POPIA Statutory Privacy Policy & Biometric Governance

1. Responsible Party vs. Operator Designation

Under Chapter 1 of POPIA:

• The Mining Enterprise (Responsible Party): The subscribed mining group determines the purpose of collecting workforce personal information, medical surveillance records, shift rosters, and lamp-room biometrics for mine safety and DMRE reporting.
• TVB Network (Operator): Acts strictly as an Operator processing encrypted data on behalf of the mining enterprise through isolated Google Cloud BigQuery and dedicated MySQL functional shards.

2. Special Personal Information & Biometric Telemetry (POPIA S26 & S32)

To enforce statutory underground descent safety, shaft muster headcount, and prevent identity fraud, MineCore processes Special Personal Information under POPIA Section 26:

• Biometric Facial Landmarks: Mathematical vector hash representations collected at the lamp-room turnstile station (confidence score threshold 0.98). Raw facial photographs are never permanently stored without explicit consent.
• RFID Tag Telemetry: Hard hat and lamp-battery RFID beacon tags logged upon entry and egress from the shaft head.
• Medical Fitness Records (MHSA S13): Red/Amber/Green certificate of fitness expiration tracking (Annexure 3) for underground work clearance.
• GPS Geofence Telemetry: Latitude and longitude coordinates logged during shift clocking to verify physical presence within the concession perimeter.

3. Purpose of Processing (POPIA S13)

All data captured in MineCore is processed strictly for legitimate mining operational purposes:

1. Statutory compliance with the Mine Health and Safety Act (Act 29 of 1996) and mandatory DMR/DMRE statutory returns.
2. Emergency underground muster board reconciliation and blast clearance verification.
3. Calculation of shift punctuality, overtime, hazard pay allowances, and BCEA Section 34 compliant disciplinary deductions.
4. Tracking maintenance telematics for yellow plant machinery and heavy haulage vehicles.

4. 30-Day Statutory Account Deletion Governance (POPIA S14)

• Compliance Status: Submitting a deletion request transitions the concession to pending_deletion and schedules permanent purge for exactly +30 days.
• Self-Service Cancellation: Concession administrators may reverse the deletion request at any point during the 30-day period via the Danger Zone console.
• Irrevocable Purge: Once the 30-day cooling-off period elapses, all 14 operational database shards (biz_<clientId>) are permanently dropped from Google BigQuery and MySQL storage.

5. Data Subject Rights & Data Portability (POPIA S14 & S24)

Mining employees and concession administrators maintain statutory rights to:

• Access Personal Records: Request confirmation of what personal information is held on the concession roster.
• Correction of Records: Correct erroneous medical expiration dates, contact telephone numbers, or shift assignments.
• Full Operational Export: Concession owners may download a comprehensive JSON operational archive (/company/export) containing complete historical logs across all 14 database shards, or export targeted CSV files for workforce, clock logs, and production.

6. Information Officer Contact

For POPIA inquiries, data subject access requests, or regulatory privacy audits, contact our designated Information Officer: