Public Document · POPIA s18 · PAIA s51

Privacy Statement

Community Development Initiatives International NPC
Reg. 2012/201981/08  |  PBO 930 041 456  |  IR Reg. 2025-008244
Reference: CDII/PS/2026/001  |  Version 3.4  |  Effective: 16 June 2026
Plain Language Commitment. This Privacy Statement is written in plain language. If any term is unclear, contact our Information Officer before providing personal information. You should never feel pressured to share data without understanding how it will be used.
Information Officer: Louw Allan  ·  information.officer@wemindfoundation.co.za  ·  +27 83 399 9911

1. Who We Are

Community Development Initiatives International NPC (CDII) is a South African non-profit company focused on education, skills development, enterprise development, and community upliftment programmes. CDII operates We MiND Foundation as a division and delivers programmes through www.wemindfoundation.co.za.

Full legal nameCommunity Development Initiatives International NPC
Registration2012/201981/08
SARS PBO930 041 456
SARS Tax Reference9162706189
IR Registration2025-008244
Registered address02 Hotel Road, Cullinan 1000, Tshwane, Gauteng
Information OfficerLouw Allan (Johannes Lodewikus Allan)
Deputy IODonald Bernard Leffler (designated under POPIA s17(1))
IO emailinformation.officer@wemindfoundation.co.za
IO telephone+27 83 399 9911

2. Scope

This statement applies to all personal information processed by CDII in connection with education, skills development, enterprise, and community programmes; donor and partner relationships; our websites; and administrative, governance, and compliance functions. It applies to all data subjects: programme participants, staff and volunteers, directors, donors, service providers, and website visitors.

3. Information We Collect

CategoryTypes of InformationHow Collected
Programme participantsName, ID/passport, contact details, educational history, assessment data, digital signatures, photographs, cultural preferencesRegistration forms, assessment submissions, facilitator records
Staff & volunteersName, contact details, employment records, bank details, tax referencesEmployment contracts, HR records
DirectorsName, appointment date, contact details (ID numbers held internally, not published publicly)MOI, CIPC filings
Donors & sponsorsName, organisation, contact details, donation recordsDonation forms, correspondence
Website visitorsIP address, browser type, pages visited, time and date, cookie dataAutomatic collection; consent banner for non-essential cookies

4. Lawful Bases for Processing (POPIA s11)

Lawful BasisPOPIAHow CDII relies on this
Consents11(1)(a)Participant data; optional marketing; AI-assisted learning; photography. Consent is voluntary, specific, informed, and withdrawable at any time.
Contractual necessitys11(1)(b)Fulfilling obligations under programme enrolment, employment, and partnership agreements.
Legal obligations11(1)(c)PAIA, POPIA, Companies Act, Income Tax Act, SARS PBO requirements, SETA/QCTO/SAQA obligations.
Legitimate interestss11(1)(f)Programme quality assurance, fraud prevention, security, governance and audit — balanced against data subject rights.
Vital interestss11(1)(d)Health or emergency contact information where safety is at risk and consent cannot be obtained.
Public interests11(1)(e)Community development research where processing serves broader public benefit and meets ethical standards.

5. Purposes of Processing

We collect and use personal information only for: delivering and administering education, training, and skills development programmes; assessing learners and issuing certificates; managing donor relationships; fulfilling statutory obligations; operating digital platforms and AI-assisted tools; communicating programme updates where you have consented; conducting anonymised research; and safety, security, and fraud prevention. We will not use your information for any incompatible purpose without fresh consent or a new lawful basis.

6. Artificial Intelligence and Automated Processing (POPIA s71)

AI Use Disclosure. CDII's digital platforms may incorporate AI tools to provide personalised learning pathways, generate educational content, analyse assessment data, and assist with programme administration. All AI-generated outputs that affect a participant are reviewed by a qualified CDII professional before being actioned. No significant decision about you — such as assessment outcomes, certification, or programme eligibility — is made solely by automated means without human oversight.

You have the right under POPIA s71 to request that any automated decision affecting you be reconsidered by a human being. Contact our Information Officer to exercise this right.

7. Children's Personal Information (POPIA s35)

Children's Data. CDII does not intentionally collect personal information from persons under 18 without written consent of a parent or competent person as defined in POPIA s1. If you believe a minor's data has been provided without appropriate consent, contact our Information Officer immediately.

