POPIA & Commercial Confidentiality

Construction Data Privacy & POPIA Policy

Statutory privacy policy governing the protection, processing, and confidentiality of site worker personal information, subcontractor compliance records, and architectural project data under the Protection of Personal Information Act (POPIA Act 4 of 2013).

Licensor: TVB Network (Pty) Ltd POPIA Role: Section 21 Operator Effective Date: 1 January 2026 Location: Johannesburg, South Africa

CONSTRUCTION SITE DATA GOVERNANCE BuildPro processes site worker biometric clock-ins, national identity numbers, medical fitness certificates (Annexure 3 OHS), subcontractor COIDA certificates, and tender financial estimates. The contracting firm serves as the statutory Responsible Party, and TVB Network operates strictly as the Operator (Section 21 POPIA) executing instructions within encrypted BigQuery operational tables.

1. Categories of Construction Data Processed

BuildPro collects and processes only information strictly necessary for construction ERP operations:

Site Workforce Data: Full names, South African ID or passport numbers, certified trades (e.g. bricklaying, rigging, electrical), OHS medical certificates of fitness, and emergency contact details.
Subcontractor Business Records: CIPC registration numbers, CIDB registration numbers, SARS Tax Compliance Status PINs, COIDA Letters of Good Standing, and B-BBEE verification affidavits.
Project Commercial Records: Bills of Quantities (BoQ) unit rates, subcontractor payment claims, JBCC payment certificates, material delivery notes, and site diary photographs.
Site Geolocation Telemetry: GPS coordinates captured exclusively at the instant of mobile clock-in or material dispatch confirmation.

2. Commercial Pricing & Tender Confidentiality

2.1. Tender Rate Secrecy: TVB Network treats all contractor BoQ pricing, supplier unit rates, markup percentages, and tender estimates as trade secrets. TVB Network will never aggregate, publish, benchmark, or sell contractor rate sheets to competing construction entities.

2.2. Tenant Sharding: All project data is stored in isolated client tables (biz_<clientId>) preventing cross-tenant visibility or multi-contractor data leakage.

3. Site Worker & Subcontractor Rights

Contractors must ensure that laborers and site personnel are informed that their attendance and qualification data is recorded digitally for payroll and statutory OHS compliance. Site personnel may exercise their rights of access and rectification under Sections 23 and 24 of POPIA through their contracting employer.

4. Statutory Record Retention

Pursuant to the Basic Conditions of Employment Act (BCEA) and OHS Construction Regulations:

Site employee attendance records and timesheets must be retained for at least three (3) years.
OHS safety file documentation and Section 24 incident reports must be archived for a minimum of five (5) years.
JBCC/GCC contract records and tax invoices must be retained for five (5) years per the Tax Administration Act.

5. Information Officer Contact

For inquiries regarding BuildPro privacy architecture, cloud security, or POPIA data subject requests:

Information Officer — TVB Network (Pty) Ltd:
Email: privacy@tvbnet.co.za / popia@buildpro.co.za
Location: Johannesburg, Gauteng, South Africa