PAIA MANUAL

MANUAL STATEMENT

This manual, forms part of the manual owner’s internal business processes and procedures.
Any reference to the “FSP” shall be interpreted to include the “manual owner”.
The FSP’s board of directors, its employees, volunteers, contractors, suppliers and any other persons acting on behalf of the FSP are required to familiarise themselves with the manual’s requirements and undertake to comply with the stated processes and procedures.
The Key Individuals of the FSP are responsible for overseeing and maintaining control procedures and activities.

MANUAL ADOPTION

As Head of the abovementioned FSP (JWR Financial Services (Pty) Ltd), I John William Roelofse, hereby authorise the approval and adoption of the processes and procedures outlined herein.

1. DEFINITIONS

1.1 Data Subject The

person to whom Personal Information relates.

1.2 Deputy Information Officer

The person to whom any power or duty conferred or imposed on an Information Officer by POPIA has been delegated.

1.3 Head

In relation to a private body means:

in the case of a natural person, that natural person or any person duly authorised by that natural person;
in the case of a partnership, any partner of the partnership or any person duly authorised by the partnership;
in the case of a juristic person:
- the chief executive officer or equivalent officer of the juristic person or any person duly authorised by that officer; or
- the person who is acting as such or any person duly authorised by such acting person.

1.4 Information Officer

The head of a private body.

1.5 Information Regulator

The Regulator established in terms of Section 39 of POPIA.

1.6 PAIA

The Promotion of Access to Information Act 2 of 2000, as amended from time to time.

1.7 Person

A natural person or a juristic person.

1.8 Personal Information

Information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, including, but not limited to: information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of the person;
Information relating to the education or the medical, financial, criminal or employment history of the person;
Any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier or other particular assignment to the person, the biometric information of the person;
The personal opinions, views or preferences of the person; correspondence sent by the person that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence;
The views or opinions of another individual about the person; and the name of the person if it appears with other personal information relating to the person or if the disclosure of the name itself would reveal information about the person.

1.9 Personal Requester

A requester seeking access to a record containing personal information about the requester.

1.10 POPIA

The Protection of Personal Information Act 4 of 2013, as amended from time to time.

1.11 Private body

a natural person who carries or has carried on any trade, business or profession, but only in such capacity
a partnership which carries or has carried on any trade, business or profession; or
any former or existing juristic person, but excludes a public body.

1.12 Processing

Any operation or activity or any set of operations, whether or not by automatic means, concerning personal information, including the collection, receipt, recording, FSP, collation, storage, updating or modification, retrieval, alteration, consultation or use, dissemination by means of transmission, distribution or making available in any other form, or merging, linking, as well as restriction, degradation, erasure or destruction of information.

1.13 Public body

any department of state or administration in the national or provincial sphere of government or any municipality in the local sphere of government; or
in any other functionary or institution when:
exercising a power or performing a duty in terms of the Constitution or a provincial constitution; or
exercising a public power or performing a public function in terms of any legislation.

1.14 Requester

In relation to a private body, means any person, including, but not limited to public body or an official thereof, making a request for access to a record of the FSP or a person acting on behalf of such person.

1.15 Request for access

A request for access to a record of the FSP in terms of section 50 of PAIA.

1.16 Record

Any recorded information regardless of the form or medium, in the possession or under the control of the FSP irrespective of whether or not it was created by the FSP.

1.17 Third Party

In relation to a request for access to a record held by the FSP, means any person other than the requester.

2. MANUAL PURPOSE

The Promotion of Access to Information Act, 2000, gives effect to section 32 of the Constitution, which provides that everyone has the right to access information held by the State or any other person (or private body), when that information is required for the exercise or protection of any rights.

The purpose of PAIA is to:

foster a culture of transparency and accountability in public and private bodies by giving effect to the right of access to information, and to; and
actively promote a society in which the people of South Africa have effective access to information to enable them to exercise and protect all of their rights more fully.

The FSP recognises everyone’s right to access to information and is committed to provide access to the FSP’s records where the proper procedural requirements as set out by PAIA and POPIA have been met.

