PAIA MANUAL

MANUAL NUMBER: CD_MAN_001_SSH_V1

MISSION STATEMENT

To provide leading business solutions that make the world a safer place, providing excellence in risk management, health and safety services.

VALUE STATEMENT

1. Introduction and Purpose

   On the 9th of March 2001, the Promotion of Access to Information Act, No 2 of 2000 (“the Act”) became operative, giving effect to the section 32(2) Constitutional right of access to information.

   One of the main requirements specified in the Act, 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 the company’s information manual and provides references to the records held by the company and the process to request access to such records.

2. Scope

   The scope of the manual is limited to the records held by Safety SA.

3. Information requires under Section 51(1)(a) of the Act

   Designated Head of Safety SA:	Pieter Erasmus
   Street Address of Safety SA:	Porta Nova Building, Gazelle Close, Corporate Park South, Old Pretoria Road, Randjesfontein, Midrand, 1683, South Africa
   Tel. No of Safety SA:	+27 87 286 8222
   E-Mail address of Safety SA:	compliance@safetysa.com

   The responsibility for administration of, and compliance with the Act has been delegated to the Deputy

   Information Officers. Requests pursuant to the provision of the Act should be directed as follows:

   Person delegated to deal with requests:

   Appointment	Name	Email Address
   Information Officer	Pieter Erasmus (Chief Executive Officer)	compliance@safetysa.com
   Deputy Information Officer	Palesa Gaasenwe (Chief Information Officer)	compliance@safetysa.com
   Deputy Information Officer	Karen de Jager (Group Compliance Executive)	compliance@safetysa.com

   We may collect Personal Data about you in the following ways:

   • Directly from you, such as through the application and hiring process (online or in person)
   • During your activities in the course of your employment, such as through your performance and interaction with other Employees, contractors, customers, or other individuals, or through your use of our systems, Intranet or the Human Resources services that we offer through our Intranet or Talent online service, and other similar applications; and
   • From other parties, subject to the requirements of applicable law. These parties may include:
     • Further processing limitation;
     • Information quality;
     • Transparency (honesty and integrity);
     • Security safeguards; and
     • Data subject participation.
4. Description of guide referred to in Section (10)

   A Guide has been compiled in terms of Section 10 of PAIA by the South African Human Rights Commission (SAHRC). It contains information required by a person wishing to exercise any right, contemplated by PAIA. It is available in all of the official languages.

   The Guide is available for inspection, inter alia, at the office of the offices of the Human Rights Commission at The Guide is available for inspection, inter alia, at the office of the South African Human Rights Commission at Braampark Forum 3, 33 Hoofd Street, Braamfontein, Johannesburg, Gauteng and at www.sahrc.org.za.

   For further information please contact the SAHRC:

   Postal Address: Private Bag 2700, Houghton, 2041

   Telephone Number: +27-11-877 3600

   Fax Number: +27-11-403 0625

   Email: mnyuswa@sahrc.org.za

5. Records available in terms of other Legislation

   Records available in terms of other legislation are as follows:

