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1.1 COMPANY collects, uses and, in some circumstances, shares the personal information of Users in and through this online service (“website”) and during the provision of services to you.
1.2 COMPANY respects the rights of Users whose personal information is collected and used by it, including their right to protection against the unlawful collection, retention, sharing and use of such personal information.
1.3 The purpose of this Privacy Policy is to provide Users with information about the information processing activities of COMPANY and the manner in which their rights are protected.
1.4 This Privacy Policy shall serve as a blanket notification to Users about COMPANY’s processing activities which will remain valid for as long as one has an active account with or is using the services of COMPANY, including the browsing of this website. Users will not be notified separately on each occasion that COMPANY processes the same personal information in the same way over the period.
1.5 COMPANY may amend the provisions of this Privacy Policy to comply with any changes in the law, and/or pursuant to any changes to its information processing activities or privacy practices. Such amendments will be published on the website and will become operable from the date of such publication.
1.6 This privacy policy, and the interpretation and enforcement thereof, will be governed by the laws of the Republic of South Africa.
1.7 The provisions of this Privacy Policy are, as far as possible, be incorporated into any agreement between COMPANY and Users.

Definitions and interpretation
2.1 In this Privacy Policy, the following words bear the following meanings:
2.1.1 ‘‘consent’’ means any voluntary, specific and informed expression of will in terms of which permission is given by or on behalf of a User for the processing of their personal information;
2.1.2 ‘‘direct marketing’’ means to approach a data subject, either in person or by mail or electronic communication, for the direct or indirect purpose of promoting or offering to supply any goods or services to the data subject;
2.1.3 ‘‘operator’’ means an outside third party who processes personal information for or on behalf of COMPANY in terms of a contract or mandate;
2.1.4 ‘‘personal information’’ means any information linked to a User or information that can identify a User, including but not limited to: information relating to a User’s gender, nationality, ethnic or social origin age, language; a User’s e-mail address, physical address, telephone number, location information or online identifier; a User’s financial information including banking details and invoice information; a User’s personal opinions, views or preferences; correspondence sent by a User which is of a private or confidential nature; the User’s special personal information, including without limitation information about a User’s health; and the User’s name if it appears with other personal information relating to that User, or if the disclosure of their name on its own would reveal further personal information about that User;
2.1.5 ‘‘POPIA’’ means the Protection of Personal Information Act of 2013, including any regulations or codes of conduct promulgated under it;
2.1.6 ‘‘PAIA’’ means the Promotion of Access to Information Act 2 of 2000;
2.1.7 ‘‘process or processing’’ means, in relation to personal information, any operation or activity or any set of operations, whether or not by automatic means, including: the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use of that information; dissemination by means of transmission, distribution or making available in any other form; or merging, linking, as well as restriction, degradation, erasure or destruction of that information;
2.1.8 “special personal information” means the religious or philosophical beliefs, race or ethnic origin, trade union membership, political persuasion, health, sex life or any biometric information of a User; and may include criminal behaviour of a User to the extent such data relates to the alleged commission of the User of an offence or any proceedings in respect of any offence allegedly committed by a User or the disposal of such proceedings
2.1.9 “services” means the services provided to any User by COMPANY;
2.1.10 ‘‘User’’ means a visitor or user of this website, or any of the content or services associated with this website; and
2.1.11 ‘‘the website’’ means the website or any part thereof which is accessible from
2.2 Any reference in this Privacy Policy to:
2.2.1 the singular includes the plural and vice versa;
2.2.2 any one gender includes the other genders, as the case may be;
2.2.3 an act, regulation or other law is to the version of that law in force at the effective date of this Policy and includes any amendment or re-enactment made to that law after the effective date of this Policy.
2.3 When calculating any number of days for the purposes of this Policy, the first day must be excluded and the last day of the relevant interval included, unless the last day is not a business day, then the last day will be the next succeeding business day.
2.4 The word “include” means “include without limitation”. Use of the word ‘’include’’ or ‘’in particular’’ is for illustration or emphasis only and where followed by specific examples must not be interpreted as limiting the meaning of the general wording preceding it.
2.5 A requirement that any Policy, request, demand or other communication made in terms of this Privacy Policy must be in writing will be met if it is in the form of a data message as defined in the Electronic Communications and Transactions Act, No. 25 of 2002, and is accessible in a manner usable for subsequent reference, provided that this policy may not be amended as such.

Responsible party
3.1 COMPANY will be the party who will be collecting and processing a User’s personal information and as such is designated as the ‘’responsible party’’ for the purposes of this Policy.
3.2 COMPANY‘s contact details are as follows:
3.2.1 Email address:
3.2.2 Website address:
3.3 COMPANY may instruct third party operators from time to time to undertake certain processing activities relating to the User’s personal information.

