Opencomm privacy notice
Version: 2026-10-05-draft-1 Effective from: [DOM: effective date]
This notice explains what personal information Opencomm holds, why, who can see it, how long it is kept, and what you can do about it. It is written for members, parents and carers, and the people who run communities on Opencomm.
The short version
- Opencomm is a place where a community (a school, a club, an estate, a congregation) runs itself: members, notices, events, fees, a shop, a gate register and more.
- Your community decides what it collects about you and why. We run the software for it.
- We do not sell your information, we do not show you adverts, and we do not use tracking or analytics tools.
- Money does not pass through Opencomm. Your community's own bank details are shown to you, and you pay the community directly.
- You can download everything held about you, correct your details, choose what reaches you, and erase your account, from inside the product.
- A child cannot have an account. A parent or carer is linked to the child, gives consent for them, and uses the child's rights on their behalf.
1. Who we are
Opencomm is operated by [DOM: legal name of the entity that operates Opencomm], registration number [DOM: company registration number], of [DOM: physical address] ("we", "us").
Contact: [DOM: general contact email for Opencomm], or our Information Officer (section 15).
2. Two kinds of "responsible party"
POPIA calls the person who decides why and how personal information is processed the responsible party. On Opencomm there are two, and it matters which one you deal with.
| Information | Responsible party | Our role |
|---|---|---|
| Your Opencomm account and sign-in, the security of the service, our support and administration records | Us | Responsible party |
| Everything inside a community: your membership, profile as the community sees it, charges and payments, bookings, forms, the gate register, incidents, messages and so on | That community (the school, club or organisation that set it up) | We are its operator: we process the information on its behalf and on its instructions |
So for a question about what your school or club holds and why, ask the community first: it decides what it records. We will help it answer, and you can always contact our Information Officer if you cannot get an answer.
3. What we collect, and where it comes from
From you, when you sign in
- Your email address and name, from the Microsoft account you sign in with (Microsoft Entra External ID, see section 8).
- A small profile photo, only if your Microsoft account has one. It is copied once at sign-in.
- An account identifier and sign-in tokens that link your Microsoft sign-in to Opencomm. These are never shown to anybody and are left out of your data download for your own safety.
From you, when you use Opencomm
- Profile: first name, last name and phone number. All optional, and you can change them at any time.
- What you do in a community: event bookings and replies, waitlist places and reminders, poll votes, orders from the community shop, articles, comments and likes, discussion posts and reactions, forms you submit, reports you make about content, and onboarding steps you complete.
- Emergency contacts for yourself or for a child in your care: a name, a relationship and a phone number.
- Directory and mentoring profile (optional): if you choose to be listed in your community's member directory or to join a mentoring programme, the things you choose to share there, such as your availability, what people can ask you about, an approximate location, your interests or skills, how you prefer to be contacted, mentoring preferences, check-in replies and feedback. You choose, field by field, who can see each item. You are not listed in the directory unless you switch it on.
- Notification choices: which messages reach you in the app, by email or as a browser push notification, your quiet hours and time zone, and your digest settings. If you turn on push, we store the address your browser gives us for it and the name of your browser and device type.
From your community, about you
- That you are a member: your role, your member type (for example "Coach" or "Learner"), which groups, teams or spaces you belong to, and when you joined.
- An invitation: if an admin invited you, the email address they typed and when the invitation was sent, accepted or withdrawn.
- Money owed and paid: charges raised against you, payments the community recorded as received, contributions to a collection, and the references for them. Opencomm records these; it does not move money.
- Attendance: event attendance, and if your community uses the gate register, the times you were checked in or out and how (scanned code or by hand). Your personal gate code is drawn in your own browser.
- Safety incidents: if something happens, the community records what happened, where and when, and notes as it is handled. An incident can mention people by name. Its details are seen only by the community's owner and admins, and never appear in a notification.
- Sports: your team, role, shirt number and fixtures.
- Tags and groupings your community uses to send the right messages to the right people (for example, everyone in the under-12 team).
- Decisions on forms you submitted, and notes made by the people who approve them.
Automatically
- Records the service keeps to work and stay secure: when things happened, which notification was delivered by which channel, which articles you opened (to count readers), and a log of actions taken by community admins and by our staff.
- Cookies: see section 13.
