It’s about access

Promotion of access to information policy: PAIA

This manual was prepared in accordance with section 51 of the promotion of access to information act 2000 (“The Act”) and to address requirements of the protection of personal information act, 2013 (“POPI”). This manual is intended to assist persons wishing to access information, it terms of the Act, from Secure Citizen. This manual applies to Secure Citizen. Registration number No: 2019/547916/07. Registered Office Address. Silverpoint Office Park 1st FL, building 1, 22 Ealing Crescent, Bryanston (Head Office).
  1. Version control
Version No.Change DateChange DescriptionChanged By
Version 1.003/04/2021Document createdBiancha Kotze
Version 1.110/05/2021Reviewed and editedBrad Scott
Version 1.221/07/2021Final versionBrad Scott

2. Introduction

The Promotion of Access to Information Act, 2000 (the “Act”) gives third parties the right to approach private bodies and the government to request information held by them, which is required in the exercise and/or protection of any rights. On request, the private body or government is obliged to release such information unless the Act expressly states that the records containing such information may or may not be released. This manual informs requestors of procedural and other requirements which a request must meet as prescribed by the Act.

3. Nature of business

Secure Citizen offers advanced identification &  verification solutions that help to eliminate the risk of fraud. Through our biometric, customer onboarding and digital identity products and services, we create virtual identifies for consumers to ensure our clients know who they are dealing with.

Contact details

Name of businessSecure Citizen
Head of private bodyPaul Hutton / Dalene Deale
Information officerPaul Hutton
Street addressSilverpoint Office Park 1st FL, floor 1, 22 Ealing Crescent, Bryanston (head Office)
Telephone number010 476 0518
Emailinfo@securecitizen.co.za
Websitewww.securecitizen.co.za

Guide of human rights commission / Information regulator

A guide to the Act (as contemplated under section 10 of the Act) is available from the South African Human Rights Commission. The Act grants a requester access to records of a private body if the record is required for the exercise or protection of any right/s. If a public body lodges a request, it must be acting in the public interest. The guide contains such information as may reasonably be required by a person who wishes to exercise any right contemplated in the Act. 

Any enquiries regarding this guide and its contents should be directed to:

The South African Human Rights Commission:
PAIA Unit
Telephone: +27 11 877 3608
Website: www.sahrc.org.za 
Dr. Shanelle Van Der Berg – svanderberg@sahrc.org.za
Tshepang Sebulela – tsebulela@sahrc.org.za

Alternatively, its successor, 
The Information Regulator (South Africa) 
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001 inforeg@justice.gov.za

Access to records held by the company

Records held by the Company may be accessed on request only once the requirements for access have been met. A requester is any person making a request for access to a record of the Company and in this regard, the Act distinguishes between two types of requesters:

Personal Requester

A personal requester is a requester who is seeking access to a record containing personal information about the requester. Subject to the provisions of the Act and applicable law, the Company will provide the requested information, or give access to any record with regard to the requester’s personal information. The prescribed fee for reproduction of the information requested will be charged by the Company.

Other Requester

This requester (other than a personal requester) is entitled to request access to information pertaining to third parties. However, the Company is not obliged to grant access prior to the requester fulfilling the requirements for access in terms of the Act. The prescribed fee for reproduction of the information requested will be charged by the Company.

Request Procedure

A requester must comply with all the procedural requirements contained in the Act relating to a request for access to a record. A requester must complete the prescribed form enclosed herewith in Appendix 1 and submit same as well as payment of a request fee and a deposit, if applicable to the information officer at the postal or physical address, or electronic mail address stated herein. The prescribed form must be filled in with enough details to at least enable the information officer to identify:

A requester must state that he or she requires the information in order to exercise or protect a right, and clearly state what the nature of the right is so to be exercised or protected. The requester must also provide an explanation of why the requested record is required for the exercise or protection of that right.

The Company will process a request within 30 days, unless the requestor has stated special reasons which would satisfy the information officer that circumstances dictate that this time period not be complied with.

The requester shall be informed in writing as to whether access has been granted or denied. If, in addition, the requester requires the reasons for the decision in any other manner, he or she must state the manner and the particulars so required. 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 information officer.

If an individual is unable to complete the prescribed form because of illiteracy or disability, such a person may make the request orally to the information officer.

Decision

The Company will, within 30 days of receipt of a request, decide whether to grant or decline a request and give notice with reasons (if required) to that effect. The 30 day period within which the Company has to decide whether to grant or refuse a request, may be extended for a further period of not more than 30 days if the request is for a large quantity of information, or the request requires a search for information held at another office of the Company (other than the head office) and the information cannot reasonably be obtained within the original 30 day period. The information officer will notify the requester in writing should an extension be necessary.

Fees

The Act provides for two types of fees:

If a search for the record is necessary and the preparation of the record for disclosure, including arrangement to make it available in the requested form, requires more than the hours prescribed in the regulations for this purpose, the information officer shall notify the requester to pay as a deposit the prescribed portion of the access fee which would be payable if the request is granted.