What personal information is collected?
4.1 COMPANY may collect the following personal information from the User:
4.1.1 Initials, first name, surname;
4.1.2 Email address;
4.1.3 Cell phone number;
4.1.4 Physical address;
4.1.5 Geo-location and geocoding data;
4.1.6 Employment details;
4.1.7 Credit and financial risk information;
4.1.8 Banking and credit card details; and
4.1.9 Identity or passport number.
4.2 The supply of personal information by the User to COMPANY is voluntary and not mandatory. However, if the User refuses to supply any personal information, certain consequences may naturally flow from such a refusal, such as preventing COMPANY from concluding or performing any contract with the User, or preventing COMPANY from complying with one or more of its obligations in law.
4.3 There are certain laws which require or authorise COMPANY to collect a User’s personal information, including the National Credit Act 34 of 2005 and regulations and directives issued under this Act.

Purpose/s for collection and processing of personal information

5.1 COMPANY shall only collect a User’s personal information for a specific, explicitly defined and lawful purpose relating to a function or activity of COMPANY‘s business.
5.2 Such purposes may include the following:
5.2.1 to enter into a contract with a User including the undertaking to provide a product or service;
5.2.2 to perform any obligations under a contract with a User;
5.2.3 to comply with a legal obligation;
5.2.4 to protect a legitimate interest of a User (unless the User has specifically objected in writing to all or some of the processing activities on reasonable grounds);
5.2.5 to pursue its own legitimate interests or the legitimate interests of a third party who it is sharing the information with (unless the User has specifically objected in writing to all or some of the processing activities on reasonable grounds);
5.2.6 to process personal information for direct marketing purposes (only if the User has opted in to receiving any direct marketing material);
5.2.7 to customise and display content to the User in a way that COMPANY feels may interest the User or be most beneficial to them;
5.2.8 to send content including, but not limited to products, articles, listings and advertisement content to the User via email or other electronic media, where the User has consented to be contacted by COMPANY with such content;
5.2.9 to enable the User to voluntarily participate in interactive features;
5.2.10 to notify the User about changes to the website or services.
5.3 If COMPANY intends to process a User’s personal information for any other purpose not listed in clause 5.2 or which is otherwise not automatically permitted by law, it shall ensure that it obtains the User’s written consent to do so.
5.4 COMPANY will not sell a User’s personal information to any third party without the prior written consent of the User.

Collection directly from user
6.1 COMPANY shall, as far as possible, always collect personal information about a User directly from the User, except in the following circumstances:
6.1.1 Where personal information is collected from a public record, or from another source if the information has already been made public by the User;
6.1.2 where the User has given their written consent to COMPANY to collect their information from another source;
6.1.3 where the collection of a User’s personal information from another source will not prejudice any of the User’s legitimate interests;
6.1.4 where the collection of personal information from another source is necessary to maintain COMPANY’s legitimate interests or those of any third party it intends sharing the information with;
6.1.5 where the collection of personal information directly from the User would prejudice the purpose for the collection;
6.1.6 where the collection of personal information directly from the User is not reasonably practicable in the circumstances.
6.2 If COMPANY collects personal information from a source other than the User, it shall record in writing the details of that source, including the full names and contact details of that source where applicable.
6.3 Personal information may be collected from or supplied by the User in any of the following ways:
6.3.1 during the process of scanning a QR Code or sending a SMS, USSD number or WhatsApp message;
6.3.2 when subscribing to or contracting for a service;
6.3.3 when requesting further services or information from COMPANY;
6.3.4 when engaging with the COMPANY via social media platforms including messaging and meeting platforms;
6.3.5 when contacting COMPANY to report a problem with the website or the services or for any other reason;
6.3.6 when completing any forms on the website.
6.4 The User may visit the website without providing any personal information. However, the website’s servers may still collect technical information regarding the use of the website, which is aggregated for analytical purposes, technical maintenance and for improving the content offered on the website. Such information may include details of the User’s visit, information about the User’s computer, including IP (Internet Protocol) address, operating system and browser type, the User’s location, and usage information. An individual User will not be identified from or by this information and COMPANY is entitled to copy, distribute or otherwise use such information without limitation.

7.1 “Cookies” are small text files transferred by a webserver to a User’s hard drive and thereafter stored on their computer. The types of information a Cookie collects includes a User’s username, the date and time of their visits to the website, their browsing history and preferences.
7.2 COMPANY may use Cookies on this website to:
7.2.1 distinguish one User from another on the website;
7.2.2 remember the User’s last session when they return to the website;
7.2.3 estimate the website’s audience size and usage patterns;
7.2.4 store information about the User’s preferences, which allows COMPANY to customize the website and content according to the Users individual preferences; and
7.2.5 speed up searches on the website.
7.3 The provisions of this clause are only applicable to Cookies used by COMPANY. In some instances, third-party service providers may use Cookies on the website. COMPANY cannot and does not control or access Cookies used by third party service providers and takes no responsibility therefor.
7.4 The User has the right and ability to either accept or decline the use of Cookies on their computer’s web browser, whether they are logged in as a member, or simply casually visiting the website. However, declining the use of Cookies may limit a User’s access to certain features on the website.