   Administration of Estates Act, No. 66 of 1965	Arbitration Act No. 42 of 1965
   Atmospheric Pollution Prevention Act 45 of 1965	Banks Act No. 94 of 1990
   Basic Conditions of Employment Act No. 75 of 1997	Bills of Exchange Act 34 of 1964
   Broad-based Black Economic Empowerment Act 53 of 2003	Children’s Act 38 of 2005
   Companies Act No 71 of 2008 and Applicable Regulations	Compensation for Occupational Injuries and Health Diseases Act No. 130 of 1993
   Competition Act No. 89 of 1998	Consumer Affairs (Unfair Business Practice) Act No. 71 of 1988
   Consumer Protection Act 68 of 2008	Copyright Act No. 98 of 1978
   Currency and Exchanges Act No .9 of 1933	Customs and Excise Act, 55 of 1998
   Debt Collector’s Act No. 114 of 1998	Electronic Communications Act, No. 36 of 2005
   Electronic Communications and Transactions Act No 25 of 2002	Employment Equity Act. No. 55 of 1998
   Exchange Control Amnesty and Amendment of Taxation Laws Act of 2003	Explosives Act 26 of 1956
   Financial Advisory and Intermediary Services Act 37 of 2002	Financial Intelligence Centre Act No. 38 of 2001
   Financial Services Board Act No. 97 of 1990	Firearms Control Act 60 of 2000
   Harmful Business Practices Act No. 23 of 1999	Hazardous Substances Act 15 of 1973
   Health Professions Act 56 of 1974	Identification Act 68 of 1997
   Immigration Act 13 of 2002	Income Tax Act No 58 of 1962
   Insider Trading Act 135 of 1998	Insolvency Act No. 24 of 1936
   Insurance Act No. 27 of 1943	Intellectual Property Laws Amendment Act No. 38 of 1997
   Johannesburg Stock Exchange Listing Requirements	Labour Relations Act No 66 of 1995
   Long –Term Insurance Act No. 52 of 1998	Medical Schemes Act 131 of 1998
   Medicines and Related Substances Act 101 of 1965	National Health Act 61 of 2003
   Mine Health and Safety Act 29 of 1996	Mines and Works Act 27 of 1956
   National Credit Act No. 34 of 2005	National Environmental Management Act 107 1998
   National Water Act 36 of 1998	Nonprofit Organisations Act No. 71 of 1997
   Occupational Diseases in Mines and Works Act 78 of 1973	Occupational Health and Safety Act No. 85 of 1993
   Pension Funds Act No 24 of 1956	Prevention and Combating of Corrupt Activities Act No 12 of 2004
   Prevention of Organised Crime Act No. 121 of 1998	Promotion of Access to Information Act No.2 of 2000
   Promotion of Equality and Prevention of Unfair Discrimination Act No. 4 of 2000	Protected Disclosures Act No. 26 of 2000
   Protection of Personal Information Act 4 of 2013	Protection of Constitutional Democracy against Terrorist and Related Activities Act 33 of 2004
   Regulation of Interception of Communication and Provision of Communications Act, No.2 of 2000	Regulation of Interception of Communications and Provisions of Communication Related
   Road Accident Fund Act 56 of 1996	Information Act No. 70 of 2002
   SA Reserve Bank Act No. 90 of 1989	Second-Hand Goods Act No.  6 of 2009
   Securities Services Act No. 36 of 2004	Securities Transfer Tax Act 25 of 2007
   Skills Development Act 97 of 1998	Skills Development Levies Act No 9 of 1999
   South African Reserve Bank Act No.  90 of 1989	South African Schools Act of 1996
   Stock Exchanges Control Act No.  1 of 1985	Supreme Court Act No. 59 of 1959
   Tobacco Products Control Act No 83 of 1993	Trade Marks Act 194 of 1993
   Trust Property Control Act No. 57 of 1988	Unemployment Insurance Act No. 63 of 2001
   Unemployment Insurance Contributions Act No 4 of 2002	Value Added Tax Act No 89 of 1991

6. Records Automatically Available

   No notice has been submitted by the practice to the Minister of Justice and Constitutional Development regarding the categories of records, which are available without a person having to request access in terms of Section 52(2) of PAIA. However, the information on the website of the business is automatically available without having to request access in terms of PAIA.

   Our ability to perform our obligations derived from your employment contract (or similar type of agreement) with Safety SA and our ability to comply with our legal and contractual obligations depend on occasion on Safety SA having access to and being able to use certain Personal Data.

   Therefore, and depending on the circumstances, if you do not provide us with the Personal Data we request or if you ask that we stop processing your Personal Data, we may not be able to perform our contractual obligations (such as paying you for your work), or we may be in breach of one or more legal obligations applicable to us. In some cases, if we are not allowed to process your Personal Data, this may result in us being required to terminate our work relationship with you.

7. Subjects and Categories of Records held by Safety SA

   General information about Safety SA can be accessed via the internet on www.safetysa.com, which is available to all persons who have access to the internet.