The FSP’s PAIA manual is compiled in accordance with section 51 of the Act and contains the following provisions:

Annexure A: Contact Details & Business Type

This section provides the FSP’s postal and street address, phone and fax number, and, the e-mail address of the Head of the FSP.

Annexure B: Section 10 PAIA Guide

This section provides a description of the guide referred to in Section 10 of PAIA and how you may obtain access to it.

Annexure C: Statutory Records

This section provides a description of the various statutes in terms of which the FSP is required to maintain records.

Annexure D: Availability of Records

This section provides a list of records held by the FSP along with an indication of whether the record is freely available or only accessible by way of a formal request in terms of the provisions of PAIA. The section also provides a description of the category of data subject(s) to who the respective records relates along with an indication of the purpose for which the record is being kept. Records that are indicated as “Freely Available” can be accessed by contacting the Deputy Information Officer (see Annexure A), without having to follow any formal procedures. Records that are indicated as a “PAIA Request”, requires the requester to lodge a formal request as provided for in Annexure E.

Annexure E: Request Procedure

This section sets out the procedure required to be followed by a Requestor to obtain access to a record indicated as a “PAIA Request” in Annexure D.

Annexure F: Prescribed Fees

This section sets out the fees that are payable to the FSP by the Requestor prior to the FSP processing a request to obtain access to a record held by the FSP.

Annexure G: Processing of Personal Information

This section sets out the applicable aspects for the processing of personal information.

Annexure H: Outcome of Request and Of Fees Payable

This section sets out the outcome of request to the Requestor and of the fees payable by the Requestor.

Annexure I: Deputy Information Officer Appointment

This section provides for the formal appointment of a Deputy Information Officer where so required.

3. DUTIES OF THE INFORMATION OFFICER

The Information Officer of the FSP are responsible for:

Publishing and proper communication of the manual i.e. creating manual awareness;
The facilitation of any request for access;
Providing adequate notice and feedback to the requester;
Determining whether to grant a request for access to a complete/full record or only part of a record;
Ensuring that access to a record, where so granted, is provided timeously and in the correct format; and
Reviewing the manual for accuracy and communicating any amendments.

3.1 Right of Access

The Information Officer may only provide access to any record held by the FSP to a requester if:

The record is required for the exercise or protection of any right;
The requester complies with the procedural requirements relating to a request for access to that record; and
Access to that record is not refused in terms of any of the grounds for refusal listed below. The Requestor must complete and submit Annexure E to the FSP.

3.2 Grounds for Refusal

The Information Officer must assess whether there are any grounds for refusing a request for access. Where any grounds for refusal are found, a request for access will not be granted and the Information Officer must complete Annexure H and make the completed Annexure available to the Requestor.

However, despite finding any grounds for refusal, access to the record(s) will be provided where:

the disclosure of the record would reveal evidence of a substantial contravention of, or failure to comply with the law or imminent and serious public or environmental risk; and
the public interest in disclosing record, will clearly outweigh the harm contemplated in the provision in question,

Where there are no grounds for refusal, request for access will be granted.

If a request for access is made with regards to a record containing information that would justify a ground for refusal, every part of the record which

does not contain such information; and
can reasonably be severed from any part that does,

must, despite any other provision of PAIA, also be disclosed.

The grounds for refusal, or absence thereof, are set out below:

A: Mandatory Protection of privacy of a Third Party who is a Natural Person

Grounds for Refusal:

The disclosure would involve the unreasonable disclosure of personal information about a third party that is a natural person (including a deceased individual).

