1. Introduction

This is the privacy statement of Harvard Global Research Support Centre South Africa NPC (HG SA), located at 22 Bree Street, Cape Town, 8000, Republic of South Africa. This privacy statement describes the processing of personal information by HG SA under the Protection of Personal Information Act as it may be amended from time to time (POPIA).

The terms “consent,” “data subject,” “operator,” “personal information,” “processing,” and “responsible party,” which appear in this privacy statement, are defined in POPIA.

HG SA hosts program activities carried on in South Africa by the Africa Research Center of Harvard Business School (HBS ARC) and by the Center for African Studies of Harvard University Africa office (CAS Africa). HG SA also from time to time hosts other South Africa activities related to Harvard University.

2. Description of Personal Information Collected and Processed

HBS ARC Programs

HG SA, though its HBS ARC programs, collects and processes personal information as an operator for Harvard Business School, a part of Harvard University, Boston, Massachusetts USA, in connection with academic research, and as a responsible party in connection with HBS ARC sponsored events.

HG SA, through its HBS ARC program, primarily collects personal information in the course of academic research on businesses and economic activity in South Africa and Africa-wide. This data may be obtained from public sources and directly through interviews with data subjects.

Data subjects may include executives and employees of businesses and other organizations which are the subjects of the research. The personal information collected in the course of research may be published in case studies and informational newsletters.

In its HBS ARC program, HG SA may also collect personal information from individuals who wish to attend and participate in HBS ARC events such as seminars, conferences, workshops and alumni events. This information is collected directly from the individuals for event registration and further communications of interest to registrants, as well as in connection with promoting, organizing and hosting events.

HG SA’s HBS ARC program often receives personal information about students recently accepted to Harvard Business School from African countries and communicates with them to offer matriculation information and to answer questions. The program may also do the same with information on students from South Africa recently accepted to Harvard College.

The types of data may include:

  • name, contact information, employer and job title
  • date and place of birth
  • educational and career information
  • information on present work responsibility
  • other business information
  • other personal information volunteered by data subjects
  • images (video of interviews, other imaging)

This personal information may be shared by HG SA’s HBS ARC program within HG SA and with the following parties for the purposes stated above:

  • offices of Harvard Business School and Harvard Business School faculty, in Boston, Massachusetts USA
  • Harvard Business School Publishing -
  • other Harvard University schools and offices
  • Harvard Business School alumni organizations -
  • the advisory board of HBS ARC
  • as also stated below

CAS Africa Programs

HG SA, through its CAS Africa program, collects and processes personal information both as a responsible party and, for some purposes, as an operator for Harvard University schools and programs.

In its CAS Africa program, HG SA processes personal information for the following purposes:

  • recruiting and assessing candidates from South Africa with higher education degrees to participate in annual fellowship programs at Harvard University
  • recruiting and assessing high school students from South Africa to participate in an annual summer education program at Harvard University
  • promoting, organizing and hosting CAS Africa and other South Africa conferences, webinars, workshops and other events
  • connecting with Harvard University alumni

Data subjects may include:

  • candidates for and participants in fellowship programs and high school summer programs
  • alumni 
  • participants in and attendees at events

Types of data vary from program to program, but may include:

  • name, contact information such as mailing address, email address, telephone number (parents’ contact information for high school students)
  • date of birth, citizenship
  • educational background, degrees, transcripts
  • current employer and employment history
  • South Africa ID copy when needed for travel arrangements and confirmation of citizenship
  • travel itineraries
  • financial information if financial aid has been requested
  • medical information when volunteered as needed for arranging travel, health insurance or accommodations
  • gender
  • Harvard University graduation year of alumni
  • other personal information volunteered by data subjects
  • photos

This personal information may be collected as follows:

  • directly from program candidates, or from persons assisting program candidates 
  • directly from persons registering to attend CAS Africa events
  • from other academic institutions participating in the organization of events
  • from Harvard University and CAS Africa alumni records
  • from publicly available sources

This personal information may be shared by HG SA’s CAS Africa program within HG SA and with the following parties for the purposes stated above:

  • the office of the Center for African Studies at Harvard University in Cambridge, Massachusetts USA, and other Harvard University offices and schools
  • with respect to event information, any institutions collaborating in the event 
  • as also stated below

Other HG SA Programs

From time to time HG SA supports other local and third-country affiliates of Harvard University and may process data, including names, other identity information, photos of minors for program marketing and reporting to donors, contact information, educational information, travel itineraries, and medical information when volunteered as needed. 

