Trigger PAIA Manual
TRIGGER SYSTEMS (Pty) Ltd
2016/460285/07
Table of Contents
1. Introduction.……………………………………………………………………………………………………………………………………………………………………………………………………………………………………....……………………………………….
2. Structure of Organisation/Company...………………………………………………………………………………………………………………………………………………………………………………......................................................
i Board of Directors
3. Location...…………………………………………………………………..……………..………………………………………………………………………………..……………..………………………………………………………………………………………………....
4. Information Officer...…………………………………………………………………………………………………………..……………..…………………………………………………………….....……………………………………………….…………...…...
5. Guide on how to use the Act.……………………………………………………………………………………………………..……………..…………………………………………………………….....……………………………………………………....
6. Legislation...………………………………………………………………………………………………………………………………………………………………………………..……………..……………………………………...………………………………….…....
7. Records held by the organization...…………………………………………………………………………………………………………………………………..……………..…………………………………………………………….....……………...
8. Categories of records available without recourse to the promotion of access to the Information Act (PAIA).…...…………………………………………………………….…..……....
9. Protection of Personal Information Policy...…………………………….…………………………...………….…......………………………………………………………………………………………………………..……………..…..........
10. Accessing records held by the Company through PAIA...…………………………………………………………………………………………………………………………………………..……………..………...................…
10.1 Appeals ...………………..………………………………………………………………………..…….………………………………………………………………..…….………………………………………………………………..…….………......................
11. Services of the Organisation...……………..……………………………………………………………..……………………………………………………………..……………………………………………………………..……………...………………...
12. Availability of the Manual...……………………………………………………..………………………………………………………………………..………………………………………………………………………..……………………………………….
13. PAIA FORMS...……………………………………………………….………………………………………………………………………………………..………………………………………………………………………..…………………………………................
1. INTRODUCTION
The Company focuses on providing Safety and Security related solutions to both the residential and commercial market.
2. STRUCTURE OF ORGANISATION / COMPANY
The Company is a Private Company with the following Board of Directors:
Cawood, Werner
Lessing, Adriaan Johannes
Kruger, Morne
3. LOCATION
Physical Address
305 Melk Street
Nieuw Muckleneuk
Pretoria
0081
0145
Postal Address
As above
Contact
https://trigger.co.za/
010 824 0620
4. INFORMATION OFFICER
The information officer for the Company is as follows:
Werner Cawood
Physical Address
305 Melk Street
Nieuw Muckleneuk
Pretoria
0081
0145
Postal Address
As above
Contact
https://www.trigger.co.za/
010 824 0620
5. GUIDE ON HOW TO USE THE ACT
The Company has a hard copy of this guide at the above address and an electronic version.
6. LEGISLATION
The Company holds information in terms of but not limited to the following legislation:
i. Basic Conditions of Employment Act, No 75 of 1997;
ii. Companies Act, No 71 of 2008;
iii. Compensation for Occupational Injuries & Diseases Act, 130 of 1993;
iv. Competition Act, No.71 of 2008;
v. Constitution of the Republic of South Africa;
vi. Copyright Act, No 98 of 1978;
vii. Customs and Excise Act, 91 of 1964;
viii. Electronic Communications Act, No 36 of 2005;
ix. Electronic Communications and Transactions Act, No 25 of 2002;
x. Employment Equity Act, No 55 of 1998;
xi. Financial Intelligence Centre Act, No 38 of 2001;
xii. Income Tax Act, No 58 of 1962;
xiii.Intellectual Property Laws Amendment Act, No 38 of 1997;
xiv. Labour Relations Act, No 66 of 1995;
xv. Occupational Health & Safety Act, No 85 of 1993;
xvi. Prescription Act, No 68 of 1969;
xvii. Prevention of Organised Crime Act, No 121 of 1998;
xviii. Promotion of Access to Information Act, No 2 of 2000;
xix. Protection of Personal Information Act, No. 4 of 2013;
xx. Regulation of Interception of Communications and Provision of Communication Related Information Act 70 of 2002;
xxi. Revenue laws Second Amendment Act. No 61 of 2008;
xxii. Skills Development Levies Act No. 9 of 1999;
xxiii. Unemployment Insurance Contributions Act 4 of 2002;
xxiv.Unemployment Insurance Act No. 30 of 1966.