No Grounds for Refusal:

The record consists of information that concerns an individual who has already consented in writing to its disclosure to the requester concerned.
The record consists of information that is already publicly available.
The record consists of information that was given to the FSP by the individual to whom it relates and the individual was informed by or on behalf of the FSP, before it is given, that the information belongs to a class of information that would or might be made available to the public.
The record consists of information about an individual’s physical or mental health, or well-being, who is under the care of the requester and who is under the age of 18; or incapable of understanding the nature of the request, and if giving access would be in the individual’s best interest.
The record consists of information about an individual who is deceased and the requester is the individual’s next of kin or making the with the written consent of the individual’s next of kin.
The record consists of information about an individual who is or was an official of the FSP and which relates to the position or functions of the individual, including, but not limited to the title, work address, work phone number, the classification, salary scale or remuneration and responsibilities of the position heled or services performed by the individual and the name of the individual on a record prepare by the individual in the course of employment.

B: Mandatory Protection of Commercial Information of a Third Party

Grounds for Refusal:

The record consists of information that contains trade secrets of a third party.
The record consists of information that contains financial, commercial, scientific or technical information, other than trade secrets, of a third party, the disclosure of which would be likely to cause harm to the commercial or financial interests of that third party.
The record consists of information supplied in confidence by a third party, the disclosure of which could reasonably be expected to put that third party at a disadvantage in contractual or other negotiations or to prejudice that third party in commercial competition.

No Grounds for Refusal:

The record consists of information about a third party who has consented who has already consented in writing to its disclosure to the requester concerned.
The record consists of information about the results of any product or environmental testing or other investigation supplied by a third party or the results of any such testing or investigation carried out by or on behalf of a third party and its disclosure would reveal a serious public safety or environmental risk (the results of any product or environmental testing or other investigation do not include the results of preliminary testing or other investigation conducted for the purpose of developing methods of testing or other investigation).

C: Mandatory Protection of certain Confidential Information of a Third Party

No Grounds for Refusal:

The record consists of information the disclosure of which would constitute an action for breach of a duty of confidence owed to a third party in terms of an agreement.

D: Mandatory Protection of Safety of Individuals and Protection of Property

Grounds for Refusal:

The record consists of information that if disclosed could reasonably be expected to endanger the life or physical safety of an individual.
The record consists of information that if disclosed would likely prejudice or impair the security of a building, a structure or system, a computer or communication system, a means of transport, any other property.
The record consists of information that if disclosed would likely prejudice or impair the security of methods, systems, plans or procedures for the protection of an individual in accordance with a witness protection scheme, the safety of the public, or any part of the public, or the security of property.

E: Mandatory Protection of Records privileged from Production in Legal Proceedings

Grounds for Refusal:

The record consists of information privileged from production in legal proceedings unless the person entitled to the privilege has waived the privilege.

F: Commercial Information of the FSP

Grounds for Refusal:

The record consists of information that contains trade secrets of the FSP.
The record consists of information that contains financial, commercial, scientific or technical information, other than trade secrets, of the FSP, the disclosure of which would likely cause harm to the commercial or financial interests of the FSP.
The record consists of information, the disclosure of which, could reasonably be expected to put the FSP at a disadvantage in contractual or other negotiations or prejudice the FSP in commercial competition.
The record is a computer program as defined in section 1(1) of the Copyright Act (Act 98 of 1978), owned by the FSP, except insofar as it is required to give access to a record to which access is granted in terms of PAIA.

No Grounds for Refusal

The record consists of information about the results of any product or environmental testing or other investigation supplied by the FSP or the results of any such testing or investigation carried out by or on behalf of the FSP and its disclosure would reveal a serious public safety or environmental risk (the results of any product or environmental testing or other investigation do not include the results of preliminary testing or other investigation conducted for the purpose of developing methods of testing or other investigation).

G: Mandatory Protection of Research Information of a Third Party and the FSP

Grounds for Refusal

The record consists of information that contains information about research being or to be carried out by or on behalf of a third party, the disclosure of which would be likely to expose the third party, a person that is or will be carrying out the research on behalf of the third party, or the subject matter of the research to serious disadvantage.
The record consists of information that contains information about research being or to be carried out by or on behalf of the FSP, the disclosure of which would be likely to expose the FSP, a person that is or will be carrying out the research on behalf of the FSP, or the subject matter of the research to serious disadvantage.

