South Africa: The revised CBA Code of Conduct and Its Impact on Credit Bureaus

Fox Rothschild LLP

Fox Rothschild LLP

The Credit Bureau Association of South Africa has issued a code of conduct for the processing of credit information under the Protection of Personal Information Act, No.4 of 2013 (POPIA).

Here is an analysis I wrote for OneTrust DataGuidance, which may be helpful for GDPR, CPRA, CPA and CDPA.

Key points:

  • Purpose limitation: Personal information which is processed for credit purposes will not be further processed in a manner that is incompatible with the original purpose for processing. The issues of compatibility between direct marketing and credit rating were also recently raised by a complaint filed by
  • Disclosure: Provide detailed privacy disclosure.
  • Data Subject rights must be honored.
  • Security safeguards and accountability program.

The code also distinguishes between the obligation of the credit bureau when collecting directly from individuals or as an operator (processor) for a credit provider.

[View source.]

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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