General conditions for processing personal information
8.1 COMPANY shall comply with all laws, contracts or regulations when it processes a User’s personal information.
8.2 COMPANY shall not act unreasonably when processing a User’s personal information. This means that it will collect and process a User’s personal information in a way that the User can reasonably expect and in a way that is fair.
8.3 COMPANY shall respect the User’s right to privacy at all times. If there is another way in which it can achieve the same goal without posing any risk of harm to the privacy rights of the User, then it will choose that option.
8.4 Similarly, if COMPANY needs to process personal information but there are less privacy-invasive methods of collecting, using and sharing that information, then it will use those methods.
8.5 COMPANY shall ensure that the personal information that is collected and processed is and remains relevant to the identified purpose/s for such processing, and that such information is and remains adequate, but not excessive, for achieving the identified purpose/s.
8.6 If there are any alternative ways to achieve the identified purpose/s without processing personal information, COMPANY shall not process that personal information.
8.7 COMPANY shall ensure that the processing activities it chooses to apply are proportionate to achieving the identified purpose/s and that no less privacy invasive measures are available to achieve the same purpose/s.
8.8 COMPANY shall ensure that, regardless of the stated purpose/s for processing personal information, the rights and interests of Users will not be unnecessarily prejudiced or infringed, unless it cannot be avoided, and then in such cases, it shall ensure that its own rights and/or interests justify such prejudice or infringement taking place.
8.9 COMPANY shall be entitled to store the personal information of Users indefinitely unless the User objects thereto. In the event a User objects to the indefinite storage, once COMPANY has achieved the purpose for the collection of the User’s personal information, it will destroy or delete such information, unless the User has directed otherwise in writing, or COMPANY is required by law to retain the information for a longer period of time.
8.10 If COMPANY no longer needs to process personal information to achieve the purpose originally specified, it will stop using that information.

Disclosure and sharing of personal information
9.1 COMPANY may, in the course of providing any content or services on this website, or for the purposes of concluding or performing any other services or transaction with a User, share certain personal information with third party operators who perform certain processing activities on behalf of COMPANY.
9.2 The information shared and the categories of third party operators with whom it is shared will always be notified to you prior to being shared. Notwithstanding the aforegoing, you consent to us sharing your personal information with the following operators for, amongst other things, the purposes of curbing the spread of any contagion (including for subsequent research purposes relating to COVID-19 or any other viral outbreak):
9.2.1 Suppliers and third party service providers;
9.2.2 The Department of Health;
9.2.3 The Department of Labour;
9.2.4 The National Centre for Infectious Diseases;
9.2.5 Other regulators or government departments;
9.2.6 Universities and research institutes;
9.2.7 Medical institutes including laboratories; and
9.2.8 Statisticians or other analytical data modelling entities.
9.3 COMPANY may also share aggregated information about Users of this website and their usage patterns. COMPANY may also use such aggregated information to help advertisers target specific audiences. Such aggregated information will be de-identified and the User’s personal information will not be disclosed.
9.4 Other than as stated in clause 9.1 and 9.3, COMPANY shall not share a User’s personal information with any third parties unless it has the User’s express consent to do so.

User’s rights in relation to the processing of their personal information
10.1 Users shall have the following rights in relation to the processing of their personal information:
10.1.1 to access and correct any personal information held by COMPANY about them;
10.1.2 to object to the processing of their information; and
10.1.3 to lodge a complaint with the Information Regulator.
10.2 Users may make a request in terms of clause 10.1.1 by following the process for making such a request as set out in COMPANY’s PAIA manual.

Further processing
11.1 COMPANY shall not process a User’s personal information for any purpose not previously specified except in the following circumstances:
11.1.1 where the User has consented to such further processing;
11.1.2 where the further processing is necessary for the exercise of any contractual rights or the fulfillment of any obligations between COMPANY and the User;
11.1.3 where the further processing activities are linked to or compatible with the original purpose;
11.1.4 where the further processing is necessary for the prevention, detection, investigation, prosecution and punishment of an offence;
11.1.5 where the further processing is necessary to enforce any law;
11.1.6 where the further processing is necessary for the conduct of legal proceedings in any court or tribunal that have commenced or are reasonably contemplated;
11.1.7 where the further processing is necessary to prevent or mitigate a serious and imminent threat to the life or health of the User or another individual;
11.1.8 where the further processing is necessary for historical, statistical or research purposes.
11.2 COMPANY shall ensure that if it intends processing personal information for other purposes not previously specified, it shall notify the User of such further purposes and the possible consequences of the intended further processing for the User.