4. NOTICE

4.1 Fee payable

Where a request for access has been received the Information Officer and/or Deputy Information Officer will notify the requester of receipt and the prescribed fee (if any) that is payable prior to processing the request. Refer to Annexure F for a full breakdown of fees payable. Personal Requesters will not be charged a request fee.

The notice must state:

The amount of the deposit payable (if any);
That the requester may lodge a complaint with the Information Regulator or an application with a court against the tender or payment of the request fee, or the tender or payment of a deposit, as the case may be; and
The procedure (including the period) for lodging the complaint with the Information Regulator or the application,

except to the extent that the provisions regarding third party notification may apply, the Information Officer and/or Deputy Information Officer to whom the request is made, must as soon as reasonably possible, but in any event within 30 days, after the request has been received in the prescribed format:

Decide in accordance with PAIA whether to grant the request; and
Notify the requester of the decision and, if the requester stated that he or she wishes to be informed of the decision in any other manner, inform him or her in that manner, if it is reasonably possible.

4.3 Granted request for access

If the request for access is granted, the notice must state:

The access fee (if any) to be paid upon access;
The form in which access will be given; and
That the requester may lodge a complaint with the Information Regulator or an application with a court against the access fee to be paid or the form of access granted, and the procedure, including the period allowed, for lodging a complaint with the Information Regulator or the application.

4.3 Refused request for access

If the request for access is refused, the notice must:

State adequate reasons for the refusal, including the relevant provision of PAIA that was relied on;
Exclude, from any such reasons, any reference to the content of the records’; and
State that the requester may lodge a complaint with the Information Regulator or an application with a court against the refusal of the request, and the procedure (including the period) for lodging a complaint with the Information Regulator or the application.

4.4 Undiscoverable record

Should all reasonable steps have been taken to find a record requested, and there are reasonable grounds for believing that the record:

Is in the FSP’s possession, but cannot be found; or
Simply does not exist,

the head of the FSP must, by way of affidavit or affirmation, notify the requester that it is not possible to provide access to that record. The affidavit or affirmation must provide full account of all steps taken to find the record in question or to determine whether the record exists, as the case may be, including all communication with every person who conducted the search on behalf of the head.

5. AVAILABILITY OF THE MANUAL

A copy of the Manual is available-

on our website: www.jwr.co.za;
at the office of JWR for public inspection during normal business hours;
to any person upon request and upon the payment of a reasonable prescribed fee; and
to the Information Regulator upon request.

A fee for a copy of the Manual, as contemplated in Annexure F, shall be payable per each A4-size photocopy made.

ANNEXURE A: CONTACT DETAILS & BUSINESS TYPE

Postal address:

P.O. Box 4590, Tyger Valley, 7536

Street address:

The IQ Business Building, Farm 3, The Vineyards Office Estate, 99 Jip De Jager Drive, Bellville, 7530

Phone number:

021 914 0818

Email address:

info@jwr.co.za

Fax number:

086 416 9210

FSP Contact Details

1. Head of FSP

Full names & surname:

John William Roelofse

Email address:

johnnieR@jwr.co.za

Phone number:

021 914 0818

Fax number:

086 416 9210

2. Business Type

The FSP conducts its main type of business in the following sector(s):

Agriculture

Mining and Quarrying

Manufacturing

Electricity, Gas & Water

Construction

Retail & Motor Trade and Repair Services

Wholesale Trade, Commercial Agents & Allied Services

Catering, Accommodation & Other Trade

Finance & Business Services

Community, Special & Personal Services

If other, please specify:

ANNEXURE B: SECTION 10 PAIA GUIDE

The Regulator has, in terms of section 10(1) of PAIA, as amended, updated and made available the revised Guide on how to use PAIA (the “Guide”), in an easily comprehensible form and manner, as may reasonably be required by a person who wishes to exercise any right contemplated in PAIA and POPIA.

The Guide is available in each of the official languages and in braille.

