8.3. The recipients or categories of recipients to whom the personal information may be supplied

●     Any firm, organisation or person that GZI SA uses to collect payments and recover debts or to provide a service on its behalf;

●     Any firm, organisation or person that/who provides GZI SA with products or services;

●     Any person who GZI SA has reason to believe to be a data subject’s/consumer’s parent, carer or helper where he/she is unable to handle his/her own affairs because of mental incapacity or other similar issues;

●     Any payment system the GZI SA uses;

●     Regulatory and governmental authorities or ombudsmen, or other authorities, including tax authorities, where the GZI SA has a duty to share information;

●     Credit Bureaux;

●     Third parties to whom payments are made on behalf of employees;

●     Financial institutions from whom payments are received on behalf of data subjects;

●     Any other operator not specified;

●     Employees, contractors and temporary staff; and

●     Agents.

 

               8.4.      Planned transborder flows of personal information

●     Storing information electronically; and

●     Making use of third-party service providers to fulfil a business function on behalf of the GZI SA.

8.5.      General description of information security measures to be implemented by GZI

GZI SA undertakes extensive information security measures to ensure the security, confidentiality, integrity and availability of personal information in our possession. This is supported by appropriate technical and organisational measures designed to ensure that personal data remains confidential and secure against unauthorised or unlawful processing and against accidental loss, destruction or damage.

9.         INFORMATION AVAILABLE IN TERMS OF OTHER LEGISLATION

Information is available in terms of certain provisions of the following legislation to the persons or entities specified in such legislation:

●       Administration of Estates Act 66 of 1965

●       Basic Conditions of Employment Act 75 of 1997

●       Broad-Based Black Economic Empowerment Act 53 of 2003

●       Companies Act 71 of 2008

●       Compensation for Occupational Injuries and Health Diseases Act 130 of 1993

●       Competition Act 89 of 1998

●       Consumer Protection Act 68 of 2008

●       Copyright Act 98 of 1978

●       Customs and Excise Act 91 of 1964

●       Customs Duty Act 30 of 2014

●       Debt Collectors Act 114 of 1998

●       Electronic Communications and Transactions Act 25 of 2002

●       Electronic Communications Act, 36 of 2005

●       Employment Equity Act 55 of 1998

●       Financial Advisory and Intermediary Services Act 37 of 2002

●       Financial Intelligence Centre Act 38 of 2001

●       Income Tax Act 58 of 1962

●       Insolvency Act No. 24 of 1936

●       Labour Relations Act 66 of 1995

●       Merchandise Marks Act 17 of 1941

●       National Credit Act 34 of 2005

●       Occupational Health & Safety Act 85 of 1993

●       Pension Funds Act 24 of 1956

●       Prevention of Organised Crime Act 121 of 1998

●       Prevention and Combating of Corrupt Activities Act 12 of 2004

●       Protection of Personal Information Act 4 of 2013

●       Promotion of Access to Information Act 2 of 2000

●       Promotion of Equality and Prevention of Unfair Discrimination Act 4 of 2000

●       Protected Disclosures Act 26 of 2000

●       Skills Development Act 97 of 1998

●       Skills Development Levies Act 9 of 1999

●       Stamp Duties Act 77 of 1968

●       Unemployment Contributions Act 4 of 2002

●       Unemployment Insurance Act 30 of 1966

●       Value Added Tax Act 89 of 1991

●       Such other legislation as may from time to time be applicable

10.       CATEGORIES OF RECORDS AVAILABLE UPON REQUEST

GZI SA maintains records on the categories and subject matters listed below. Please note that recording a category or subject matter in this manual does not imply that a request for access to such records would be honoured. All requests for access will be evaluated on a case-by-case basis in accordance with the provisions of PAIA.

Please note further that many of the records held by GZI are those of third parties, such as clients and employees, and GZI takes the protection of third-party confidential information very seriously. In particular, where GZI SA acts as professional advisors to clients, their records held are confidential and others are the property of the client and not of GZI. For further information on the grounds of refusal of access to a record please see paragraph 11.5 below. Requests for access to these records will be considered very carefully.  Please ensure that requests for such records are legitimate and in compliance with the PAA and POPIA Acts.

