Privacy Notice

BAT Group South African Entities – External Privacy Notice

1. Introduction

  • At British American Tobacco (“BAT”) we collect a variety of information about people we interact with, as part of our business and may use it in many different ways. We are committed to ensuring that your personal information is protected and never misused.
    • In this Privacy Notice, "BAT", "us", "we" or "our" means the BAT group company or companies who are responsible for personal information collected about you in the Republic of South Africa (“RSA”), having their registered address at Waterway House South, 3 Dock Road, V&A Waterfront, Cape Town, South Africa, 8001 and which include:
    • British American Tobacco South Africa (Pty) Ltd
    • British American Tobacco East and Southern Africa (Pty) Ltd
    • Twisp (Pty) Ltd
  • If you are an online consumer and want to know how your information is being processed, then please contact us at ESADataPrivacy@bat.com and we will direct you to the correct website and privacy notice.
  • If you are a current or former employee, contractor or another staff member of BAT (such as a trainee or secondee) then please note that this Privacy Notice does not apply to you. Please contact us at ESADataPrivacy@bat.com and we will direct you to where you can obtain the privacy notice.
  • We may amend this Privacy Notice from time to time, so please ensure to check back regularly.

2. Data Subjects with Business Relationships with BAT

At BAT, we need some information about you, such as your name, job title,registration numbers, bank details, tax details and contact details so we can work with you to manage the contract and relationship for the goods or services you supply to us, or we supply to you.  In addition, as part of managing the business relationship, we may be legally required to conduct ‘know your customer’, or similar compliance screenings on you. In doing so we will use the information listed below. In the context of conducting compliance screenings, we will also check the personal information provided to us against public information.

Why do we hold your information What type of information? How legally can we use your information?
To contact you in order to manage the contract and business relationship with either you. Name, contact information (e.g. email address, telephone number) In order to perform our obligations under contract or take steps prior to entering into a contract.
To comply with all statutory and regulatory requirements within the jurisdictions within which we operate (including those relating to bribery and corruption, money laundering and sanctions) when engaging with third parties.

Name, contact information, financial information, such as creditworthiness, bank account details, specimen signature; and

In the case of certain key individuals: KYC (know your customer) and KYS (know your supplier) records, such as passport details, identity documentation, identification number, date and place of birth, nationality, relationships with public officials, or allegations of criminal conduct.

To comply with Legal obligations to which BAT is subject and in order to perform our obligations under contract or take steps prior to entering into a contract
  Personal information relating to criminal allegations, proceedings or convictions; and political opinions To comply with regulatory requirements relating to unlawful acts to which we are subject, including but not limited to the bribery and sanction laws.

 3. A candidate or job applicant

We process the information you provide in your curriculum vitae, in our application form and supporting documentation/information you provide during the recruitment process.

Why do we hold your information What type of information? How legally can we use your information?

We use your information about you to ensure that we can respond to any queries and contact you if you request us to do so, for storing your details (and updating them when necessary) on our database and to enable you to submit your CV for general applications, to allow you to apply for specific jobs, so that we can contact you in relation to job opportunities or respond to any query you have asked us to answer, research that we conduct for statistical purposes.

We may also screen your CV prior to considering your application further.

  • Name;
  • your email address and contact details;
  • your country/city of residence;
  • information in relation to your background;
  • education history;
  • interview notes and any assessment results;
  • Images and recordings of any video interviews (if relevant);
  • employment history,
  • vocation/profession; and
  • extra information that you choose to tell us.

To pursue the legitimate interests we have. For example, it is in our legitimate commercial interest to be able to consider your details as a candidate to ascertain if you are the correct person for the role.

We may check your identity to comply with a legal obligation such as establishing your right to work in the country.

4. Emergency Contacts or those named to receive benefits by a BAT employee

This section of the Privacy Notice applies to you if one of our employees employed by a BAT legal entity has named you as the person we should contact in an emergency or to administer any employee-based benefits.

We only hold information about you (as detailed in the table below) which has been provided to us by a BAT employee to enable us to contact you in emergencies or to administer employee benefits such as healthcare or pensions.

Why do we hold your information What type of information? How legally can we use your information?
To contact you in emergencies relating to the BAT employee(s) that have named you as their emergency contact person Name and contact information. It is in our employees’ legitimate interests for us to be able to contact you in an emergency.
To administer employee benefits that our employee has asked us to take steps to fulfil.

Name and contact information; and

Identification number

This is necessary for us to take steps to perform the benefits contract between the BAT employee and the benefits provider.
To administer employee pension benefits that our employee has asked us to take steps to fulfil. Name and contact information; and

Identification number

This is necessary for us to take steps to perform to comply with our legal obligations (e.g. tax laws) between the BAT employee and the benefits provider.

5. Other individuals who interact with BAT

This section of the Privacy Notice applies to you if you fall within any of the following categories:

  • journalists with whom we communicate in any medium;
  • visitors to our physical premises;
  • individuals and/or businesses who attend or participate in conferences or events in which we are involved;
  • individuals and/or businesses who represent regulatory and law enforcement agencies or other governmental offices; and
  • academics and research professionals; and
  • individuals and businesses who submit information for the purposes of participating in programmes we offer (for example, our Be a Supplier programme).

At BAT, we need some information about you, and will collect and hold the information listed in the table below under ‘What Type of Information’ so we can manage any current or future relationship  we may have with you. We obtain this information either directly from you or from your employer, or from third parties who lawfully provide it to us (including publicly available materials) including the organisers of public events you attend.