The aforesaid Guide contains the description of:

the objects of PAIA and POPIA;
the postal and street address, phone and fax number and, if available, electronic mail address of-
- the Information Officer of every public body, and
- every Deputy Information Officer of every public and private body designated in terms of section 17(1) of PAIA and section 56 of POPIA;
the manner and form of a request for:
- access to a record of a public body contemplated in section 11; and
- access to a record of a private body contemplated in section 50;
the assistance available from the IO of a public body in terms of PAIA and POPIA;
the assistance available from the Regulator in terms of PAIA and POPIA;
all remedies in law available regarding an act or failure to act in respect of a right or duty conferred or imposed by PAIA and POPIA, including the manner of lodging-
- an internal appeal;
- a complaint to the Regulator; and
- an application with a court against a decision by the information officer of a public body, a decision on internal appeal or a decision by the Regulator or a decision of the head of a private body;
the provisions of sections 14 and 51 requiring a public body and private body, respectively, to compile a manual, and how to obtain access to a manual;
the provisions of sections 15 and 52 providing for the voluntary disclosure of categories of records by a public body and private body, respectively;
the notices issued in terms of sections 22 and 54 regarding fees to be paid in relation to requests for access; and
the regulations made in terms of section 92.

Members of the public can inspect or make copies of the Guide from the offices of the public and private bodies, including the office of the Regulator, during normal working hours.

The Guide can also be obtained-

upon request to the Information Officer; or
from the website of the Regulator (https://www.justice.gov.za/inforeg/).

PAIA grants a requester access to records of a private body, if the record is required for the exercise or protection of any rights. Where a public body lodges a request, the public body must be acting in the public interest.

Requests in terms of PAIA shall be made in accordance with the prescribed procedures at the rates provided.

ANNEXURE C: STATUTORY RECORDS

The FSP maintains statutory records and information in terms of the following legislation:

Administration of Estates Act
Arbitration Act
Auditing Professions Act
Basic Conditions of Employment Act
Closed Corporations Act
Collective Investment Schemes Control Act
Companies Act
Compensation of Occupational Injuries & Diseases Act
Consumer Protection Act
Copyright Act
Customs and Excise Act
Electronic Communications and Transactions Act
Employment Equity Act
Financial Advisory & Intermediary Services Act
Financial Institutions (Protection of Funds) Act
Financial Intelligence Centre Act
Friendly Societies Act
Income Tax Act
Insolvency Act
Labour Relations Act
Long-term Insurance Act
Medical Schemes Act
National Credit Act
Occupational Health and Safety Act
Patents Act
Pension Funds Act
Prevention of Organised Crime Act
Prevention and Combatting of Corrupt Activities Act
Promotion of Equality and Prevention of Unfair Discrimination Act
Protection of Constitutional Democracy against Terrorist and related Activities Act
Short-term Insurance Act
Skills Development Act
Trademarks Act
Unemployment Insurance Act
Value Added Tax Act

ANNEXURE D: AVAILABILITY OF RECORDS

The FSP maintains the following categories of records and related subject matter. The status of the record’s availability, the purpose for its processing and the relevant data subject category to who the record relates are set out below:

Record:

Availability:

Purpose:

Data Subject:

Public 
Affairs

Public Product Information

Freely Available

Convey Public Information

FSP

Public Corporate Records

Freely Available

Convey Public Information

FSP

Media Releases

Freely Available

Convey Public Information

FSP

Published Newsletters

Freely Available

Convey Public Information

FSP

Magazine Articles

Freely Available

Convey Public Information

FSP

Regulatory &
Administrative

Permits, Licenses or Authorities

Freely Available

Statutory Requirement

FSP

Conflict of Interest Management Policy

Freely Available

Statutory Requirement

FSP

Complaints Policy

Freely Available

Statutory Requirement

FSP

FICA Internal Rules

PAIA Request

Statutory Requirement

FSP

Health & Safety Plan

PAIA Request

Statutory Requirement

FSP

Memorandum of Incorporation

PAIA Request

Statutory Requirement

FSP

Minutes of Board or Directors Meetings

PAIA Request

Statutory Requirement

FSP

PAIA Request

Statutory Requirement

FSP

PAIA Request

Statutory Requirement

FSP

Internal correspondence (e-mails/memos)