Other HG SA Data Uses and Sharing

HG SA may process or share personal information, including communicating data to government authorities, as necessary for preventing, investigating, providing notice of, or taking other action concerning fraud, unlawful or criminal activity, other misconduct, security or technical issues, or unauthorized access to or use of personal information or HG SA’s website or data systems; responding to subpoenas, court orders, or other legal process; managing and enforcing HG SA agreements; protecting the health, safety, rights or property of HG SA and its personnel, program personnel, program participants, Harvard University, and others; and meeting other legal obligations.

HG SA may also engage service providers to assist in processing of personal information for the purposes described above. Our service providers will have contractual commitments to safeguard the privacy and security of personal information. (In engaging service providers, HG SA will obtain names and contact information of their personnel.)

HG SA does not sell personal information to third parties.

3. Legal Bases for The Processing Of Personal Information

Where it acts as responsible party, HG SA processes personal information for the purposes described above on the basis of its legitimate interests; to carry out requests of or agreements with data subjects; to carry out agreements with Harvard University for the benefit of data subjects; to satisfy its legal or regulatory obligations; or, where applicable, on the basis of legally compliant data subject consent or the consent of a competent person where the data subject is a minor.

4. International Data Transfers

Data subject personal information may be transferred from South Africa to the United States and other countries, for example, to other academic institutions in connection with events. These countries may provide for data protection rules that differ from POPIA. Transfers of personal information from one country to another (or one geographic region to another) will be completed in accordance with paragraph 3 of this privacy statement and POPIA.

5. Security of Personal Information

HG SA has taken appropriate technical and organizational measures to provide a level of security for the personal information appropriate to the risk. Unfortunately, however, no data transmission, processing, sharing or storage by any party can be guaranteed to be completely secure.

6. Duration of Personal Information Retention

Personal information will be kept for the period necessary for the performance of the purposes described above and to achieve lawful purposes related to HG SA’s activities, and may also be kept to the extent legally permitted for the archival and statistical records of HG SA.

7. Data Subject Rights

To the extent required by and in accordance with POPIA, HG SA will provide a data subject, upon the data subject’s reasonable, good faith request, with information about whether HG SA holds any of the data subject’s personal information as a responsible party. If HG SA holds such personal information as a responsible party, then upon the data subject’s request, HG SA will provide a record or description of the personal information, including a description of the categories of third parties who have access to the information.

To the extent required by and in accordance with POPIA, a data subject may also request HG SA as the responsible party:

  • to correct or delete personal information that is inaccurate or otherwise misleading, or unlawfully obtained; or
  • to destroy or delete personal information that HG SA is no longer authorized to retain under applicable law.

A data subject may object to further processing of personal information where the personal information has been processed based on the legitimate interest of HG SA, provided that the objection is based on reasonable grounds relating to the data subject’s particular situation. A data subject may also object to processing of personal information by HG SA for purposes of direct marketing.

If HG SA processing of personal information is solely based on consent, a data subject also has the right to withdraw consent to the processing, subject to certain limitations at law.

If a data subject request results in cessation of processing, HG SA thereafter might not be able to provide the data subject with all (or any) of the related services.

In certain cases, HG SA may continue to process personal information after the data subject has withdrawn consent or requested that HG SA delete personal information or otherwise objected to processing, if HG SA has a legal basis to do so, for example, if the data is still needed to comply with a legal obligation or to pursue or enforce HG SA’s legal rights.

To submit a request, a data subject may contact HG SA by sending an email message to notices@harvardglobal.org. HG SA and a relevant unit of Harvard University will often cooperate on the response. To avoid taking action regarding a data subject’s personal information at the direction of someone other than the data subject, data subjects will often be asked for information verifying their identity.

HG SA will respond to such data subject requests in a reasonable time, in accordance with the procedures stated in POPIA. Data subjects may lodge complaints about HG SA’s response, or other complaints about HG SA’s processing of their personal information, with the South Africa Information Regulator:

JD House
27 Stiemens Street
Braamfontein
Johannesburg
South Africa
2001

POPIAComplaints.IR@justice.gov.za.

8. Information Officer

The Director of HG SA is HG SA’s Information Officer.

9. Statement Date; Changes

This privacy statement was last updated as of: 31 May 2024. This privacy statement may be amended from time to time in accordance with changes in the data practices of HG SA or applicable law.