Accuracy, correctness and completeness of personal information
12.1 COMPANY shall take reasonably practicable steps to ensure that the personal information kept by it about Users is complete, accurate, not misleading and is updated when necessary.
12.2 However, if a User is aware of any personal information in COMPANY’s custody that is incorrect, inaccurate or which needs to be updated, the User must make a written request to COMPANY’s information officer to update or correct the relevant information.
12.3 If a User has contested the accuracy of any personal information being used by COMPANY, it shall immediately stop using that information until its accuracy has been verified.
12.4 COMPANY reserves its right to only adhere to a request from a User in terms of clause 12.2 if the correction or updating of that information will result in the personal information being correct and accurate.
12.5 Where personal information that has been shared by COMPANY with a third party is subsequently updated or corrected, COMPANY shall ensure that all third parties, with whom that information was shared, receives the updated and/or corrected version of the information as soon as it has been updated and/or corrected.

Security safeguards
13.1 COMPANY is committed to protecting the personal information in its custody against any loss of, damage to or unauthorised destruction of that information, and to prevent any unauthorised parties from accessing that information.
13.2 COMPANY takes steps to continually identify and document any risks to the personal information it has in its possession or under its control and that appropriate security safeguards are in place against those risks.
13.3 COMPANY shall ensure that in any contracts entered into with third party operators who process personal information on COMPANY’ behalf, include the following obligations:
13.3.1 the operator shall not process any personal information without COMPANY’s knowledge and authority;
13.3.2 the operator shall treat all personal information given to it as confidential and shall not disclose it to any unauthorised third parties;
13.3.3 the operator shall establish and maintain adequate security measures which are the same or offer similar protection over the personal information as that employed by COMPANY;
13.3.4 the operator shall notify COMPANY immediately where there are reasonable grounds to believe that any personal information has been leaked to or accessed by any unauthorised person;
13.3.5 if the operator is situated in another country, it must comply with the data protection laws in that country and be able to provide verification that it is so compliant;
13.3.6 if an operator is legally obliged to disclose any personal information processed by them on COMPANY’ behalf to other parties, it must notify COMPANY beforehand to enable COMPANY and/or individual Users to protect their rights if necessary.
13.4 COMPANY shall ensure that all personal information on its systems is properly backed-up and that back-up copies are stored separately and off-site from the live files.

Notification of breach of security
14.1 If personal information about a User is inadvertently leaked or COMPANY’s security has been unlawfully breached by any unauthorised party, COMPANY shall immediately identify the relevant Users who may be affected by the security breach, and shall contact them at their last known email address or contact details or by the quickest means possible.
14.2 COMPANY shall provide sufficient information to the User to allow him or her to take the necessary protective measures against the potential consequences of the compromise, or shall advise Users of the steps to be taken by them and the possible consequences that may ensue from the breach for them.

Decisions based on personal information processed
15.1 If COMPANY is required to make a decision about a User using any personal information that has been obtained, it shall ensure that a record of such information and the decision made is kept for a reasonable period of time to give the User an opportunity to request access to that record.
15.2 COMPANY shall allow a User a reasonable opportunity to make representations before any decision is made solely on the basis of the personal information processed, if that decision will affect the legal position of the User, or will otherwise adversely affect them in some manner or form.
15.3 COMPANY shall always ensure that the underlying logic behind any decision made pursuant to the automated processing of personal information is sound and that this underlying logic can be communicated to the User to enable them to make representations.
15.4 If COMPANY has made a decisions based on incorrect personal information, it shall immediately revisit that decision as soon as it receive Policy or becomes aware of the error or inaccuracy of that information.

Linked third party websites
16.1 This website may contain links or references to other websites, including those of advertisers (“third party websites“) which are not under COMPANY’s control.
16.2 The provisions of this Privacy Policy are not applicable to third party websites and COMPANY shall not be responsible for the information processing practices and/or privacy policies of those third party websites, or the cookies that those websites may use.

Direct marketing
17.1 The User hereby consents to the processing of their personal information for the purpose of direct marketing by means of electronic communications including automatic calling machines, facsimile machines, software applications, SMS’s or electronic mail.
17.2 COMPANY will only send electronic communications to the User for the purpose of marketing similar products or services offered by COMPANY, with the User’s consent.
17.3 The User may object, free of charge, and without unnecessary formality, to the use of their details either when the information was first collected from them or when each subsequent electronic communication is sent to them by COMPANY.
17.4 The User can opt out of receiving further marketing communications by unchecking certain boxes on the forms used on the website to collect their personal information, or by contacting COMPANY at

Children’s personal information
COMPANY shall not process any personal information relating to a person under the age of 18 years unless it has obtained consent from that person’s parent or legal guardian. If this website is being accessed by the parent or guardian of a child under the age of 18 years, and personal information pertaining to that child is being provided by the parent or guardian, then they hereby expressly consent to COMPANY processing such information according to the further provisions of this Privacy Policy.