Why do we hold your information What type of information? How legally can we use your information?
To contact you in order to manage your relationship with us. Name, contact information (e.g. email address, telephone number, region where you are from) In order to: (1) perform our obligations under contract (in particular: (a) for those individuals who attend, or participate in, conferences or events; or (b) in the context of our relationships with journalists) or take steps prior to entering into a contract; or (2) exercise our legitimate interests in being able to contact you in the context of a current or future business or commercial relationship.
To perform relevant due diligence into publicly available materials relating to you

Name, contact information including the region where you are from

Professional details including your work history, academic history and qualifications, job title, organization, website details (if any), contact details, and area of expertise or speciality

Any publications, articles or publicly available materials you have created

We will either: (1) rely on our legitimate interest in: (a) protecting our business; or (b) in the context of a current or future business or commercial relationship; or (2) seek your consent where appropriate.
To respond to any query that you have asked us.

Name and contact information

Any information that you provide to us in submitting your query through our contact form or to us directly

It is in our legitimate interests to respond to your query and in order to ensure that you have the most up to date information about the BAT business and that any concerns you have relating to BAT are resolved.
To facilitate safe visits to our premises, and to contribute to COVID-19 containment measures.

Name, contact information and potentially questions surrounding your recent whereabouts or contact with those who may have been infected with the COVID-19 virus and body temperature information

Any information that you provide to us relating to your visit.

It is in our legitimate interests to facilitate your visit to our premises. This includes recording your access to our premises, taking steps to help ensure your safety on site, and recording any feedback you provide.

Furthermore, maintaining safe premises and a safe working environment is within our legitimate interests, and is necessary to protect your legitimate interests (and those of others) and to comply with our legal obligations.

Building a professional relationship with you in relation to your attendance at conferences and events that are of mutual interest.

Name and contact information

Records of conferences and events attended

It is in our legitimate interests to process your personal information for the purposes of building our professional relationship with you.
Building current or future professional relationship with you in the context of your work as an academic or research professional.

Name and contact information

Professional details including your academic history and qualifications, job title, organization, website details (if any), contact details, and area of speciality

It is in our legitimate interests to process your personal information for the purposes of developing a current or future professional relationship with you.
To enable you to complete a submission and participate in the programmes we offer and, depending on the programme, building a current or potential future professional relationship with you through your participation in programmes we offer.

Names, contact details, job title, organisation information such as registrations numbers, country of incorporation and financial information, nature of business and proposals.

It is in our legitimate interests to process your personal information for the purposes of facilitating our programmes and for building potential professional relationships with you.

6. Your rights?

You have a number of rights in relation to your personal information. These are:

Right to object: this right enables you to object to us processing your personal information under certain circumstances and we can be required to no longer process your personal information.

Right to withdraw consent: In certain circumstances, where we have obtained your consent to process your personal information for certain activities, you may be able to withdraw this consent at any time and we will cease processing the personal information in connection with that activity. 

Right to access (sometimes known as a data subject access request or a "DSARs"): You may ask us to confirm what information we hold about you at any time and request access to that personal information. We do have to take into account the interests of others, so this is not an absolute right, and we may sometimes have to withhold information to meet our obligations towards others.

Right to erasure: You may have the right to ask us to erase personal information concerning you. This right does not apply to all situations, as there will be certain areas where we will need to retain your information.

Right to restrict processing: In limited circumstances, you may have the right to request that we restrict our processing of your personal information.

Right to rectification: You may have the right to request that we rectify any inaccurate or incomplete personal information that we hold about you.

Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with Information Regulator. You can contact them in the following ways:

JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
P.O Box 31533, Braamfontein, Johannesburg, 2017
Complaints email: complaints.IR@justice.gov.za
General enquiries email: inforeg@justice.gov.za.

If you would like to exercise any of these rights or withdraw your consent to the processing of your personal information (where consent is our legal basis for processing your personal information), please contact ESADataPrivacy@bat.com. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

7. Who do we share your information with?

At BAT, we do not share, rent or trade your information with third parties for marketing or promotional purposes. When necessary we may share information about you with the following recipients:

  • any of our BAT group companies;
  • tax, audit, or other authorities, when we believe we are legally required to do so, where the relevant authority has asked us to assist (for example, because of a request by a tax authority or in connection with any expected litigation), or in order to help prevent fraud or to protect the rights of BAT; or protect the personal safety of BAT employees, third party agents or members of the public.
  • third party service providers such as external consultants and professional advisers (including law firms, auditors and accountants), technical support functions, and IT consultants carrying out testing and development work on our business technology systems);
  • third parties for the purposes of background screening checks, credit worthiness checks, order fulfilment, delivery, customer support services and storage services;
  • third party outsourced IT providers, including but not limited to email/text messaging providers; Cloud IT service providers, business suite solution providers; data analytics agencies; IT strategic implementation partners; hosting service providers;
  • if it is proposed that a BAT Group entity or business is to merge with or be acquired by another business in the future, we may share your personal information with potential purchasers, where this is necessary, or the new owners of the business or company.

Sometimes when we share your personal information with the third parties described in above, it may be transferred to countries outside of the Republic of South Africa.

We will do our best to ensure that your personal information is stored and transferred in a way which is secure. When we transfer your personal information outside the Republic of South Africa, we do so in compliance with the law and we take appropriate steps to protect that information, which include:

  • entering into agreements with third parties;
  • transferring to organizations within countries that offer adequate protection for your information.

8. Contact us

To exercise any of your rights or if you have any questions or complaints about this Privacy Notice please email by writing to ESADataPrivacy@bat.com.

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