PAIA Request

Internal Communications

Employees

Insurance Policies held by FSP

PAIA Request

Risk Management

FSP

Human
Resources

Employment Applications

PAIA Request

Internal Referencing

Employees

Employment Contracts

PAIA Request

Contractual Agreement

Employees

Personal Information of Employees

PAIA Request

Internal Referencing

Employees

Employment Equity Plan

PAIA Request

Statutory Requirement

FSP

Medical Aid Records

PAIA Request

Internal Referencing

Employees

Pension Fund Records

PAIA Request

Internal Referencing

Employees

Disciplinary Records

PAIA Request

Statutory Requirement

Employees

Performance Management Records

PAIA Request

Internal Referencing

Employees

Salary Records

PAIA Request

Internal Referencing

Employees

Employee Benefit Records

PAIA Request

Internal Referencing

Employees

PAYE Records

PAIA Request

Statutory Requirement

Employees

Seta Records

PAIA Request

Statutory Requirement

Employees

Disciplinary Code

PAIA Request

Statutory Requirement

FSP

Leave Records

PAIA Request

Internal Referencing

Employees

Training Records

PAIA Request

Internal Referencing

Employees

Training Manual

PAIA Request

Internal Referencing

FSP

Financial

Financial Statements

PAIA Request

Internal Referencing

FSP

Financial and Tax Records

PAIA Request

Statutory Requirement

FSP

Asset Register

PAIA Request

Internal Referencing

FSP

Management Accounts and Reports

PAIA Request

Internal Referencing

FSP

Vouchers, Cash Books and Ledgers

PAIA Request

Internal Referencing

FSP

Banking Records and Statements

PAIA Request

Internal Referencing

FSP

Electronic Banking Records

PAIA Request

Internal Referencing

FSP

Marketing

Market Information

PAIA Request

Internal Referencing

FSP

Product Brochures

PAIA Request

Internal Referencing

FSP

ANNEXURE E: REQUEST FOR ACCESS TO RECORD

ANNEXURE F: PRESCRIBED FEES

The following applies to requests (other than personal requests):

A requester is required to pay a preliminary request fee before a request will be processed.
If the preparation of the record requested requires more than the prescribed hours (six), an additional deposit shall be paid (of not more than one third of the access fee which would be payable if the request was granted).
A requestor may lodge an application with a court against the render / payment of the request fee and/or deposit.
Records may be withheld until the fees have been paid.

No.

Description

Fee

The request fee payable by every requester

R140.00

Photocopy/printed black & white copy of A4-size page

R2.00

Printed copy of an A4 size page

R2.00

For a copy in a computer-readable form on:

Flash drive (to be provided by requester)
Compact disc:
- - If provided by requestor
  - If provided to the requestor

R40.00

R40.00
R60.00

5.

6.

For a transcription of visual images per A4-size page

Copy of visual images

Service to be outsourced will depend on quotation from Service provider.

Transcription of an audio record, per A4-size page

R24.00

Copy of an audio record on:

Flash drive (to be provided by requester)
Compact disc:
- - If provided by requestor
  - If provided to the requestor

R40.00

R40.00
R60.00

To search for and prepare the record for disclosure for each hour or part of an hour, excluding the first hour, reasonably required for such search and preparation.

To not exceed a total cost of

R145.00

R435.00

10.

Deposit: If search exceeds 6 hours

One third of amount per request ito items 2-8.

11.

Postage, e-mail or any other electronic transfer

Actual expense, if any.