 

Category of records	Records
Internal records The records listed pertain to GZI affairs	●                 Memorandum of Incorporation ●                 Financial records ●                 Operational records ●                 Intellectual property ●                 Marketing records; ●                 Internal correspondence; ●                 Service records; ●                 Statutory records; ●                 Internal policies and procedures; ●                 Minutes of meetings.
Personnel records For the purposes of this section, “personnel” means any person who works for or provides services to or on behalf of GZI SA and receives or is entitled to receive any remuneration and any other person who assists in carrying out or conducting the business of GZI.   This includes partners, directors, all permanent, temporary and part-time staff as well as consultants and contract workers.	●         Any personal records provided to GZI  by itspersonnel; ●         Any records a third party has provided to us about any of their personnel; ●         Conditions of employment and other personnel-related contractual and quasi legal records; ●         Employment policies and procedures; ●         Internal evaluation and disciplinary records; and ●         Other internal records and correspondence.
Client-related records	●	Contracts with the client and between the client and other persons;
Other third-party records Records are kept in respect of other parties, including without limitation joint ventures and consortia to which GZI SA is a party, contractors and sub-contractors, suppliers, service providers, and providers of information regarding general market conditions.    In addition, such other parties may possess records which can be said to belong to GZI.	● ●	Personnel, client, or GZI records which are held by another party as opposed to being held by GZI; and Records held by GZI pertaining to other parties, including financial records, correspondence, contractual records, records provided by the other party, and records third parties have provided about the contractors or suppliers.
Other records	●	Information relating to GZI; and
	●	Research information belonging to GZI or carried out on behalf of a third party.

 

11.       REQUEST PROCEDURE

               11.1.    Completion of the prescribed form

Any request for access to a record in terms of PAIA must substantially correspond with Form C of Annexure B to Government Notice No. R.187 dated 15 February 2002 and should be specific in terms of the record requested. Please complete the prescribed form attached hereto as Appendix A and submit it to the Information Officer at the postal or physical address or electronic mail address:

Alphina.Kekae@gzican.com (See Appendix A hereto.)

A request for access to information which does not comply with the formalities as prescribed by PAIA will be returned to you.

POPIA provides that a data subject may, upon proof of identity, request GZI SA to confirm, free of charge, all the information it holds about the data subject and may request access to such information, including information about the identity of third parties who have or have had access to such information.

POPIA also provides that where the data subject is required to pay a fee for services provided to him/her, GZI must provide the data subject with a written estimate of the payable amount before providing the service and may require that the data subject pays a deposit for all or part of the fee.

Grounds for refusal of the data subject’s request are set out in PAIA and are discussed below.

POPIA provides that a data subject may object, at any time, to the processing of personal information by GZI SA, on reasonable grounds relating to his/her particular situation, unless legislation provides for such processing.

The data subject must complete the prescribed form attached hereto as Appendix C - Form 1 and submit it to the Information Officer at the postal or physical address or electronic mail address: alphina.kekae@gzican.com.

Section 24 of POPIA provides that a data subject having provided adequate proof of identity may request access to personal information as per Appendix D - Form 3 by submitting a request to the Information Officer at the postal or physical address or electronic mail address: alphina.kekae@gzican.com.

A data subject may also request GZI to correct or delete personal information about the data subject in its possession or under its control that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully; or destroy or delete a record of personal information about the data subject that GZI SA is no longer authorised to retain records in terms of POPIA's retention and restriction of records provisions.

A data subject that wishes to request a correction or deletion of personal information or the destruction or deletion of a record of personal information must submit a request to the Information Officer at the postal or physical address or electronic mail address: alphina.kekae@gzican.com set out above on the form, attached hereto as Appendix E - Form 2.

               11.2.    Proof of identity

Proof of identity is required to authenticate your identity and the request. You will, in addition to this prescribed form, be required to submit acceptable proof of identity such as a certified copy of your identity document or other legal forms of identity.

               11.3.    Payment of the prescribed fees

There are two categories of fees which are payable:

● The request fee: R50

● The access fee: This is calculated by taking into account reproduction costs, search and preparation costs, as well as postal costs. These fees are set out in Appendix B.

Section 54 of PAIA entitles GZI SA to levy a charge or to request a fee to enable it to recover the cost of processing a request and providing access to records. The fees that may be charged are set out in Regulation 9(2)(c) promulgated under PAIA.

When a decision to grant a request has been taken, the record will not be disclosed until the necessary fees have been paid in full.

               11.4.    Timelines for consideration of a request for access

Requests will be processed within 30 (thirty) days, unless the request contains considerations that are of such a nature that an extension of the time limit is needed.

Should an extension be required, you will be notified, together with reasons explaining why the extension is necessary.

               11.5.    Grounds for refusal of access and protection of information

There are various grounds upon which a request for access to a record may be refused.  These grounds include:

●       the protection of personal information of a third person (who is a natural person) from unreasonable disclosure;

●       the protection of commercial information of a third party (for example: trade secrets; financial, commercial, scientific or technical information that may harm the commercial or financial interests of a third party);

●       if disclosure would result in the breach of confidence owed to a third party;

●       if disclosure would jeopardise the safety of an individual or prejudice or impair certain property rights of a third person;

●       if the record was produced during legal proceedings, unless that legal privilege has been waived;

●       if the record contains trade secrets, financial or sensitive information or any information that would put GZI (at a disadvantage in negotiations or

prejudice it in commercial competition); and/or

●       if the record contains information about research being carried out or about to be carried out on behalf of a third party or by GZI.

