EntryGuard Privacy Policy

Who we are

Realeaz (Pty) Ltd, registration number 2021/122704/07, operates the EntryGuard mobile application and supporting platform. EntryGuard is a digital school-safety and access-management service used to manage authorised learner drop-off, collection, check-in and check-out events.

• Registered physical address: 2 Reiger Road, Stellenberg, Bellville
• Postal address: Not applicable — please use the registered physical address or the privacy contact email below.
• Information Officer: Johannes Meyer
• Privacy contact email: francois.vw@personablaze.com

Scope and allocation of responsibility

This Policy applies when personal information is processed through EntryGuard. It should be read with the privacy notice issued by the school that has implemented EntryGuard.

For core learner, guardian-authorisation, check-in, check-out and attendance records, the relevant school ordinarily determines why the information is processed and is the responsible party under POPIA. Realeaz processes that information for the school as an operator under a written agreement.

Realeaz acts as a responsible party for limited information it determines and uses for its own legitimate business purposes, including school contract administration, authorised-user account security, service support, fraud prevention and compliance records.

Where a school’s deployment differs from this allocation, the school’s notice and agreement must explain the difference.

Children and intended users

EntryGuard knowingly processes personal information relating to children under 18. The app is intended to be operated by competent adults, including parents, guardians and authorised school staff, and not by children acting without adult assistance.

A school may process a child’s information only where an exception in section 35 of POPIA applies. Depending on the school’s circumstances, this will ordinarily be prior consent from a competent person, or processing that is necessary for the establishment, exercise or defence of a right or obligation in law. The school must identify and document the applicable ground before activating the learner.

Information we process

Parent, guardian and authorised-collector information

• Name, surname, contact details and preferred communication channel.
• Relationship to the learner and the status, scope and expiry of collection authority.
• Account, authentication and verification information, including login and security-event records.
• Device information reasonably necessary for security and delivery, such as device type, operating system, app version, IP address, notification token and diagnostic information.
• Collection and drop-off events associated with that authorised user.

Learner information

• Name and surname, school-generated learner number, school, grade and class.
• The relationship between the learner and authorised parents, guardians or collectors.
• Check-in, check-out, drop-off and collection timestamps, status and related audit events.
• A system-generated identifier and QR token used for secure matching and verification.
• A national identity number only where the school has separately documented that it is necessary, lawful and proportionate. EntryGuard does not require national identity numbers by default.

School and staff information

• School identity, campus, grade and class structure.
• Authorised staff names, roles, business contact details, account information and audit activity.
• Configuration, support and service-administration records.

Technical and generated information

• QR scan time, result and related device or terminal identifier.
• Login, audit, error, performance, security and incident records.
• Aggregated or properly de-identified service statistics.

Where the information comes from

Information may be obtained:

• Directly from a parent, guardian, authorised collector or school staff member.
• From the relevant school or its authorised education administration system.
• From another competent person who lawfully nominates an authorised collector.
• Automatically when an authorised user signs in, scans a QR code, receives a notification or uses the app.

Why and on what grounds we process information

Where consent is relied upon, it must be voluntary, specific, informed and obtained before the relevant processing. Consent may be withdrawn, but withdrawal does not affect processing that occurred lawfully before withdrawal or information that may still lawfully be retained.

Mandatory and voluntary information

Core profile, relationship, authentication and event information is required where the school cannot safely provide the EntryGuard service without it. If required information is not supplied, the app may be unable to verify or record a collection or drop-off event.

Optional notification preferences and any optional analytics choice may be declined without preventing access to the core service, unless the school explains a lawful operational reason otherwise.

Camera and QR-code use

• The camera is used to scan QR codes for verification.
• EntryGuard does not record or store camera images or video through the QR-scanning function.
• EntryGuard does not use facial recognition and does not process biometric information through the QR-scanning function.
• Camera permission may be disabled in device settings, but QR-scanning functionality will then be unavailable.
• QR codes should contain or reference a random or system-generated token, not a learner’s national identity number in readable form.

Human review and refused events

A failed QR match or system alert must be referred to authorised school staff. EntryGuard is not intended to make a solely automated decision having legal consequences for a learner. School staff remain responsible for applying the school’s safeguarding and identity-verification procedures.

Sharing and disclosure

Personal information may be disclosed only where necessary to:

• The relevant school and its specifically authorised personnel.
• A parent, guardian or collector whose access to the particular learner has been lawfully authorised.
• Approved cloud-hosting, authentication, notification, security, support and analytics operators bound by written confidentiality and security obligations.
• Professional advisers, insurers, auditors or incident-response providers where necessary and subject to confidentiality.
• A regulator, court, law-enforcement authority or other person where disclosure is required or authorised by law.

Realeaz does not sell, rent or trade personal information and does not use learner information for advertising or direct marketing.

Service providers and transfers outside South Africa

EntryGuard uses only the cloud and support services recorded in its approved operator register. Realeaz and the school must ensure that every operator is contractually required to apply appropriate security and confidentiality measures.

Actual Firebase / Google services enabled

Cloud Firestore; Firebase Authentication; Cloud Functions for Firebase (2nd generation); Cloud Run; Eventarc; Cloud Pub/Sub; Cloud Scheduler; Firebase Cloud Messaging; Firebase Installations; Cloud Logging; Firebase Hosting; and Firebase Security Rules.

Supporting Google Cloud build infrastructure includes Cloud Build, Artifact Registry and Cloud Storage buckets used only for function source code and deployment artefacts.