7. RECORDS HELD BY THE ORGANISATION
a. Records Management System
Each of the business units at the Company holds records related to that unit. Where possible records are kept in electronic format. In cases where records cannot be transferred or cannot be converted to electronic form such documents are filed and stored in shelves managed by each unit.
Each business unit undertakes to comply with the provisions of POPI, assisted by the reasonable party and / operator, to ensure that personal information is stored with the utmost care and diligence.
b. Categories of Records held
Operational Information is generally not accessible to persons outside the company or persons without the requisite authorization or justification.
i. Administration
▪ Financial & Management Reports
▪ Banking Records
▪ Audited Financial statements and SARS returns
▪ Income tax statements
▪ Files relating to the appointment of staff
▪ Insurance
▪ Work reviews, appraisals, leave forms, etc
▪ Correspondence with Associations
▪ Requisitions & Invoices
▪ Internal phone lists & address lists
▪ Company policies & procedures
▪ Budgets, accounts, banking & monthly reconciliations
▪ Audited financial statements & SARS returns
▪ Contracts: staff, clients, employee records
ii. Operational documentation
▪ Newsletters & marketing material
▪ Client consultations
▪ Client database (personal information)
▪ Sensitive client information (Debit order mandates / banking information)
▪ All documentation relating to client services
▪ All documentation relating to supplier rates
8. CATEGORIES OF RECORDS AVAILABLE WITHOUT RECOURSE TO THE PROMOTION OF ACCESS TO INFORMATION ACT (PAIA)
The Company also holds some documents which are already available to the public and records which can be accessible without using PAIA.
I. Website(s): https://trigger.co.za/
II. Advertising & marketing brochures/pamphlets
III. Letterheads, invoices, telephone directory entries
IV. Press releases and magazine adverts
V. Companies’ registration details at CIPC
VI. VAT Number
9. PROTECTION OF PERSONAL INFORMATION (POPI) POLICY
Data Protection Principles as required by POPI:
• Accountability – the Company as the responsible party and operator, with the assistance of the Information Officer, shall ensure that all data processed, used, received, and / or requested shall be stored in the requisite company database for such time as the personal information is needed to complete requested services or for a reasonable time after said requested services are completed.
• All records held by the Company shall be done in compliance with POPI, including the retention time and destruction of personal information.
• Processing Limitation – the Company shall ensure that all information processed is done lawfully and within the ambit of the services requested. Personal information processed by the Company shall be adequate for purpose, reasonable, and not excessive.
• Purpose Specification – Personal information must be collected for a specific, explicitly defined and lawful purpose related to a function or activity of the Company. the Company as responsible party and operator undertakes to ensure that the data subject is aware at all material times of the purpose of the collection of information unless s18(4) of POPI is applicable (circumstances when the non
compliance is permitted).
• Further Processing Limitation – the further processing of personal information, once collected and received, must be in accordance or compatible with the purpose for which it was collected. the Company will further need to assess the information collected with a view of identifying what form of processing and / or storage is necessary for the personal information at hand. Factors influencing the aforesaid will include, inter alia, the nature of the information; consequences of the further processing of the information; manner in which the information has been collected; and any contractual rights and obligations between the parties.
• Information Quality – the Company and its Information Officer shall take reasonably practicable steps to ensure that the personal information is complete, accurate, not misleading and updated, from time to time, where necessary. the Company must further have regard for which personal
information is collected and further processed.
• Openness – In terms of section 14 of POPI and section 51 of PAIA, the Company must maintain the documentation of all processing operations under its responsibility.