Cross border Transfers of personal information
19.1 COMPANY may transfer personal information to another country in the following circumstances:
19.1.1 the transfer is necessary for the performance of a contract that COMPANY has with the User;
19.1.2 the transfer is necessary for the conclusion or performance of a contract with a third party which is for the benefit of or in the interest of the User;
19.1.3 the transfer is otherwise for the benefit of the User;
19.1.4 the transfer is for research purposes to prevent or curb the spread of a contagion another viral outbreak; or
19.1.5 the User has consented to the transfer of their information.
19.2 If COMPANY is required to transfer personal information from South Africa to a third party in a foreign country, such foreign country may not have data protection laws with a similar or adequate level of protection as POPIA.

Retention of information
20.1 COMPANY will keep a record of any personal information collected for no longer than agreed by the User or as is necessary to achieve the specific purpose for which it collected such information in the first place unless:
20.1.1 It is required by law to keep a record of such information for a longer period of time; or
20.1.2 It needs to keep a record of such information for another lawful purpose; or
20.1.3 It has a contractual obligation to keep a record of such information; or
20.1.4 The User has consented to their information being kept for a longer period.
20.2 COMPANY may, if it has de-identified personal information, kept such information for historical, statistical or research purposes. COMPANY shall ensure that appropriate safeguards are in place to prevent those records from being used for any other purposes, or against the information being re-identified.

Returning, destroying or deleting personal information
21.1 Where COMPANY is no longer authorised to retain a record of any personal information, it shall either:
21.1.1 ensure that the information is permanently destroyed or deleted as soon as reasonably practicable; or
21.1.2 return the information to the User or transfer it to a third party, if requested by the User in writing to do so.

22.1 The User hereby consents to the processing of their personal information in terms of the provisions of this Privacy Policy.
22.2 The User acknowledges and agrees that such consent has been given voluntarily after the User has read and understood the provisions of this Privacy Policy, in particular, regarding the following:
22.2.1 the types of personal information to be processed, including specifically special personal information;
22.2.2 the specific processing activities to be undertaken;
22.2.3 the specific purpose/s for such processing; and
22.2.4 the possible consequences for the User that may arise from such processing.
22.3 Should a User wish to withdraw any consent previously given by the User, they must notify COMPANY’s information officer in writing.

Lodging an objection
23.1 A User may, on reasonable grounds, object to the processing of their personal information at any time after that processing has started.
23.2 If a User wishes to object to the processing of their personal information, they must send written notice of their objection to COMPANY’s information officer, together with their reasons for doing so.

Choice of Law
This Privacy Policy shall be governed and interpreted in accordance with the laws of the Republic of South Africa.

Amendment of this privacy policy
25.1 COMPANY reserves the right to change, update, add, remove and/or amend any of the provisions of this Privacy Policy from time to time. Such changes, updates, additions, removals or amendments will become effective from the date of their publication on this website.
25.2 It is the User’s obligation to periodically check the provisions of this Privacy Policy for any such changes, updates, additions, removals or amendments.
25.3 The User’s continued use of this website following any changes, updates, additions, removals or amendments to this Privacy Policy will be considered Policy of the User’s acceptance to abide by and be bound by this Privacy Policy, as amended.

Africa Floorcare and Promop (Pty) Ltd (“Company”) Manual to Accessing Information (“Manual”)

This Manual has been prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 (“PAIA”) and updated in the light of the Protection of Personal Information Act 4 of 2013 (“POPIA”)

1.1. This manual is for the Company.

Purpose of PAIA
2.1. PAIA is an act that was passed to give effect to the constitutional right, held by everyone in South African, of access to information which is held by the State or by another person and which is required for the exercise or protection of any right. Where a request is made in terms of PAIA, the body to which the request is made is obliged to give access to the requested information, except where the Act expressly provides that the information may or must not be released.
2.2. It is important to note that PAIA recognises certain limitations to the right of access to information, including, but not exclusively, limitations aimed at the reasonable protection of privacy, commercial confidentiality, and effective, efficient and good governance, and in a manner which balances that right with any other rights, including such rights contained in the Bill of Rights in the Constitution.
2.3. POPIA was enacted in November 2013, to promote the protection of personal information processed by public and private bodies. POPIA amended certain provisions of PAIA, balancing the need for access to information against the need to ensure the protection of personal information.