8. Sharing Your Information

We share personal information only where necessary. We do not sell your personal information and do not share it with third parties for their own marketing purposes.

RecipientPurposeSafeguards
SETA / QCTO / SAQALearner registration, certificationStatutory obligation (s11(1)(c))
SARS / CIPCTax compliance, NPC statutory reportingStatutory obligation
We MiND FoundationJoint programme deliveryPartnership agreement; consent where required
Auditors / legal advisersFinancial audit, legal complianceWritten confidentiality agreement
Technology providersPlatform hosting, AI tools, IT supportData processing agreements; POPIA-compliant contracts
Information RegulatorPOPIA / PAIA compliance; breach notificationStatutory obligation
Employers (participants)Learner progress reportingParticipant's prior written consent only

9. Cross-Border Transfer (POPIA s72)

CDII's primary operations and data storage are in South Africa. Where cross-border processing occurs — website hosting via Netlify, Inc. (USA), web font delivery via Google Fonts (USA), and Google Analytics 4 once activated (USA) — CDII ensures POPIA s72 compliance through the provider's standard data processing terms, supplemented by a written data processing agreement where personal information is involved. See the Cookie Policy for full details of each third-party service.

10. Data Retention (POPIA ss14–15)

CategoryRetention PeriodAuthority
Programme / training records5 years from completionSAQA Act; QCTO regulations
Assessment records7 years from date of assessmentSAQA Act; SETA accreditation requirements
Financial records (donations, invoices)7 yearsIncome Tax Act s73; Companies Act s24
Employment records3 years post-employment (minimum)Basic Conditions of Employment Act; SARS requirements
Website visitor logs12 months, then anonymisedLegitimate interests; security audit requirements
Consent records3 years from last interactionPOPIA s11; burden of proof requirements

11. Security

We implement appropriate technical and organisational measures to protect personal information against unlawful access, loss, destruction, or damage. In the event of a data breach affecting your rights and interests, we will notify the Information Regulator within 72 hours and notify you as soon as reasonably practicable.

12. Direct Marketing

We send marketing communications only to persons who have consented (new contacts) or where an existing relationship permits (current participants — POPIA s69(2)). You may opt out at any time by replying UNSUBSCRIBE to any email, or by contacting the Information Officer. Opt-out is actioned within 5 business days.

13. Your Rights Under POPIA

RightPOPIAHow to exerciseOur response
Accesss23Written request to IO; PAIA Form 2 required; R140 request fee (no exemption for personal records — GG 45057)Within 30 days (extendable by 30 days)
Correction / deletions24Written request to IOCorrect inaccurate or delete unlawfully held information within 30 days
Object to processings11(3)Written objection to IOStop processing unless overriding legitimate ground demonstrated
Withdraw consents26Written notice to IOImmediate effect; does not affect prior lawful processing
Object to direct marketings69Reply UNSUBSCRIBE / STOP, or contact IOActioned within 5 business days
Automated decision reviews71Written request to IOReconsidered by qualified human; outcome within 30 days
Lodge a complaints74Contact Information Regulator directly (see Section 16)IR has jurisdiction — you may complain without approaching CDII first

Submission channels: Email: information.officer@wemindfoundation.co.za  ·  Post: Information Officer, CDII, 02 Hotel Road, Cullinan 1000, Tshwane  ·  Tel: +27 83 399 9911  ·  In person: by appointment

14. Governance and Board Accountability

CDII's Board of Directors has adopted this Privacy Statement and the CDII POPIA Compliance Programme. The Information Officer (Louw Allan) reports to the Board on POPIA compliance matters. The Deputy Information Officer (Donald Leffler) assists and acts in the IO's absence.

15. Updates to This Statement

Reviewed annually or within 30 days of any material change in law, processing activities, IO structure, or a security incident. Previous versions are available from the Information Officer on request.