We do not collect identity numbers or dates of birth, and we do not use location tracking, your camera or your microphone.
Information that may be sensitive
Opencomm does not ask for health, religious, racial, biometric or criminal information. But some parts of it accept free text: incident reports, forms a community builds, and discussions. What people type there can include sensitive information, for example an injury in an incident report or a medical note on a trip form. Your community is responsible for only asking for what it needs and for having a lawful basis to hold it. A community can mark a form as sensitive to restrict who reads the answers.
4. Why we use it, and on what basis
POPIA (section 11) lets personal information be processed only on a recognised basis. These are the ones that apply.
| Purpose | Basis |
|---|---|
| Creating and running your account, letting you sign in, and delivering the service you or your community signed up for | Needed to perform the agreement with you, and our and your community's legitimate interest in running the community (s11(1)(b) and (f)) |
| Running the community: membership, notices, events, bookings, statements of account, the shop, forms, discussions, mentoring, sports | The community's legitimate interest in running itself, and your agreement with it (s11(1)(b) and (f)) |
| Keeping people safe: the gate register, incidents and emergency contacts | Protecting the legitimate interests of the people concerned, including you, and the community's legitimate interest (s11(1)(d) and (f)) |
| Optional features you switch on: the directory, mentoring, push notifications, digests | Your consent, which you can withdraw by switching the feature off (s11(1)(a)) |
| A child's information | The prior consent of the child's parent or carer (s35(1)(a)), see section 6 |
| Security, preventing abuse (for example limiting repeated attempts to join with an access code), and keeping a record of what admins and our staff did | Our legitimate interest in protecting the service and the people on it (s11(1)(f)) |
| Keeping records a law requires, and answering lawful requests | Complying with the law (s11(1)(c)) |
We do not use your information for any other purpose without telling you first.
5. Do you have to give it?
- Your email address is required. Without it you cannot sign in, and so cannot use Opencomm.
- Everything else you enter is voluntary. If you do not give your phone number, your community cannot call you, and in an emergency it will fall back to the guardians and contacts it does have. If you do not give emergency contacts for a child, the child's linked parents or carers are still shown on the register.
- What your community records about you (membership, charges, attendance and so on) is up to the community. Ask it if you want to know whether something is required and what happens if you do not provide it.
Laws that apply. No specific law requires us to collect the information described here. Your community may be required by laws that apply to it to keep some records, for example financial records. [DOM: confirm, or name any law that does require collection]
6. Children
POPIA treats anybody under 18 as a child. On Opencomm:
- A child cannot have their own account and cannot sign in. A community admin adds the child and links them to a parent or carer at the same time. You must be [DOM: minimum age for an account; 18 recommended] or older to create an account.
- A parent or carer gives the consent, not the community. The child appears on the parent's or carer's Family page as needing consent until they answer. The words they agree to, the date and who agreed are recorded.
- Until consent is given, or after it is withdrawn, the child cannot be booked onto events, cannot have new charges raised against them, and is left out of the member list for everyone except the child's own parents or carers and the community's office. Records that already exist are kept. Notices still reach the parents and carers.
- Withdrawing consent is done on the same Family page, at any time.
- The parent or carer exercises the child's rights: downloading the child's information and erasing it are on the parent's or carer's own "Your data" page.
7. Who can see your information
Inside your community. People see what their role allows, and the database enforces it:
- Your contact details (email address and phone number): the community's owner and admins.
- Your statement of account: you, the parents or carers of the person it is about, and the community's owner, admins and office staff.
- Incident details: the community's owner and admins only.
- Answers on a form marked sensitive: only the person who filled it in, the people who approve that response, and the community's owner. Admins see that a response exists, not what it says.
- Other members: generally your name, what you post, which events you are going to where that is shown, and whatever you chose to share in the directory.
- Teachers and coaches: the attendees of events and the teams they run.
Our staff. Our platform staff can see a community's outline (its name, plan and how many members it has). They cannot see inside a community (messages, statements, incidents, contact details, anything a member wrote) unless the community has a live support session open. A support session needs a written reason, lasts 60 minutes, is visible to the community, can be ended by the community, and every action in it is logged.