Information manual
3.1. One of the main requirements specified in PAIA is the compilation of an information manual that provides information on both the types and categories of records held by a private body. This document serves as Company’s information manual. This Manual is compiled in accordance with section 51 of PAIA and the Schedule to POPIA. It is intended to give a description of the records held by and on behalf of Company; to outline the procedure to be followed and the fees payable when requesting access to any of these records in the exercise of the right of access to information, with a view of enabling requesters to obtain records which they are entitled to in a quick, easy and accessible manner.
3.2. This Manual is available for public inspection at the physical address of Company, recorded in paragraph 4 below, free of charge; and on this website, free of charge; and on request by any person (along with payment of a prescribed fee).
3.3. The Manual is available from the designated Information Officer, whose details appear below.
3.4. The responsibility for administration of, and compliance with, PAIA and POPIA have been delegated to the Information Officer.
3.5. Requests pursuant to the provisions of PAIA and/or POPIA should be directed to the Information Officer as follows:

Name: David Thomas
Address: Unit 2 Prime Business Park, Montague Gardens, 7441, 17 Printers Way, Marconi Beam, 7447, Cape Town, South Africa
Email Address:
Telephone Number: +27 21 511 7250

Information Regulator’s Guide
4.1. An official Guide has been compiled which contains information to assist a person wishing to exercise a right of access to information in terms of PAIA and POPIA. This Guide is made available by the Information Regulator (established in terms of POPIA). Copies of the updated Guide are available from Information Regulator in the manner prescribed. The South African HUMAN RIGHTS COMMISSION, Head Office, Braampark Forum 3, 33 Hoofd Street, Braamfontein. Tel – (011) 8773750. Fax – (011) 403 0668. Email – Website –

Automatic disclosure
5.1. A private body may, on a voluntary basis, make available a description of categories of records that are automatically available without a person having to request access in terms of PAIA.
5.2. The only fee for access to these records may be a prescribed fee for reproduction.

Types and categories of records
6.1. A requester may also request information that is available in terms of other legislation, such as (the below is not an exhaustive list):
6.1.1. Competition Act 89 of 1998;
6.1.2. The Companies Act 71 of 2008;
6.1.3. The Labour Relations Act 66 of 1995;
6.1.4. Employment Equity Act 55 of 1998;
6.1.5. Basic Conditions of Employment Act 75 of 1997;
6.1.6. Compensation for Occupational Injuries and Diseases Act 130 of 1993;
6.1.7. Financial Intelligence Centre Act 38 of 2001;
6.1.8. Income Tax Act 58 of 1962;
6.1.9. Occupational Health and Safety Act 85 of 1993;
6.1.10. Unemployment Insurance Act 63 of 2001;
6.1.11. Value-added Tax Act 89 of 1991; and
6.1.12. Consumer Protection Act 68 of 2008

Subject Categories of Records
The information is classified and grouped according to records relating to the following subjects and categories:
7.1. Personnel Records: “Personnel” refers to any person who works for or provides services to or on behalf of Company and receives, or is entitled to receive, remuneration and any other person who assists in carrying out or conducting the business of Company. It includes, without limitation, directors (executive and non-executive), all permanent, temporary and part-time staff, as well as contract workers.
7.2. Personal records provided by personnel include:
7.2.1. Records provided by a third party relating to Personnel;
7.2.2. Conditions of employment and other Personnel-related contractual and quasi-legal records, including job applications;
7.2.3. Internal evaluation records and other internal records;
7.2.4. Correspondence relating to, or emanating from, Personnel (internal and external to the organization); and
7.2.5. Training schedules and material;
7.2.6. Payment records (and beneficiary payments), including banking details.
7.3. Client Related Records: “Client” refers to any natural or juristic entity that receives services from Company.
7.4. Client related records include:
7.4.1. Records provided by a client to a third party acting for or on behalf of Company;
7.4.2. Records provided by a third party (for example, records from a reseller);
7.4.3. Records generated by or within Company relating to its clients;
7.4.4. Transactional records;
7.4.5. Correspondence with a client that is implicitly or explicitly of a private or confidential nature
7.4.6. Records pertaining to a client retrieved from “other sources”, such as any credit bureau or credit providers industry association.
7.5. Private Body Records which include but are not limited to records pertaining to Company’s own internal affairs:
7.5.1. Financial records;
7.5.2. Operational records;
7.5.3. Information technology;
7.5.4. Communication;
7.5.5. Administrative records, such as contracts and service level agreements;
7.5.6. Product records;
7.5.7. Statutory records;
7.5.8. Internal Policies and procedures; and
7.5.9. Human resources records.
7.6. Other Party Records:
7.6.1. Records held by Company pertaining to other parties, including without limitation, financial records, correspondence, contractual records, records provided by the other party (for example third party beneficiaries or employees of a client), and records third parties have provided about Company’s contractors / suppliers.
7.6.2. Company may possess records pertaining to other parties including, but not limited to, contractors, suppliers, and service providers and such other parties may possess records that can be said to belong to Company.