16. Information Regulator Contact Details

You have the right to lodge a complaint with the Information Regulator of South Africa:

Information Regulator of South Africa
Telephone010 023 5200
Toll-free0800 001 7160
AddressJD House, 27 Stiemens Street, Braamfontein, Johannesburg 2001

Version History

VersionDateSummary
1.016 Aug 2025Initial version
3.01 Jun 2026Full revision: lawful bases table; retention schedule; AI/s71 disclosure; children's data clause; cross-border transfer table; complete IR contact details; Deputy IO designation; plain language commitment
3.11 Jun 2026Removed Hivekeeper references; added www.cdii.org.za as second website
3.21 Jun 2026Both websites added throughout
3.310 Jun 2026Phone corrected to +27 72 7113 277 throughout (CC-01).
3.416 Jun 2026Domain consolidated to www.wemindfoundation.co.za (CDII's own, independently-operated domain); IO/DIO email addresses updated to the @wemindfoundation.co.za standard (CF-113/CF-116). Section 9 (Cross-Border Transfer) rewritten to reflect actual current technical arrangements — Netlify hosting, Google Fonts, and Google Analytics 4 replace the prior generic Cloudflare CDN reference. Current operative version.
Public Document · POPIA s18

Cookie Policy

Reference: CDII/CP/2026/001  |  Version 2.0 — FINAL  |  Effective: 16 June 2026
Information Officer: Louw Allan  ·  information.officer@wemindfoundation.co.za
Final, independent policy. This is CDII's final Cookie Policy for its own website, www.wemindfoundation.co.za, describing exactly what is technically deployed rather than an audit estimate. One implementation step remains outstanding: a cookie consent banner is being built and will be live before Google Analytics begins collecting any data. Until both are in place, no non-essential cookie is set on this website.

What Are Cookies?

A cookie is a small text file placed on your device when you visit a website. Under POPIA, any cookie that can identify you — directly or indirectly — is personal information and must be processed lawfully.

This Policy applies only to www.wemindfoundation.co.za, which CDII registered and operates independently. It does not apply to www.wemindfoundation.com or cdii.org.za — those domains remain on infrastructure controlled by a third party under an unresolved ownership dispute, and CDII cannot certify what cookies that infrastructure deploys.

Cookie Consent Banner

Once implemented, a consent banner will be displayed on your first visit, allowing you to accept all cookies (including Google Analytics), reject all non-essential cookies, or customise by category. Your preference will be stored for 12 months. CDII will not place Google Analytics or any other non-essential cookie on your device until the banner is live and you have made a choice — declining will never prevent you from accessing the content of this website.

Public Document · PAIA s51 · Statutory Requirement

PAIA Manual

Reference: CDII/PAIA/S51/2026/001  |  Version 2.2  |  Effective: 1 June 2026 (revised 16 June 2026)
Head of Private Body & Information Officer: Louw Allan  ·  information.officer@wemindfoundation.co.za

This Manual is published in compliance with section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA), read with the PAIA Regulations, 2021 (GG 45057, 27 August 2021) and the Protection of Personal Information Act 4 of 2013 (POPIA). It describes the records held by Community Development Initiatives International NPC (CDII) and its division We MiND Foundation, the procedure for requesting access, applicable fees, and grounds on which access may be refused.

PAIA s51 — Statutory Requirement
Download the complete signed PAIA Manual
CDII/PAIA/S51/2026/001 v2.2  ·  21 pages  ·  PDF  ·  Revised 16 June 2026
Includes Schedule 1 (Records Classification) and all Annexures
Download PDF

The key operative provisions are summarised below. The downloadable PDF above is the authoritative, complete, signed version as required under PAIA s51. Both are published on www.wemindfoundation.co.za. A printed copy is available on request from the Information Officer.

Automatically Available Records (PAIA s52)

The following records are automatically available and do not require a formal PAIA request:

RecordAccess Method
This PAIA Manual v2.2Download PDF · Summary on this page · www.wemindfoundation.co.za · Hard copy on request from IO
PAIA Form 2 (prescribed request form)Annexure 1 to the full Manual · www.inforegulator.org.za · On request from IO
Privacy Statement v3.4This page · www.wemindfoundation.co.za · On request from IO
Cookie Policy v2.0 FINALThis page · www.wemindfoundation.co.za · On request from IO
NPO/NPC Registration (MOI)Available from CIPC · On request from IO
B-BBEE CertificateOn request from IO
SARS PBO Certificate (PBO 930 041 456)On request from IO
PAIA Annual Report (most recent: April 2026)On request from IO · Submitted to IR eServices portal

Categories of Records Held (PAIA s51)

CDII holds records in the following categories. The listing of a category does not create an entitlement to access — all requests are assessed against the grounds for refusal in PAIA Chapter 4.

