Effective date: 17 August 2026
Policy owner: Casa Kink / Information Officer

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1. Purpose

Casa Kink is committed to protecting personal information in accordance with the Protection of Personal Information Act 4 of 2013 (POPIA). Personal information will only be collected, used, stored and retained where there is a lawful and legitimate purpose.

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2. Records We Keep

Casa Kink may keep personal information necessary for its legitimate activities, including:

• Guest, membership, ticketing and contact information

• Payment and financial records

• Staff, volunteer and contractor records

• Event and attendance records

• Communications relating to Casa Kink activities

• Consent, safety, incident and reporting records

• Investigation and outcome records

• Records required for legal, regulatory, tax, insurance or other legitimate business purposes.

 

Casa Kink will collect and retain only information that is adequate, relevant and necessary for the purpose for which it is held.  Particular care will be taken with sensitive information, including information relating to sexual behaviour, health, sexuality, alleged misconduct or safety incidents.

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3. How Records Are Maintained

Personal information will:

• Be stored securely, whether electronically or physically

• Be accessible only to people who require access for their role

• Not be disclosed to third parties unless there is a lawful basis to do so

• Be kept accurate and updated where reasonably necessary

• Not be copied, downloaded, forwarded or retained unnecessarily.

 

Electronic records will be protected through appropriate passwords, access controls and other reasonable security measures. Physical records will be kept securely and not left accessible to unauthorised persons.

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4. Retention

Casa Kink will not retain personal information for longer than is necessary for the purpose for which it was collected, unless retention is required or authorised by law, is necessary for legitimate business or legal purposes, or is otherwise permitted by POPIA.

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Where a record relates to an incident, complaint, investigation, dispute or potential legal matter, it may be retained for as long as reasonably necessary to manage that matter and protect Casa Kink, its community and the persons involved.

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Retention periods will be reviewed periodically and unnecessary records will be deleted or destroyed.

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5. Destruction and De-identification

When personal information is no longer required or Casa Kink is no longer authorised to retain it, it will be securely deleted, destroyed or permanently de-identified as soon as reasonably practicable.

• Electronic records will be securely deleted where reasonably practicable.

• Paper records will be shredded or otherwise destroyed so that the information cannot reasonably be reconstructed.

• Information retained for statistical, historical or learning purposes will, wherever possible, be anonymised or de-identified.

 

Records subject to a legal hold, investigation, dispute or other legitimate retention requirement will not be destroyed until that requirement has ended.

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6. Access and Correction

A person may request information held about them and may request correction or deletion where permitted by POPIA.  Casa Kink will respond to such requests within the requirements of applicable law.

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7. Responsibility

The Casa Kink Information Officer is responsible for overseeing compliance with this policy, including appropriate access, retention, security and destruction of personal information.

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All staff, volunteers and contractors who have access to personal information are required to maintain its confidentiality and follow this policy.

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8. Review

This policy will be reviewed periodically and updated where necessary to reflect changes in POPIA, applicable regulations or Casa Kink's operations.