Google Analytics for Firebase, Firebase Crashlytics, Firebase Performance Monitoring, Firebase App Check, Firebase Realtime Database and Firebase Storage are not currently used by the live application.

Hosting, authentication and backup regions or countries

• The primary Cloud Firestore database is hosted in Google Cloud’s africa-south1 region in Johannesburg, South Africa.
• The currently deployed Cloud Functions, their Cloud Run execution environments, the related Cloud Scheduler job, and function deployment artefacts are located in Google Cloud’s us-central1 region in Iowa, United States.
• Firebase Authentication and Firebase Cloud Messaging are Google-managed services for which EntryGuard does not select a dedicated processing region. Firebase Hosting uses Google’s global content-delivery infrastructure.
• Cloud Logging uses Google-managed global logging infrastructure. The standard _Default log bucket currently has a 30-day retention period, while the mandatory _Required audit-log bucket has a locked 400-day retention period.
• Scheduled Firestore backups are configured using a rolling retention cycle not exceeding 90 days. Point-in-time recovery is enabled under the current configuration.
• www.entryguard.co.za is hosted by Vercel Inc. Vercel provides hosting through globally distributed infrastructure and content-delivery services; the website is therefore not restricted to hosting exclusively within South Africa. The site currently serves public EntryGuard web content, including the privacy policy and guardian-invitation landing pages.

Other live SDKs, subprocessors and support providers

• Live application components include Google Firebase SDKs, mobile_scanner for on-device QR scanning, geolocator for device-location capture, google_fonts for application typography, and operating-system integration packages for file selection, sharing, links and local application preferences.
• QR image processing takes place on the device through Apple Vision on iOS and Google ML Kit barcode scanning on Android. QR camera images are not uploaded by EntryGuard for scanning.
• Location information captured during relevant attendance operations is stored in Cloud Firestore.
• The application may retrieve font resources from Google at runtime, which may disclose ordinary connection information such as the device’s IP address to Google.
• When an authorised staff member deliberately opens a guardian’s telephone number in WhatsApp, the number is disclosed to WhatsApp/Meta as part of that user-initiated action. No such disclosure occurs unless that function is used.
• Apple and Google provide mobile-application distribution services. Codemagic/Nevercode OÜ provides build and release automation and processes source code and deployment credentials, but is not intended to receive learner or guardian records.
• The EntryGuard administrative web portal accesses the same Firestore environment through Google’s server-side Admin SDK and must be included in the system and operator register.

Section 72 transfer safeguard relied upon

EntryGuard relies, subject to legal confirmation and completion of the relevant contractual records, on binding contractual arrangements with Google incorporating the Google Cloud Data Processing Addendum, applicable data-protection commitments, documented technical and organisational security measures, and the applicable Standard Contractual Clauses.

These arrangements are intended to provide protections substantially similar to those required under POPIA and to establish enforceable obligations concerning confidentiality, security, restricted processing and data-subject protections.

Retention and deletion

Subject to the school’s lawful instructions and any applicable legal hold, the adopted default periods are:

Information must be securely deleted, destroyed or properly de-identified when retention is no longer authorised. A school’s own lawful retention schedule may require a different period and should be disclosed in its school-specific notice.

Security and security compromises

Realeaz applies appropriate, reasonable technical and organisational safeguards proportionate to the sensitivity of children’s information. These include access controls, least-privilege permissions, secure authentication, encryption in transit, protected storage, logging, backup, vulnerability management, staff confidentiality duties and incident-response procedures.

No system can be guaranteed completely secure. If there are reasonable grounds to believe that personal information has been accessed or acquired by an unauthorised person, Realeaz will immediately notify the relevant school where it acts as operator. The responsible party will notify the Information Regulator and affected data subjects as soon as reasonably possible as required by section 22 of POPIA.

Your rights

Subject to POPIA, a data subject or competent person acting for a child may:

• Ask whether the responsible party holds personal information and request access to it.
• Request correction of inaccurate, incomplete, misleading or outdated information.
• Request deletion or destruction where the information is inaccurate, irrelevant, excessive, outdated, incomplete, misleading, unlawfully obtained or no longer authorised to be retained.
• Object to processing on reasonable grounds where POPIA permits an objection.
• Withdraw consent where consent is the ground relied upon.
• Complain to the Information Regulator or institute proceedings where permitted.

Deletion and withdrawal are not absolute. Some records may continue to be processed or retained where law, a legal claim, a valid objection process or another POPIA ground permits it.

How to exercise a right

A request concerning core school records should first be sent to the relevant school’s Information Officer. A request may also be sent to Realeaz at francois.vw@personablaze.com; where Realeaz is only the operator, it will route the request to the school. Reasonable proof of identity and, for a child, proof that the requester is a competent person may be required.

Complaints to the Information Regulator

A complaint may be submitted through the Information Regulator’s eServices Portal.

• Website: https://inforegulator.org.za/
• eServices: https://eservices.inforegulator.org.za/
• Email: POPIAComplaints@inforegulator.org.za (POPIA complaints) or enquiries@inforegulator.org.za (general enquiries)
• Telephone: 010 023 5200; toll-free 0800 017 160
• Address: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191

Changes to this Policy

Material changes will be communicated through the app, the school or another appropriate channel before the changed processing begins where required. The effective date and last-updated date will be revised. A material new purpose involving a child’s information will be assessed separately and, where required, new prior consent will be obtained.

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