Service providers who work for us (operators under POPIA), only to run Opencomm:
| Provider | What for | What they receive |
|---|---|---|
| Microsoft (Azure) | Hosting the application, the database and files | Everything stored in Opencomm, held in [DOM: confirm Azure region, e.g. South Africa North] |
| Microsoft (Entra External ID) | Sign-in | Your email address, name and sign-in activity |
| [DOM: email delivery provider] | Sending email | Your email address and the content of the email (a notification's title and text) |
| Your browser's push service (Google, Mozilla, Apple or Microsoft, depending on your browser) | Push notifications, only if you switch them on | An encrypted message the service cannot read, and the fact that one was sent to your browser |
Integrations your community sets up. A community on a suitable plan can connect its own systems to Opencomm: an automatic feed of events (such as "somebody joined" or "an RSVP changed"), a read-only connection to things like events and the directory, or a file export of its members, attendance, forms or other records. What leaves through these is chosen by the community, which is responsible for where it goes. The automatic event feed is designed to leave out form answers, posts, contact details, passwords and tokens. A member export includes each member's name, email address, role and member type, and directory details only for members who chose to be listed. A forms export includes the answers to ordinary forms, but never the answers to a form marked sensitive. Export files are kept for 24 hours, and only people who run the community can download them.
Others, only when we must. If a law, a court or a regulator lawfully requires it, or to protect someone's life or safety.
We never sell personal information or share it for advertising.
8. Where your information is stored, and transfers outside South Africa
Opencomm's application, database and files are hosted by Microsoft Azure in [DOM: confirm Azure region, e.g. South Africa North].
Some information does leave South Africa, and POPIA (section 72) requires us to tell you:
- Sign-in. Microsoft Entra External ID holds your sign-in details. Microsoft does not offer South Africa as a storage location for it; a South African sign-in directory is stored in Microsoft's Europe, Middle East and Africa region, which in practice means Europe. [DOM: confirm the External ID tenant's country/region setting]
- Email. [DOM: where the email provider processes mail]
- Push notifications, if you switch them on, pass through your browser maker's push service, which may be anywhere in the world. The message is encrypted so that service cannot read it.
We only use providers bound by contract to protect personal information to a standard substantially similar to POPIA, or in countries with comparable data-protection law (s72(1)(a)), or where the transfer is needed to provide the service you asked for (s72(1)(c)). [DOM: confirm the contractual basis with each provider before publishing]
Information about children stays in Opencomm's own database. Children cannot sign in, so none of it is held by the sign-in service.
9. How long we keep it
Opencomm deletes these automatically, on a schedule that runs every hour:
| Information | Kept for |
|---|---|
| Notifications in your list | 12 months |
| Records of which channel delivered a notification | 90 days |
| Which articles you opened | 12 months |
| Digest delivery records | 90 days |
| Gate check-ins and check-outs | 12 months |
| A closed gate register | 2 years after it was closed |
| A resolved incident and its notes | 5 years after it was resolved |
| A gate code that has been replaced | 30 days |
| Export files a community creates | 24 hours |
| Internal event records used to send notifications and integrations | 30 days after they were processed |
| What was sent to a community's connected systems (webhooks) | Cleared 90 days after delivery ends |
| Records of each attempt to run a background task | Deleted 90 days after the attempt finishes |
These are kept until you erase your account or the community removes them:
- your account and profile, and your membership of each community;
- what you wrote, booked, ordered and submitted;
- charges and payments, which your community may need to keep for its books [DOM: confirm whether a retention period applies to financial records];
- consent records, which are the proof that consent was given, and are kept even after an erasure.
The log of what admins and our staff did is kept permanently, because a log that can be edited is not a log. It holds the name of the action and who did it, not the content of your records.
Backups of the database are kept for [DOM: database backup retention period] and then overwritten. An erasure takes effect in the live system at once and in backups when they expire.
When a community stops using Opencomm, [DOM: what happens to a community's data when it leaves or is deleted; D-25 recommends a 30-day grace period, during which the owner can export, then deletion].
10. How we protect it
- Every community is walled off from every other in the database itself, not only in the screens.
- Inside a community, access follows each person's role, again enforced in the database.
- Sign-in is handled by Microsoft; Opencomm never sees or stores a password.
- Records that must not be rewritten (consent records, the admin and staff log, edit histories) are locked so they cannot be changed.
- Our staff cannot see inside a community without a visible, time-limited, logged support session.