The information officer shall withhold a record until the requester has paid the fee or fees as indicated. A requester whose request for access to a record has been granted, must pay an access fee for reproduction and for search and preparation, and for any time reasonably required in excess of the prescribed hours to search for and prepare the record for disclosure including making arrangements to make it available in the request form. If a deposit has been paid in respect of a request for access, which is refused, then the information officer shall repay the deposit to the requester.

Categories of records held by the company: section 51(1)(E)

Companies Act Records

Financial Records

Tax Records

Personnel Documents and Records

Consumer records

Processing of personal information

Purpose of Processing

The Company uses the Personal Information under its care in the following ways:

Categories of Data Subjects and their Personal Information. The Company may possess records relating to suppliers, shareholders, contractors service providers, staff and clients:

Entity typePersonal Information Processed
Clients – Juristic Persons / EntitiesNames of contact persons; Name of Legal Entity; Physical and Postal address and contact details; Financial information; Registration Number; Founding documents; Tax-related information; contracts
ClientsNames; registration  number; contact details; physical and postal addresses; Tax-related information; confidential correspondence
End consumerNames, mobile numbers, email addresses. National ID/Passport, voice and/or face biometric
PartnersNames of contact persons; Name of Legal Entity; Physical and Postal address and contact details; Financial information; Registration Number; Tax-related information; authorised signatories, contracts, confidential correspondence
Contracted Services ProvidersNames of contact persons; Name of Legal Entity; Physical and Postal address and contact details; Financial information; Registration Number; Tax-related information; authorised signatories, contracts, confidential correspondence
Employees / DirectorsGender, Pregnancy; Marital Status; Colour, Age, Language, Education information; Financial Information; Employment History; ID number;
Physical and Postal address; Contact details;
Opinions, Criminal behaviour; Well-being; contracts, confidential correspondence

Categories of Recipients for Processing the Personal Information  

The Company may supply the Personal Information to service providers who render the following services:

Actual or Planned Transborder Flows of Personal Information

The Company may transfer data trans-border in order to store data with third party cloud storage providers. 

General Description of Information Security Measures

The Company employs up to date technology to ensure the confidentiality, integrity and availability of the Personal Information under its care. Measures include:

Remedies available if request for information is refused

Internal Remedies

The Company does not have internal appeal procedures. As such, the decision made by the information officer pertaining to a request is final, and requestors will have to exercise such external remedies at their disposal if a request is refused, and the requestor is not satisfied with the response provided by the information officer.

External Remedies

A requestor that is dissatisfied with the information officer’s refusal to disclose information, may within 30 days of notification of the decision, apply to a court for relief. Likewise, a third party dissatisfied with the information officer’s decision to grant a request for information, may within 30 days of notification of the decision, apply to a court for relief. For purposes of the Act, courts that have jurisdiction over these applications are the Constitutional Court, the High Court or another court of similar status, including a Magistrate’s Court designated by the Minister of Justice and Constitutional Development and which is presided over by a designated Magistrate.

List of applicable legislation

Records of the Company’s and other legal entities in which the Company has a direct controlling interest or an indirect controlling interest through its subsidiaries may be kept by or on behalf of the Company in accordance with the following legislation (some of which legislation may not be applicable to the Company), as well as with other legislation that may apply to the Company and/or its subsidiaries from time to time:

Availability of the manual

The manual is available for inspection, on reasonable prior notice, at the office of the company free of charge.

Approval

Assented to on behalf of the company on this 30th June 2021.

Appendix 1: Prescribed form C – To be completed by a requester

Request for access to record of private body (Section 53(1) of the Promotion of Access to Information Act, 2000 (Act No. 2 of 2000) [Regulation 10]

  1. Particulars of private body

The head :

B. Particular of person requesting access to the record

The particulars of the person who requests access to the record must be given below.
The address and/or fax number in the Republic to which the information is to be sent must be given.
Proof of the capacity in which the request is made, if applicable, must be attached.

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

– 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.
– 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.

D. Fees

  1. 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.
  2. You will be notified of the amount required to be paid as the request fee.
  3. 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.
  4. If you qualify for exemption of the payment of any fee, please state the reason for exemption.

Reason for exemption from payment of fees:

E. 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.
DisabilityForm in which record is required:
Compliance with your request in the specified form may depend on the form in which the record is available.
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.
The fee payable for access for the record, if any, will be determined partly by the form in which access is requested.

If the record is in written or printed form:

Copy of recordInspection of record

If record consists of visual images, this includes photographs, slides, video recordings, computer-generated images, sketches, etc.

View images Copy images Transcription of images

If record consists of recorded words or information which can be reproduced:

Listen to the audio fileTranscription of the audio file

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

Print copy of record Print copy of information derived from the record Copy in computer readable form (flash drive or removable media)
If you requested a copy or transcription of a record (above), do you wish the copy or transcription to be postage to you? Postage is payable.YESNO

F. 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:
  2. Explain why the record requested is required for the exercise of protection of the right:

G. 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 …………………….20…………………..

SIGNATURE OF REQUESTER / PERSON ON WHOSE BEHALF REQUEST IS MADE