Compiled By: Natasha Colyn Authorised By: Juliette Fourie CEO SIGNATURE Created: 28 June 2021 Next revision: as and when required METRO MINDS (PTY) LTD Registration number 2010/008164/07 PAIA AND POPIA MANUAL in terms of Section 51 of the Promotion of Access to Information Act No. 2 of 2000 as amended (“PAIA”) and Section 55 of the Protection of Personal Information Act No. 4 of 2013 as amended (“POPI Act”)
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Registration number 2010/008164/07 PAIA AND POPIA MANUAL
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Compiled By: Natasha Colyn
Authorised By: Juliette Fourie CEO
SIGNATURE
Created: 28 June 2021
Next revision: as and when required
METRO MINDS (PTY) LTD
Registration number 2010/008164/07
PAIA AND POPIA MANUAL in terms of Section 51 of the Promotion of Access to Information Act No. 2 of 2000
as amended (“PAIA”) and Section 55 of the Protection of Personal Information Act No. 4 of 2013 as
amended (“POPI Act”)
POLICY DOCUMENT
Metro Minds Pty Ltd PAIA and POPIA Manual
Rev No.: 002
Page No.: Page 1 of 15
Date revised
28 June 2021
Next Revision Date:
As and when required
2 | P a g e U P D A T E D J U N E 2 0 2 1
- INDEX -
1. Definitions 4
2. Introduction and Purpose of the Manual 5
3. Availability & updating of the manual 5
4. The Act 5
5. Availability of PAIA Guide 6
6. Applicable legislation 6
7. The Company’s processing of personal information 7
8. The purpose of processing of personal information by the Company 7
9. Categories of data subjects & personal information processed by the Company 8
10. Recipients/categories of recipients with whom personal information is shared 9
11. Type of company records with Classification key (refer to point 12 below for
information on Classification key) 10
12. Company record classification key 11
13. Information security measures to protect personal information 12
14. Personal information received from third parties 12
15. Company information & contact details of the information officer & data privacy
protection officer 12
16. Decision to grant access to records 13
17. Process to obtain information from the Company 13
a. To facilitate the processing of request/s, kindly: 13
b. Prescribed fees 13
c. Access to prescribed forms and fees 14
18. Grounds for refusal of access to records in terms of PAIA 14
19. Information or records not found 15
20. Remedies available to the requester upon refusal of a request for access in terms
of PAIA 15
POLICY DOCUMENT
Metro Minds Pty Ltd PAIA and POPIA Manual
Rev No.: 002
Page No.: Page 1 of 15
Date revised
28 June 2021
Next Revision Date:
As and when required
3 | P a g e U P D A T E D J U N E 2 0 2 1
This document or any part thereof may not be transmitted, transcribed, reproduced,
or stored, in any form or by any means, without the prior written permission of Metro
Minds (Pty) Ltd. Any unauthorised reproduction or adaptation of this document will
constitute a copyright infringement and render the doer liable under both civil and
criminal law.
REVISION HISTORY
REVISION
NO
DATE DESCRIPTION AUTHOR
001 06/2021 INITIAL RELEASE N Colyn
POLICY DOCUMENT
Metro Minds Pty Ltd PAIA and POPIA Manual
Rev No.: 002
Page No.: Page 1 of 15
Date revised
28 June 2021
Next Revision Date:
As and when required
4 | P a g e U P D A T E D J U N E 2 0 2 1
1. Definitions 1.1. Company means Metro Minds (Pty) Ltd (registration number
2010/008164/07), a company duly registered and incorporated with limited
liability in accordance with the company laws of the Republic of South
Africa and having its principal place of business situated at Unit 41 Villa
Valencia Office Park, 2 Anemoon Street, Glen Marais, Kempton Park.
1.2. Conditions for Lawful Processing means the conditions for the lawful
processing of Personal Information as fully set out in chapter 3 of POPIA.
1.3. Constitution means the Constitution of the Republic of South Africa, 1996.
1.4. Customer refers to any natural or juristic person that received or receives
services from the Company.