   NAME OF HOLDING COMPANY: Safety SA Holdco (Pty) LTD

   NAME OF SUBSIDARIES: Safety SA Holdco (Pty) LTD, consists of 3 brands SafetyCloud, AssureCloud & MetrixCloud

   The Legal Entities for the brands are:

   SafetyCloud: NOSA (PTY) LTD; NOSA LOGISTICS (PTY) LTD (Entities listed hereafter referred to as SafetyCloud) www.safetycloud.co.za

   AssureCloud: ASPIRATA AUDITING TESTING AND CERTIFICATION (PTY) LTD; NATIONAL QUALITY ASSURANCE (PTY) LTD; NOSA AUDITING AND INSPECTION SERVICES (PTY) LTD; SAIGAS AFRICA (PTY) LTD; QUALITY AND SAFETY RISK PROFESSIONAL SERVICES INTERNATIONAL (PTY) LTD T/A QPRO SAI GLOBAL (Entities listed hereafter referred to as AssureCloud) www.assurecloud.co.za

   MetrixCloud: SAFETY SA SOLUTIONS (PTY) LTD (Entity listed hereafter referred to MetrixCloud) www.metrixcloud.online

   The subjects on which the private body holds records and the categories on each subject in terms of Section 51(1)(e) are as listed below. Please note that a requester is not automatically allowed access to these records and that access to them may be refused in accordance with Sections 62 to 69 of the Act:

   Companies Act Records	Financial Records
   All trust deeds; Documents of Incorporation; Index of names of members of the company; Memorandum of Incorporation; Minutes of meeting of the Board of Directors; Minutes of meetings of Shareholders; Proxy forms; Register of debenture-holders; Register of directors’ shareholdings; Research and development; Share certificates; Share Register and other statutory registers and/or records and/or documents; Special resolutions/Resolutions passed at General and Class meetings. Records relating to the appointment of: Auditors; Directors; Prescribed Officer; Public Officer; and Secretary.	Accounting Records Annual Financial Reports; Annual Financial Statements Asset Registers; Bank Statements Banking details and bank accounts; Banking Records Debtors / Creditors statements and invoices; General ledgers and subsidiary ledgers; General reconciliation; Invoices; Paid Cheques Policies and procedures; Rental Agreements; and Tax Returns.
   Income Tax Records	Procurement Records
   PAYE Records Documents issued to employees for income tax purposes Records of payments made to SARS on behalf of employees All other statutory compliances VAT Regional Services Levies Skills Development Levies UIF Workmen’s Compensation	Standard Terms and Conditions for supply of services and products; Contractor, client and supplier agreements; Lists of suppliers, products, services and distribution; and Policies and Procedures.
   Personnel Documents and Records	IT Records
   Accident books and records; Address Lists; Disciplinary Code and Records; Employee benefits arrangements rules and records; Employment Contracts; Employment Equity Plan Forms and Applications; Grievance Procedures; Leave Records; Medical Aid Records; Payroll reports/ Wage register; Pension Fund Records; Safety, Health and Environmental records; Salary Records; SETA records Standard letters and notices Training Manuals; Training Records; Workplace and Union agreements and records.	Computer / mobile device usage policy documentation; Disaster recovery plans; Hardware asset registers; Information security policies/standards/procedures; Information technology systems and user manuals Information usage policy documentation; Project implementation plans; Software licensing; and System documentation and manuals.
   Sales & Marketing  Records	Risk Management and Audit Records
   Customer details Credit application information Information and records provided by a third party Advertising and promotional material Advertising and promotional material	Standard Terms and Conditions for supply of services and products; Contractor, client and supplier agreements; Lists of suppliers, products, services and distribution; and Policies and Procedures.
   Safety, Health and Environment Records
   Complete Safety, Health and Environment Risk Assessment Environmental Managements Plans Inquiries, inspections, examinations by environmental authorities	And any other documents related to service delivery within Safety SA.

8. Purpose of Processing of Personal Data

   To support; sales and marketing activities; recruitment and management of employees; engagement with suppliers; engagement with the general public; engagement with investors and the media.

9. Data Subject Categories and their Personal Data
   • Customers: record of customer life cycle
   • Employees: record of employee life cycle
   • Suppliers: record of supplier life cycle
   • General public: tracking general enquiries and web site visits
   • Investors: records as maintained by the Company Secretary
   • Media: records of media interactions
   • Students: record of student life cycle
10. Planned Recipients of Personal Data
    • Statutory authorities
    • Law enforcement
    • Tax authorities
    • Financial institutions
    • Medical schemes
    • Employee pension and provident funds
    • Insurance bodies
    • Regulatory bodies
    • Accreditation bodies
    • Industry bodies
11. Planned Trans-Border Flows of Personal Data
    • Flows to service providers/operators
    • Flows to business partners
    • Flows to customers
    • Flows to suppliers
    • Flows through the use of social media
12. Security Measures to Protect Personal Data
    • Physical security measures
    • Cyber security measures
    • Training in information security
    • Policies, plans, registers and procedures in information security
    • Audits of information security
    • Any particular security framework implemented
13. Detail on how to make a Request for Access