Processing details
8.1. In terms of POPIA, data must be processed for a specified purpose. The purpose for which data are processed by Company will depend on the nature of the data and the particular data subject. This purpose is ordinarily disclosed, explicitly or implicitly, at the time the data are collected.
8.2. Purpose of Processing
8.2.1. Personnel data Company processes personnel data for business administration purposes. For example, personnel data are processed for payroll purposes. Personnel data are also processed to the extent required by legislation and regulation. For example, Company discloses employees’ financial information to the Commissioner for the South African Revenue Service, in terms of the Income Tax Act 58 of 1962 and employee’s sensitive personal information in terms of the Employment Equity Act 55 of 1998.
8.2.2. Client related data Company processes client related records as an integral party of its commercial services. For example Company processes client related records during the client application and onboarding processes and for provision of a service. This list of processing purposes is non-exhaustive.

Third party data
9.1. Company processes third party records for business administration purposes.

Other party data
10.1. Company processes “other party” records for business administration purposes. For example, Personnel data may be processed in order to effect payment to contractors and / or suppliers.
10.2. In performing these various tasks, Company may, amongst others, collect, collate, process, store and disclose personal information.

Categories of Data Subjects. Company holds information and records on the following category of data subject:
11.1. Employees / Personnel of Company;
11.2. Clients of Company;
11.3. Any third party with whom Company conducts its business services;
11.4. Contractors of Company;
11.5. Suppliers of Company;
11.6. Service providers of Company.
This list of categories of data subjects is non-exhaustive.

Recipients To Whom Personal Information Will Be Supplied
12.1. Depending on the nature of the data, Company may supply information or records to the following categories of recipients:
12.1.1. Statutory oversight bodies, regulators or judicial commissions of enquiry making a request for data (i.e. the Information Regulator in terms of POPIA);
12.1.2. Any court, administrative or judicial forum, arbitration, statutory commission, or ombudsman making a request for data or discovery in terms of the applicable rules (i.e. the Competition Commission in terms of the Competition Act 89 of 1998);
12.1.3. South African Revenue Services, or another similar authority;
12.1.4. A contracted third party who requires this information to provide services;
12.1.5. Third parties with whom Company has a contractual relationship for the retention of data (for example, a third party hosting services);
12.1.6. Research/ academic institutions;
12.1.7. Auditing and accounting bodies (internal and external);
12.1.8. Anyone making a successful application for access in terms of PAIA.

Planned Transborder Flows Of Personal Information
13.1. Company may transfer personal information to a third party who is in a foreign country in order to administer certain services, but may only do so subject to the provisions of POPIA. Thus internal cross-border transfers, as well as external cross-border transfers of information are envisaged, subject to the provisions of POPIA.

Security Measures
14.1. Company takes extensive information security measures to ensure the confidentiality, integrity and availability of personal information in Company’s possession. Company takes appropriate technical and organizational measures designed to ensure that personal data remain confidential and secure against unauthorized or unlawful processing and against accidental loss, destruction or damage.

Grounds for Refusal of Access to Records
15.1. Company may refuse a request for information on the following basis:
15.1.1. Mandatory protection of the privacy of a third party who is a natural person, which would involve the unreasonable disclosure of personal information of that natural person;
15.1.2. Mandatory protection of the commercial information of a third party, if the record contains: Trade secrets of that third party; Financial, commercial, scientific or technical information which disclosure could likely cause harm to the financial or commercial interests of that third party; and Information disclosed in confidence by a third party to Company, if the disclosure could put that third party at a disadvantage in negotiations or commercial competition.
15.1.3. Mandatory protection of confidential information of third parties if it is protected in terms of any agreement or legislation;
15.1.4. Mandatory protection of the safety of individuals and the protection of property;
15.1.5. Mandatory protection of records which would be regarded as privileged in legal proceedings;
15.1.6. The commercial activities of Company, which may include: Trade secrets of Company; Financial, which, if disclosed, could put Company at a disadvantage in negotiations or commercial competition; A computer program which is owned by Company and which is protected by copyright.
15.1.7. Requests for information that are clearly frivolous or vexatious, or which involve an unreasonable diversion of resources shall be refused.

Access Request Procedure
17.1. A requester requiring access to information held by Company must complete the prescribed Access Request Form, available here:, submit it to the Information Officer at the physical address or electronic mail address recorded in paragraph 3.5 and pay a request fee (and a deposit, if applicable).
17.2. In order to facilitate a timely response to requests for access, all requesters should take note of the following when completing the Access Request Form:
17.2.1. The Access Request Form must be comprehensively completed.
17.2.2. Proof of identity is required to authenticate the identity of the requester. Therefore, in addition to the access request form, requesters will be required to supply a copy of their identification document.
17.2.3. Every applicable question must be answered. If a question does not apply “N/A” should be stated in response to that question. If there is nothing to disclose in reply to a particular question “Nil” should be stated in response to that question.
17.2.4. The Access Request Form must be completed with enough particularity to enable the Information Officer to identify: The record(s) requested; The identity number of the requester; The form of access required if the request is granted; The postal address or fax number of the requester.
17.3. The requester must also state that he or she requires the information in order to exercise or protect a right, and clearly state the nature of the right to be exercised or protected. In addition, the requester must clearly specify why the record is necessary to exercise or protect such a right.
17.4. If a request is made on behalf of another person, then the requester must submit proof of the capacity in which the requester is making the request to the reasonable satisfaction of the Information Officer.
17.5. If an individual is unable to complete the prescribed form because of illiteracy or disability, such a person may make the request orally.
17.6. The requester will be informed in writing whether access has been granted or denied. If, in addition, the requester requires the reasons for the decision in any other manner, he must state the manner and the particulars so required.