Section 70 of the PAIA contains an overriding provision wherein the Ddsclosure of a record is compulsory if it would reveal (i) a substantial contravention of, or failure to comply with the law; or (ii) there is an imminent and serious public safety or environmental risk; and (iii) the public interest in the disclosure of the record in question clearly outweighs the harm contemplated by its disclosure.

If the request for access to information affects a third party, then such a third party must first be informed within 21 (twenty-one) days of receipt of the request. The third party would then have a further 21 (twenty-one) days to make representations and/or submissions regarding the grantof access to the record.

12.                   REMEDIES AVAILABLE ON THE REFUSAL OF ACCESS

If the Information Officer decides to grant access to the particular record, such access must be granted to the requester within 30 (thirty) days of being informed of the decision.

There is no internal appeal procedure that may be followed after a request to access information has been refused. The decision made by the Information Officer is final. In the event that you are not satisfied with the outcome of the request, you are entitled to apply to a court of competent jurisdiction to take the matter further.

Where a third party is affected by the request for access and the Information Officer has decided to grant the access to the record, the third party has 30 (thirty) days in which to appeal the decision in a court of competent jurisdiction. If no appeal has been lodged by the third party within 30 (thirty) days, the requester will be granted access to the record.

13.       AVAILABILITY OF THIS MANUAL

Copies of this Manual are available for inspection, free of charge, at the offices of GZI and at www.gzican.com

APPENDIX A

FORM C: REQUEST FORM

ACCESS REQUEST FORM

Requests can be submitted either via post or e-mail: popia-io@GZI.co.za and should be addressed to the

Information Officer.

REQUEST FOR ACCESS TO THE RECORD OF A PRIVATE BODY

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:

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 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:

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

C.              Particulars of person on whose behalf request is made

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

Disability:

Form in which record is required:

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 (CD)        Transcription of soundtrack*

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

Printed copy of

Copy in computer readable

* 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
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.

Printed copy of record*information derived from form*(CD) record* G.

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

2.    Explain why the record requested is required for the exercise or protection of the aforementioned

right:

H. Notice of decision regarding request for access

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

	YOU MUST			SEND WITH THIS APPLICATION
1     Complete all necessary spaces			1      The request fee
2     Sign the access request form Sign			2    Any additional folios completed
3     Sign additional folios completed			3      Copy of Identity Document

Signed at .......................................... this ...................... day of ...........................20………...

............................................................

Signature of Requester/Person on behalf of whom request is made

APPENDIX B

FEES IN RESPECT OF PRIVATE BODIES

Description		Rand
1	The fee for a copy of the manual as contemplated in regulation 9(2)(c) - for every photocopy of an A4-size page or part thereof.	1,10
2	The fees for reproduction referred to in regulation 11(1) are as follows:
(a)	For every photocopy of an A4-size page or part thereof	1,10
(b)	For every printed copy of an A4-size page or part thereof held on a computer or in electronic or machine-readable form	0,75
(c)	For a copy in a computer-readable form on -
(ii)	compact disc	70,00
(d)(i)	For a transcription of visual images, for an A4-size page or part thereof	40,00
(ii)	For a copy of visual images	60,00
(e)(i)	For a transcription of an audio record, for an A4-size page or part thereof	20,00
(ii)	For a copy of an audio record	30,00
3	The request fee payable by a requester, other than a personal requester, referred to in regulation 11(2)	50,00
4	The access fees payable by a requester referred to in regulation 11(3) are as follows:
4.1(a)	For every photocopy of an A4-size page or part thereof	1,10
(b)	For every printed copy of an A4-size page or part thereof held on a computer or in electronic or machine readable form	0,75
(c)	For a copy in a computer-readable form on -
(i)	compact disc	70,00
(d)(i)	For a transcription of visual images, for an A4-size page or part thereof	40,00
(ii)	For a copy of visual images	60,00
(e)(i)	For a transcription of an audio record, for an A4-size page or part thereof	20,00
(ii)	For a copy of an audio record	30,00
(f)	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.
4.2	For purposes of section 54(2) of the Act, the following applies:
(a)	Six hours as the hours to be exceeded before a deposit is payable; and
(b)	one third of the access fee is payable as a deposit by the requester.
4.3	The actual postage is payable when a copy of a record must be posted to a requester.