CategoryExamples
Corporate & governanceMemorandum of Incorporation; Board resolutions; director appointments; CIPC filings; minutes of meetings
Financial recordsFinancial statements; bank records; donation receipts; invoices; s18A certificates; tax returns
Programme recordsLearner enrolment registers; assessment records; certificates issued; SETA submissions; training registers
Staff & HR recordsEmployment contracts; payroll records; leave records; disciplinary files; skills development plans
PAIA & POPIA recordsPAIA access requests and responses; POPIA consent records; incident reports; IO correspondence
CorrespondenceProgramme communication; donor correspondence; government and regulatory correspondence
Website & digital recordsWebsite logs; cookie consent records; digital platform access logs
SmartCommute™ programmeProgramme Participation Agreements; Disbursement Notices; Employee Acceptance Forms; payroll records; s18A certificates; B-BBEE SED letters

How to Request Access to Records

Download complete PAIA Manual v2.2 (PDF, 21 pages)  — includes PAIA Form 2 as Annexure 1.

To request access to a record, submit a written request using PAIA Form 2 (prescribed form under Regulation 4 of the PAIA Regulations, 2021). The form is available from the Information Officer on request.

Submit your PAIA request to
Information OfficerLouw Allan (Johannes Lodewikus Allan)
Telephone+27 83 399 9911 (business hours)
Postal addressInformation Officer, CDII, 02 Hotel Road, Cullinan 1000, Tshwane, Gauteng
Head of Private BodyLouw Allan (simultaneously Head of Private Body under PAIA s1 and IO under POPIA s55)

We will respond to PAIA requests within 30 days (extendable by 30 days where necessary, with written notice). PAIA access requests and POPIA rights requests are separate processes with different procedures and fees.

Fees

Important — No personal requester exemption. CDII is a private body. The personal requester exemption (previously allowing data subjects to receive their own records without a request fee) was abolished by the PAIA Regulations, 2021 (GG 45057, 27 August 2021). A R140 request fee applies to all PAIA requests to CDII, including requests for your own information. CDII is not a registered VAT vendor — VAT does not apply to PAIA fees.
Fee typeAmountNotes
Request feeR140.00Payable before the request is processed. No exemptions — applies to all requesters including data subjects requesting their own records (GG 45057). No VAT applies.
Access feePer prescribed scheduleCharged on granting access — covers reproduction and search costs. Current schedule: GG 45057, 27 August 2021. See Annexure 2 of the full Manual.
DepositUp to 1/3 of estimated access feeRequired where estimated search time exceeds 6 hours or access fee likely to exceed R600. Must be paid before processing continues.
Fee waiverAt IO discretionThe IO may waive or reduce fees where payment would cause the requester financial hardship. A written application for a waiver may be submitted with the request.
POPIA rights requestsNo chargePOPIA rights requests (correction, deletion, objection, consent withdrawal) are processed at no charge. These are entirely separate from PAIA access requests.

Grounds for Refusal of Access (PAIA Ch.4)

GroundPAIAMandatory / Discretionary
Protection of third-party personal informations63Mandatory — IO has no discretion
Protection of commercial information of a third partys64Mandatory
Protection of confidential information of a third partys65Mandatory
Protection of safety of individuals or propertys66Mandatory
Records privileged from production in legal proceedingss67Mandatory — applies to legal professional privilege
Commercial information of CDII itselfs68Discretionary — IO may still grant access
Research informations69ADiscretionary — IO may still grant access
Record cannot be found or does not exists56(3)IO must certify in writing
Public Interest Override (PAIA s70). The IO will apply the public interest override where refusal would conceal evidence of substantial contravention of the law or an imminent and serious public safety or environmental risk, and where the public interest in disclosure clearly outweighs the harm contemplated. If a request is refused, the IO must provide adequate reasons and inform the requester of the right to complain to the Information Regulator (PAIA s78).

Complaint to the Information Regulator

If you are dissatisfied with our response to a PAIA request, you may lodge a complaint with the Information Regulator at PAIAComplaints@inforegulator.org.za or contact the IR using the details in Section 16 of the Privacy Statement.