MassTrailOpen the demo

Counsel-review draft · 30 October 2026

Privacy, field evidence and accountable use.

This is a substantive pre-launch draft based on the intended MassTrail operating model and public competitor/legal research. It is not yet an approved POPIA notice: the contracting entity, Information Officer, role allocation, retention schedule, sub-processors and cross-border assessment must be completed by South African counsel before personal information is processed in production.

Pre-launch only. The current site and workspace use synthetic data. Do not submit personal, customer, vehicle or production evidence until this notice, the DPA and the production data map are approved.

1. Who this notice covers

This notice is intended to cover customer administrators and users, site operators, drivers and field actors, counterparty responders, independent reviewers, supplier/installer contacts, support contacts and public-site visitors whose personal information is processed through MassTrail.

Responsible party: [MassTrail contracting entity, registration number and address—pending name/entity clearance]. Information Officer: [name and registration status pending]. Privacy contact: [dedicated address pending].

2. Our role and the customer’s role

For customer programme, evidence and user data, the customer will ordinarily determine why the data is processed and will ordinarily be the responsible party; MassTrail will ordinarily act as its operator under written instructions. MassTrail may be a responsible party for account administration, security, billing, service telemetry, product communications and its own legal obligations. The signed order form and data-processing schedule must resolve the role for each data set and prevail over this summary.

3. Information we expect to process

MassTrail is not designed to collect national identity numbers, biometrics, bank credentials, private household details, health information, children’s information or worker income merely because an upstream system contains them. Customers must remove fields that are not required for the agreed purpose.

4. Where information comes from

Information may come directly from the individual; the customer or its source systems; an assigned origin, receiver, hauler, recycler or reviewer; a registered device or approved supplier interface; and security/hosting systems that operate the service. MassTrail does not scrape or buy contact profiles for the evidence product.

5. Why information is processed

The responsible party must document the applicable POPIA justification for each production purpose. Consent will not be used as a convenient substitute where the real basis is contract, law or a properly assessed legitimate interest.

6. Camera, plate, location and workplace evidence

ProofLens and ProofMove can involve vehicle registrations, images, location and workplace activity. They may be enabled only for a documented, proportionate purpose with appropriate signage/notice, labour and counterparty consultation where required, event-level collection where feasible, role-restricted playback, access logging and a specific retention rule. Location corroborates route movement; it does not prove contents or reported mass.

7. OCR, models and human decisions

OCR and anomaly functions produce suggestions. MassTrail retains the model and version, confidence, suggested value and human action. It does not silently alter evidence or make an autonomous fraud, employment, payment, legal or assurance decision about a person.

8. Recipients and sub-processors

Authorised customer users, assigned counterparties and reviewers receive only the access their role and organisation permit. Approved MassTrail personnel may access restricted diagnostics under a time-bound, audited support process. Information may also be processed by contracted hosting, identity, email, malware-scanning, monitoring and support providers under written safeguards.

The production sub-processor register will name each provider, purpose, processing location and change-notice process before launch. It is not acceptable to infer the final list from this synthetic build.

9. International transfers and hosting

The intended primary identity and application region is South Africa (AWS Africa/Cape Town) where the selected services support it. Some delivery, support or edge services may process limited data elsewhere. No production transfer will occur until the POPIA section 72 mechanism, contractual safeguards, data categories and customer instructions are recorded in the approved transfer assessment and DPA.

10. Retention, correction and deletion

Retention is set by evidence type, customer contract, reporting/legal obligations, disputes and legal holds. Account/security logs, field media, location, source payloads, close records and support cases must not share one blanket period. The final schedule will state each period and trigger.

Evidence corrections append a linked event; a locked close is never overwritten. This integrity rule does not eliminate data-subject rights. Where deletion is legally required but an evidential record must remain, the responsible party must determine whether restriction, de-identification or another lawful treatment satisfies both duties.

11. Security safeguards

The design uses organisation membership, least privilege, database and object-layer tenant isolation, MFA/SSO, encrypted transport, restricted support access, immutable originals, signed exports, security logging, dependency/secret scanning, backups and incident procedures. No internet service can promise absolute security. Production controls and breach responsibilities will be stated in the security and data-processing schedules.

12. Your choices and POPIA rights

Subject to applicable law and verification of identity, a data subject may ask whether information is held, request access or correction, request deletion or restriction, object to certain processing, withdraw consent where consent is the basis, and complain to the responsible party or Information Regulator. Customer-controlled programme requests should normally be directed first to that customer; MassTrail will assist it as operator.

The Information Regulator lists general enquiries at enquiries@inforegulator.org.za, POPIA complaints at POPIAComplaints@inforegulator.org.za and telephone 010 023 5200 / 0800 017 160. These public details must be rechecked at launch.

13. Required information and consequences

Some account and source fields are required to provide the contracted workflow or preserve attribution. Optional fields will be labelled. Refusing a required field may prevent account creation, evidence classification, a control, close approval or access to an assigned request; it must not cause an undisclosed downgrade or invented observation.

14. Children and vulnerable people

The service is a business tool for authorised adults and is not directed at children. Reclaimer or worker programmes may involve vulnerable people and therefore require enhanced minimisation, fair notice, non-coercive capture and a documented prior-authorisation assessment where applicable. No such production programme is approved by this draft.

15. Cookies and public-site analytics

The current build does not deploy advertising trackers. Production authentication will require strictly necessary session/security cookies. Any optional analytics or marketing technology must be listed by name and purpose and, where required, held until a valid choice is recorded.

16. Changes and contact

The approved notice will carry a version/effective date. Material changes will be notified through the service or contractual channel before they take effect where required. Privacy requests must be sent to the final Information Officer address; until then, this page is for counsel and design review only.