 

 

APPENDIX C

FORM 1

OBJECTION TO THE PROCESSING OF PERSONAL INFORMATION IN TERMS OF SECTION 11(3) OF

THE PROTECTION OF PERSONAL INFORMATION ACT, 2013 (ACT NO.  4 OF 2013)

Requests can be submitted either via post or e-mail: alphina.kekae@gzican.com and should be addressed to the Information Officer.

REGULATIONS RELATING TO THE PROTECTION OF PERSONAL INFORMATION, 2018

[Regulation 2]

Note:

1.                Affidavits or other documentary evidence as applicable in support of the objection may be attached.

2.                If the space provided for in this Form is inadequate, submit information as an Annexure to this Form and sign each page.

3.                Complete as is applicable.

A	DETAILS OF DATA SUBJECT
Name(s) and surname/ registered name of data subject:
Unique Identifier/ Identity Number
Residential, postal or business address:
	Code (         )
Contact number(s):
E-mail address:
B	DETAILS OF RESPONSIBLE PARTY
Name(s) and surname/ Registered name of responsible party:

Signed at .......................................... this ...................... day of ...........................20………...

............................................................

Signature of data subject/designated person

APPENDIX D

FORM 3

ACCESS TO PERSONAL INFORMATION

REQUEST FOR ACCESS TO PERSONAL INFORMATION IN TERMS OF SECTION 23 OF THE

PROTECTION OF PERSONAL INFORMATION ACT, 2013 (ACT NO. 4 OF 2013)

Requests can be submitted either via post or e-mail: alphina.kekae@gzican.com and should be addressed to the Information Officer.

Name of Responsible Party request is made to:

Mrs.      Ms.    Miss	Last Name :
First Name :	Middle name :
Address : (Street/Apt. No./PO Box)	City :
Province :	Postal Code :
Telephone Number (Day)       )	Telephone Number (Eevening)       )
Detailed description of requested records and/or personal information. (If you are requesting access to your personal information, please identify the personal information record containing the personal information, if known.)

Responsible party us	e
Date Received:	Request Number:	Comments:

 

Personal Information contained on this form is collected pursuant to the Protection of Personal Information Act, 2013 and will be used for the purpose of responding to your request. Questions about this collection should be directed to the Information Officer of the Responsible Party.

 

APPENDIX E

FORM 2

REQUEST FOR CORRECTION OR DELETION OF PERSONAL INFORMATION OR DESTROYING OR

DELETION OF RECORD OF PERSONAL INFORMATION IN TERMS OF SECTION 24(1) OF THE

PROTECTION OF PERSONAL INFORMATION ACT, 2013 (ACT NO. 4 OF 2013)

Requests can be submitted either via post or e-mail: alphina.kekae@gzican.com and should be addressed to the Information Officer.

REGULATIONS RELATING TO THE PROTECTION OF PERSONAL INFORMATION, 2018

[Regulation 3]

Note:

1.            Affidavits or other documentary evidence as applicable in support of the request may be attached.

2.            If the space provided for in this Form is inadequate, submit information as an Annexure to this Form and sign each page.

3.            Complete as is applicable.

Mark the appropriate box with an "x". Request for:

Correction or deletion of the personal information about the data subject which is in possession or under the control of the responsible party.

Destroying or deletion of a record of personal information about the data subject which is in possession or under the control of the responsible party and who is no longer authorised to retain the record of information.

A	DETAILS OF THE DATA SUBJECT
Name(s) and surname / registered name of data subject:
Unique identifier/ Identity Number:
Residential, postal or business address:
	Code (          )
Contact number(s):

 

E-mail address:
B	DETAILS OF RESPONSIBLE PARTY
Name(s) and surname / registered name of responsible party:
Residential, postal or business address:
	Code (         )
Contact number(s):
E-mail address:
C	INFORMATION TO BE CORRECTED/DELETED/ DESTRUCTED/ DESTROYED
D	REASONS FOR *CORRECTION OR DELETION OF THE PERSONAL INFORMATION ABOUT THE DATA SUBJECT IN TERMS OF SECTION 24(1)(a) WHICH IS IN POSSESSION OR UNDER THE CONTROL OF THE RESPONSIBLE PARTY ; and/or REASONS FOR *DESTRUCTION OR DELETION OF A RECORD OF PERSONAL INFORMATION ABOUT THE DATA SUBJECT IN TERMS OF SECTION 24(1)(b) WHICH THE RESPONSIBLE PARTY IS NO LONGER AUTHORISED TO RETAIN. (Please provide detailed reasons for the request)

 

Signed at .......................................... this ...................... day of ...........................20………...

............................................................

Signature of data subject/ designated person