- We do not put incident details into notifications, emails or push messages.
If a security compromise affects your personal information, we (or your community, with our help) will tell the Information Regulator and you as soon as reasonably possible, as POPIA section 22 requires.
11. Your rights, and how to use them
| Your right | How to use it on Opencomm |
|---|---|
| See what is held about you (s23) | Open Your data from your account menu and choose Download my data. You get one file with your profile, memberships, charges and payments, bookings and replies, orders, register entries, consent records and the rest. It also lists what is left out and why (your sign-in tokens and the value of your gate code, which are keys rather than facts about you, and records about other people). |
| Correct your details (s24) | Change your name and phone number on your member profile. For anything a community recorded about you (a charge, a register entry, your member type), ask the community's admins. Your email address comes from your Microsoft sign-in. [DOM: how a person changes the email address their account uses] |
| Erase your account (s24) | On Your data, choose Erase this account and type ERASE. Your name, email address and phone number are removed from every community, your sign-in stops working on every device at once, and what you wrote stays with the byline "A former member". See the limits below. |
| Withdraw consent | Switch off the directory, mentoring, push or digests in your settings. For a child, withdraw consent on your Family page. Withdrawal does not undo processing that already happened lawfully. |
| Choose what reaches you | Every notification email has a "Change what reaches you" link. In notification settings you can choose in-app, email or push for each part of the community, set quiet hours, and set your digest. |
| Object (s11(3)) | Where we or your community rely on legitimate interests, you can object, and we must then stop unless the law allows us to continue. Write to the community's admins, or to our Information Officer. [DOM: confirm the channel and response time] |
| Leave a community | Ask one of its admins to remove you. Leaving a community is not the same as erasing your account. |
| Complain | To our Information Officer (section 15), and at any time to the Information Regulator (section 16). |
Limits on erasure, stated plainly.
- You cannot erase your account while you own a community. Hand ownership to someone else first.
- You cannot erase your account while you are a child's only parent or carer on Opencomm. Link the other parent or carer first, or erase the child's information too.
- Charges and payments stay on the community's books so they still add up, with your identity removed.
- Your name is replaced with "[erased]" in incident reports, incident notes and payment notes, but only where it is written exactly as it is on your profile. A nickname or misspelling will not be found.
- The edit history of community posts and knowledge pages, and the answers on forms you submitted, are not altered by an erasure.
- Your sign-in account at Microsoft is not deleted by erasing Opencomm. [DOM: confirm how this is handled; see drafting notes]
For a formal request under the Promotion of Access to Information Act (PAIA), see our PAIA manual: [DOM: link to PAIA manual]. We will respond to a request about your personal information within 30 days.
12. Messages and direct marketing
Opencomm sends you messages about your communities: notices, reminders, statements, bookings, safety alerts and the like. We do not use your information to market our own or anybody else's products to you.
A community may send its members news, including about its shop or events. Every notification email carries a link to change what reaches you. Some messages always come through: an incident alert to the people responsible for incidents is delivered even during quiet hours.
13. Cookies
Opencomm sets only the cookies it needs to work:
- your sign-in session (expires after 30 days without use), and the short-lived security cookies that protect the sign-in itself;
- a short-lived cookie that carries a confirmation message from one page to the next;
- a cookie that remembers whether you collapsed the sidebar (one year).
There are no advertising, analytics or tracking cookies, so we do not ask you to accept any.
14. Automated decisions
Opencomm does not make decisions about you by automated means alone. In a mentoring programme, the software can suggest pairs based on the preferences people chose to share for matching. A coordinator reviews and confirms each match, and depending on the programme, you can accept or decline it.
15. Our Information Officer
[DOM: Information Officer name] Email: [DOM: Information Officer email] Phone: [DOM: Information Officer phone] Address: [DOM: physical address]
16. The Information Regulator
If you are not satisfied with how we or your community handled your personal information, you can complain to the Information Regulator:
- Address: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191
- POPIA complaints: POPIAComplaints@inforegulator.org.za
- General enquiries: enquiries@inforegulator.org.za
- Telephone: 010 023 5200
- Website: https://inforegulator.org.za
17. Changes to this notice
When we change this notice we give it a new version and date. If the change affects how your information is used, we will ask you to read and accept the new version the next time you sign in. Opencomm records which version you accepted and when.