    The requester must complete Form C and submit this form together with a request fee, to the head of Safety SA. The form must be submitted to compliance@safetysa.com

    Form of request:

    • The requester must use the prescribed form, as attached in terms of Article 8 of this manual, to make the request for access to a record. This must be made to the designated head. This request must be made to the address, fax number or electronic mail address of the body concerned [s 53(1)].
    • The requester must provide sufficient detail on the request form to enable the designated head to identify the record and the requester.
    • The requester should indicate which form of access is required.
    • The requester should indicate if any other manner is to be used to inform the requester and state the necessary particulars to be so informed [s 53(2)(a) and (b) and (c)].
    • The requester must identify the right that is sought to be exercised or to be protected and provide an explanation of why the requested record is required for the exercise or protection of that right [s 53(2)(d)].
    • If a request is made on behalf of another person, the requester must then submit proof of the capacity in which the requester is making the request to the satisfaction of the designated head of the private body [s 53(2)(f)].
    • A requester who seeks access to a record containing personal information about that requester is not required to pay the request fee.
    • Every other requester, who is not a personal requester, must pay the required request fee.
    • The designated head of the private body must notify the requester (other than a personal requester) by notice, requiring the requester to pay the prescribed fee (if any) before further processing the request [s 54(1)].
    • The fee that the requester must pay to a private body is currently R50,00. The requester may lodge an application to the court against the tender or payment of the request fees 54(3)(b)].
    • After the designated head of the private body has made a decision on the request, the requester must be notified in the required form.
    • If the request is granted then a further access fee must be paid for the search, reproduction, preparation and for any time that has exceeded the prescribed hours to search and prepare the record for disclosure [s 54(6)].
14. Grounds for Refusing a Request

    Safety SA has the right to reject any request for information submitted in terms of Sections 62 to 70 of Chapter 4 of the PAIA Act.

15. Availability of the Manual

    A copy of this manual is available to the public on the company’s website, www.safetysa.com, at or on request form the designated contact person referred to in this manual. This manual is available for inspection at the office of Safety SA free of charge.

16. Fees in Respect of Private Body

    The following is a breakdown of the fees structure for the purposes of determining the manner in which fees relating to a request for access to a record of a private body are to be calculated:

    Part III of Regulation 187 published in the Government Gazette on the 15 February 2002:

    1. The fee for a copy of the manual as contemplated in regulation 9(2)(c) is R1,10 for every photocopy of an A4-size page or part thereof.
    2. The fees for reproduction referred to in regulation 11(1) are as follows:
       1. (a) For every photocopy of an A4-size page or part thereof R1,10
       2. (b) For every printed copy of an A4-size page or part thereof held on a computer or in electronic or machine readable form R0, 75
       3. (c) For a copy in a computer-readable form on – (i) stiffy disc R 7, 50; (ii) compact disc R 70,00
       4. (d) (i) For a transcription of visual images, for an A4-size page or part thereof R 40,00, (ii) For a copy of visual images R 60,00
       5. (e) (i) For a transcription of an audio record, for an A4-size page or part thereof R 20,00; (ii) For a copy of an audio record R 30,00
    3. The request fee payable by a requester, other than a personal requester, referred to in Regulation 11(2) is R50,00.
    4. The access fees payable by a requester referred to in Regulation 11(3) are as follows:
       1. For every photocopy of an A4-size page or part thereof R 1,10;
       2. For every printed copy of an A4-size page or part; thereof held on a computer or in electronic or machine-readable form R 0,75;
       3. For a copy in a computer-readable form on – (i) stiffy disc R 7,50; (ii) compact disc R 70,00
       4. (i) For a transcription of visual images, for an A4-size page or part thereof R 40,00; (ii) For a copy of visual images R 60,00
       5. (i) For a transcription of an audio record, for an A4-size page or part thereof R 20,00; (ii) For a copy of an audio record R 30,00
       6. To search for and prepare the record for disclosure, R30,00; for each hour or part of an hour reasonably required for such search and preparation.
    5. For purposes of section 54(2) of the Act, the following applies:
       1. (a) Six hours as the hours to be exceeded before a deposit is payable; and
       2. (b) one third of the access fee is payable as a deposit by the requester.
    6. The actual postage is payable when a copy of a record must be posted to a requester.