• Security Safeguards – the Company undertakes to treat all personal information collected as confidential and shall not disclose it unless required by law or in the course of the proper performance of their duties (in compliance with sections 19, 20, 21 and 22 of POPI read with the security safeguards and procedure recorded hereunder.
• Data Subject Participation – a data subject, having provided adequate proof of identity, has the right to, inter alia, request that a responsible party confirm whether or not the responsible party holds the data subject’s personal information. Furthermore, the data subject has the right to have access to the information within reasonable time; at a prescribed fee, if any; and in a reasonable manner and format.
Kindly refer to the Company Website POPI policy for detailed information on the application of the above. The aforesaid can be found on our Website.
For ease of reference and to better understand POPI, follow this link: http://www.justice.gov.za/legislation/acts/2013-004.pdf
10. ACCESSING RECORDS HELD BY THE COMPANY THROUGH PAIA READ WITH POPI PROVISIONS
All requests should be sent to the information Officer, detailing the content of the request on prescribed request forms (attached). The process detailed below has been endorsed by the South African Human Rights Commission (see http://www.sahrc.org.za/guideline.doc)
a. The Process
i. The person requesting information should complete the prescribed form and address the request to the Information Officer, using the address, & e-mail address indicated.
ii. Sufficient detail should be provided on the request form to enable the Information Officer to identify the record and the source of the request. Contact details for the requester should be indicated.
iii. 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.
iv. If a request is made on behalf of another person, the requester must submit proof of his capacity to the information Officer.
b. Prescribed Fees
The fees (as per Government Notice no R187) as amended are:
The fees for reproduction are as follows:
(1) For every photocopy of an A4-size page or part thereof – R1.10
(2) For every printed copy of an A4-size page or part thereof held on a computer or in electronic machine-readable form – R 0.75
(3) For every printed copy of an A4-size page or part thereof held on a computer or in electronic or machine-readable form:
a. For a copy in a computer-readable form on compact disc - R70
b. For a transcription of visual images, for an A4 size page or part thereof – R40
(4) For a copy of visual images - R60
(5) For a transcription of an audio record, an A4-size page or part thereof – R20
(6) For a copy of visual images – R60
c. The request fee payable by a requester, other than a personal requester, referred to in regulation 11(2) is R50.00.
d. The access fees payable by a requester referred to in regulation 11(3) are as follows:
i. For every photocopy of an A4-size page or part thereof – R1.10
ii. 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
iii. For a copy on compact disc – R70
iv. For a transcription of visual images, for an A4-size page or part thereof – R40
v. For a transcription of an audio record, for an A4 page or part thereof – R20
vi. For a copy of an audio record - R30
vii. To search for and prepare the record for disclosure, R30 for each hour or part of an hour reasonably required for such search and preparation. viii. For purposes of of the Act, the following applies:
(1) Six hours as the hours to be exceeded before a deposit is payable; and
(2) One third of the access fee is payable as a deposit by the requester.
ix. The actual postage is payable when a copy of the record must be posted to a requester.
11. APPEALS
In terms of PAIA [Section 56(3)(c)] a requester may lodge an application with a court, within 30 days of being informed of any decision of an Information Officer of the Company on any request, for relief against the refusal of the request, and the procedure (including the period) for lodging the application.
12. SERVICES OF THE ORGANISATION
For more information on the services of the organization or a copy of this Manual, please contact the Company and please send your inquiries to:
Physical Address
305 MELK STREET
NIEUW MUCKLENEUK
PRETORIA
GAUTENG
0081
0145
Postal Address
As above
Contact
https://www.trigger.co.za/
010 824 0620
13. PAIA FORMS
FORM C - Click here to Download
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]
Attention: The Information Officer:
305 MELK STREET,
NIEUW MUCKLENEUK,
PRETORIA,
GAUTENG,
0081
010 824 0620
NB: Completed document must be sent to [email protected] (with attachments where applicable) marked for attention Information Officer.