGHTS
Depending on applicable law, individuals may have rights relating to personal information, including the right to access, correct, delete or de-identify personal information; the right to object to or restrict processing; the right to withdraw consent where processing is based on consent; and the right to object to direct marketing.
Individuals may also have the right to request the transfer of personal information to another party (data portability) and to lodge a complaint with the Information Regulator or an equivalent supervisory authority. Requests may be submitted to infosec@fraseralexander.com, and identity verification may be required.
UPDATES TO THIS NOTICE
This Notice may be updated periodically to reflect legal developments, operational changes or enhancements in our privacy and data-protection practices. Updated versions will be published on our website, and the “last updated” date will be revised accordingly.
Last updated: November 2025
Version: 3.0
CONTACT US
Questions, concerns or requests relating to this Notice or FA’s processing of personal information may be directed to:
Global Privacy Office
Email: infosec@fraseralexander.com
Telephone: +27 11 929 3600
Postal address: Fraser Alexander (Pty) Ltd, Global Headquarters
A full list of FA group entities and their contact details is available on request