1.5. Data Subject has the meaning ascribed thereto in section 1 of POPIA.
1.6. Head of the Company means the “head” as defined in section 1 of PAIA
and referred to in point 15.
1.7. Information Officer means duly appointed person responsible to whom
requests for access to information must be made in terms of the Act.
Referred to in point 15.
1.8. Manual means this manual prepared in accordance with section 51 of
PAIA and regulation 4(1) (d) of the POPIA Regulations.
1.9. PAIA means the Promotion of Access to Information Act, 2000.
1.10. Personal Information has the meaning ascribed thereto in section 1 of
POPIA.
1.11. Personnel refers to any person who works for or provides services to or on
behalf of the Company and receives or is entitled to receive remuneration
and any other person who assists in carrying out or conducting the business
of the Company, which includes, without limitation, directors (executive
and non-executive), all permanent, temporary and part-time staff as well
as contract workers.
1.12. POPIA means the Protection of Personal Information Act, 2013.
1.13. POPIA Regulations mean the regulations promulgated in terms of section
112(2) of POPIA.
1.14. Private Body has the meaning ascribed thereto in sections 1 of both PAIA
and POPIA.
1.15. Processing has the meaning ascribed thereto in section 1 of POPIA.
1.16. Responsible Party has the meaning ascribed thereto in section 1 of POPIA.
1.17. Record has the meaning ascribed thereto in section 1 of PAIA and includes
Personal Information.
1.18. Requester has the meaning ascribed thereto in section 1 of PAIA.
1.19. Request for Access has the meaning ascribed thereto in section 1 of PAIA;
and
1.20. SAHRC means the South African Human Rights Commission.
Capitalised terms used in this Manual have the meanings ascribed thereto in section 1 of POPIA
and PAIA as the context specifically requires, unless otherwise defined herein.
POLICY DOCUMENT
Metro Minds Pty Ltd PAIA and POPIA Manual
Rev No.: 002
Page No.: Page 1 of 15
Date revised
28 June 2021
Next Revision Date:
As and when required
5 | P a g e U P D A T E D J U N E 2 0 2 1
2. Introduction and Purpose of the Manual Metro Minds (Pty) Limited (the “Company”) conducts business as a training provider
who respects the privacy of personal information, which is detailed in the Company’s
Privacy Policy and explains how the Company collects and uses personal information.
This PAI and POPIA Manual (“Manual”) provides an outline of the type of records and
the personal information the Company holds and explains how to submit requests for
access to these records in terms of the Promotion of Access to Information Act 2 of
2000 (“PAIA Act”). It also explains how to access, or object to, personal information
held by the Company, or request correction of the personal information, in terms of
paragraphs 23 and 24 of the Protection of Personal Information Act 4 of 2013 (“POPI
Act”).
In addition, this manual sets out the responsibilities of the Company’s appointed
Information Officer as well as the Data Privacy Protection Officer who will take up the
duties mandated in PAIA and POPIA, to ensure compliance with PAIA and POPIA.
3. Availability & updating of the manual • This Manual is made available in terms of PAIA and section 4 of the
Regulations to POPIA.
• This Manual is also available at: https://www.metrominds.co.za
• This Manual is further available at the offices of Metro Minds Pty offices for
inspection during normal business hours.
• No fee will be levied for inspection as contemplated in this clause.
• Copies of the Manual can be obtained from the Information Officer. A fee will
be levied for copies of the manual – refer to point 17 for details.
This manual will be updated whenever we make material changes to the current
information.
4. The Act The Promotion of Access to Information Act, 2000 (“PAIA”) gives effect to section 32
of the Constitution, which provides that everyone has the right to access information
held by the state, as well as information held by another person (or private body)
when such privately held information is required to exercise a right or to protect a
right.
PAIA, provides that a person requesting information must be given access to any
record of a private body, if that record is required for the exercise or the protection of
a right. However, such request must comply with the procedural requirements laid
down by the Act.
All requests shall be made in accordance with the prescribed procedures, at the rates
provided. The forms and tariff are dealt with in point 17 of this manual.