Form C: Request for Access to Record of Private Body

In terms of Section 53 (1) of the Promotion of Access to Information Act, 2000 (Act No. 2 of 2000) [Regulation 10]

A. Particulars of private body

The Head (Name of Body) _____________________________________________________________________________

B. Particulars of person requesting access to the record

(a) The particulars of the person who requests access to the record must be given below.

(b) The address and/or fax number in the Republic to which the information is to be sent must be given.

(c) Proof of the capacity in which the request is made, if applicable, must be attached.

Full names and surname: ______________________________________________________________________________

Identity number: ______________________________________________________________________________________

Postal address: _______________________________________________________________________________________

Telephone number: ___________________________________________________________________________________

E-mail address: _______________________________________________________________________________________

Capacity in which request is made, when made on behalf of another person: ____________________________

C. Particulars of person on whose behalf request is made

This section must be completed ONLY if a request for information is made on behalf of another person.

Full names and surname: ______________________________________________________________________________

Identity number: ______________________________________________________________________________________

D. Particulars of record

(a) Provide full particulars of the record to which access is requested, including the reference number if

that is known to you, to enable the record to be located.

(b) If the provided space is inadequate, please continue on a separate folio and attach it to this form.

The requester must sign all the additional folios.

1. Description of record or relevant part of the record: ___________________________________________________
2. Reference number, if available: ______________________________________________________________________
3. Any further particulars of record: ____________________________________________________________________

E. Fees

(a) A request for access to a record, other than a record containing personal information about yourself, will be processed only after a request fee has been paid.

(b) You will be notified of the amount required to be paid as the request fee.

(c) The fee payable for access to a record depends on the form in which access is required and the reasonable time required to search for and prepare a record.

(d) If you qualify for exemption of the payment of any fee, please state the reason for exemption.

Reason for exemption from payment of fees: ___________________________________________________________

______________________________________________________________________________________________________

F. Form of access to record

If you are prevented by a disability to read, view or listen to the record in the form of access provided for in 1 to 4 hereunder, state your disability and indicate in which form the record is required.

Disability: ____________________________________________________________________________________________

Form in which record is required: _____________________________________________________________________

NOTES:

(a) Compliance with your request in the specified form may depend on the form in which the record is available.

(b) Access in the form requested may be refused in certain circumstances. In such a case you will be informed if access will be granted in another form.

(c) The fee payable for access to the record, if any, will be determined partly by the form in which access is requested.

Mark the appropriate choice with an X.

1. If the record is in written or printed form:

• copy of record
• inspection of record

2. If record consists of visual images

(this includes photographs, slides, video recordings, computer-generated images, sketches, etc.):

• view the images copy of the images
• transcription of the images

3. If record consists of recorded words or information which can be reproduced in sound:

• listen to the soundtrack (audio file)
• transcription of soundtrack (written or printed document)

4. If record is held on computer or in an electronic or machine-readable form:

• printed copy of record
• printed copy of information
• derived from the record
• copy in computer readable form
• (stiffy or compact disc)

If you requested a copy or transcription of a record (above), do you wish the copy or transcription to be posted to you? Postage is payable.

• YES
• NO

G. Particulars of right to be exercised or protected

If the provided space is inadequate, please continue on a separate folio and attach it to this form. The requester must sign all the additional folios.

1. Indicate which right is to be exercised or protected: __________________________________________________

1. Explain why the record requested is required for the exercise or protection of the aforementioned right:

_______________________________________________________________________________________________________

H. Notice of decision regarding request for access

You will be notified in writing whether your request has been approved/denied. If you wish to be informed in another manner, please specify the manner and provide the necessary particulars to enable compliance with your request.

How would you prefer to be informed of the decision regarding your request for access to the record? ___________________________________________________________________

Signed at __________________ this ________ day of _____________________________

SIGNATURE OF REQUESTER / PERSON ON WHOSE

BEHALF REQUEST IS MADE