Payment of Fees
18.1. Payment details can be obtained from the Information Officer and can be made either via a direct deposit, by bank guaranteed cheque or by postal order. Proof of payment must be supplied when the Access Request Form is submitted.
18.2. The prescribed fee is set out below in Annexure 1.
18.3. Note that the requester may lodge a complaint to the Information Regulator or an application with a court against the tender or payment of the request fee.
18.4. If the search for, and the preparation of, the record for disclosure would, in the opinion of the Information Officer, require more than 6 hours, the requester may be required to pay as a deposit one third of the access fee (the fee which will be payable if the request is granted).
18.5. Note that the requester may lodge a complaint to the Information Regulator or an application with a court against the tender or payment of the deposit.
18.6. If a deposit has been paid in respect of a request for access which is subsequently refused, then the Information Officer must refund the deposit to the requester.
18.7. The requester must pay the prescribed fee before any processing, or any further processing, can take place.

Third Party Notification
19.1. Company must take all reasonable steps to inform a third party to whom or which a requested record relates if the disclosure of that records would –
19.1.1. involve the disclosure of personal information about that third party;
19.1.2. involve the disclosure of trade secrets of that third party; financial, commercial, scientific or technical information (other than trade secrets) of that third party, the disclosure of which would be likely to cause harm to the commercial or financial interests of that third party; or information supplied in confidence by a third party, the disclosure of which could reasonably be expected to put that third party at a disadvantage in contractual or other negotiations; or to prejudice that third party in commercial competition;
19.1.3. constitute an action for breach of a duty of confidence owed to a third party in terms of an agreement; or
19.1.4. involve the disclosure of information about research being, or to be, carried out by or on behalf of a third party, the disclosure of which would be likely to expose the third party, a person that is or will be carrying out the research on behalf of the third party, or the subject matter of the research, to serious disadvantage.
19.2. Company will inform the third party as soon as reasonably possible, but in any event, within 21 days after that request is received.
19.3. Within 21 days of being informed of the request, the third party may-
19.3.1. make written or oral representations to the Information Officer why the request for access should be refused; or
19.3.2. give written consent for the disclosure of the record to the requester.
19.4. Company will notify the third party of the outcome of the request. If the request is granted, adequate reasons for granting the request will be given.
19.5. The third party may lodge a complaint to the Information Regulator or an application with a court against the decision within 30 days after notice is given, after which the requester will be given access to the record after the expiry of the 30 day period.

Notification of Decision
20.1. The Information Officer will, within 30 days of receipt of the request, decide whether to grant or decline the request and give notice with reasons (if required) to that effect.
20.2. The 30 day period, within which Company has to decide whether to grant or refuse the request, may be extended for a further period of not more than 30 days if the information cannot reasonably be obtained within the original 30 day period. For example, the time period may be extended if the request is for a large amount of information, or the request requires Company to search for information held at another office of Company.
20.3. The Information Officer will notify the requester in writing should an extension be required. The requester may lodge a complaint to the Information Regulator or an application with a court against the extension.

Remedies Available for Refusals for a Request for Information
21.1. All complaints, by a requester or a third party, can be made to the Information Regulator or a court, in the manner prescribed below.
21.2. The requester or third party, as the case may be, may submit a complaint in writing to the Information Regulator, within 180 days of the decision, alleging that the decision was not in compliance with the provisions of PAIA. Please refer to see more detail on how to submit a complaint.
21.3. The Information Regulator will investigate the complaint and reach a decision – which may include a decision to investigate, to take no further action or to refer the complaint to the Enforcement Committee established in terms of POPIA. The Information Regulator may serve an enforcement notice confirming, amending or setting aside the impugned decision, which must be accompanied by reasons.
21.4. An application to court maybe brought in the ordinary course. For purposes of PAIA, any reference to an application to court includes an application to a Magistrates’ Court.

View the privacy statement:


For more information on your rights to privacy over your information, or the information processing activities of COMPANY, please do not hesitate to contact us directly:
Email Address:
Telephone Number: +27 21 511 7250

Date of last update: 10 June ‘21

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