ANNEXURE G: PROCESSING OF PERSIONAL INFORMATION

1. Purpose of Processing Personal Information

We collect, hold, use and disclose personal information mainly to provide clients with access to the services and products that we provide. We will only process clients’ information for a purpose they would reasonably expect, including:

Complying with the obligations contained in the contract concluded between the client and the FSP
Providing the client with advice, products and services that suit their needs as requested
To verify the client’s identity and to conduct credit reference searches
To issue, administer and manage the client’s insurance policies
To process insurance claims and to take recovery action
To notify the client of new products or developments that may be of interest to them
To confirm, verify and update our clients’ details
To comply with any legal and regulatory requirements

2. Description of the Categories of Data Subjects and of The Information or Categories of Information Relating Thereto.

Categories of Data Subjects

Personal Information that may be processed

Clients

First and last name, email address, a home, postal or other physical address, other contact information, title, birth date, gender, occupation, qualifications, past employment, residency status, investments, assets, liabilities, insurance, income, expenditure, family history, medical information and your banking details.

Service Providers

Names, registration number, vat numbers, address, trade secrets and bank details.

Employees

First and last name, email address, a home, postal or other physical address, other contact information, qualifications, gender and race, past employment, banking details.

3. The Recipients or Categories of Recipients to Whom the Personal Information May Be Supplied

In accordance with the Protection of Personal Information Act (POPIA), JWR Financial Services may supply personal information to the following recipients or categories of recipients, where necessary for the purposes for which the information was collected, and in line with regulatory obligations and client instructions:

Category of personal information

Recipients or Categories of Recipients to whom the personal information may be supplied.

Identification & Verification

Identity number and names, for criminal checks

South African Police Services

Personal and contact details, FICA documentation, bank details

Life Insurers and Investment Platforms

External Compliance Officers, Auditors (for regulatory compliance)

Financial Intelligence Centre (FIC), if required by law

Life Insurers and Investment Platforms

Internal Risk and Compliance

Financial Needs Analysis tools, CRM systems

Financial Information

Category of personal information

Recipients or Categories of Recipients to whom the personal information may be supplied.

Income, expenses, assets and liabilities, Investment, retirement, and risk product details

Financial Needs Analysis tools, CRM systems

Income, expenses, assets and liabilities,

Product Providers (for underwriting)

Internal Staff Information

Regulatory exam results, qualifications, and CPD records

Financial Sector Conduct Authority (FSCA), Internal HR, Compliance Officers

First and last name, email address, a home, postal or other physical address, other contact information, qualifications, gender and race, past employment, banking details.

Internal Management

4. Planned Transborder Flows of Personal Information

JWR makes use of reputable cloud-based platforms and software service providers for the secure storage, backup, and processing of client information. In certain cases, these services may involve the transborder flow of personal information to data centres located outside of the Republic of South Africa.

Category of Personal Information

Destination Country

Purpose

Service Provider(s)

Client contact information, documents, and correspondence

Ireland / European Union / United States

Cloud-based email, file storage, CRM and backup systems

Microsoft 365, Google Workspace, Dropbox, OneDrive, Elite Wealth

5. General Description of Information Security Measures Implemented by the Responsible Party

JWR implements a range of physical, technical, and administrative safeguards to ensure the confidentiality, integrity, and availability of personal information under its care. These measures include, but are not limited to:

Password-protected systems;
Regular software updates and patch management to protect against vulnerabilities;
Comprehensive Anti-virus and Anti-malware solutions to detect and prevent malicious threats;
Cloud-based data storage with secure backup protocols to prevent data loss and support disaster recovery;
Firewall protection and network monitoring to secure our systems against external attacks;
Internal information security policies and employee training to promote data protection awareness and compliance with relevant legislation, including POPIA.

These measures are reviewed periodically to adapt to emerging threats and maintain the highest standards of data protection.

PAIA MANUAL

1. DEFINITIONS

2. MANUAL PURPOSE

3. DUTIES OF THE INFORMATION OFFICER

4. NOTICE

5. AVAILABILITY OF THE MANUAL

ANNEXURE A: CONTACT DETAILS & BUSINESS TYPE

ANNEXURE B: SECTION 10 PAIA GUIDE

ANNEXURE C: STATUTORY RECORDS

ANNEXURE D: AVAILABILITY OF RECORDS

Category:

Record:

Availability:

Purpose:

Data Subject:

ANNEXURE E: REQUEST FOR ACCESS TO RECORD

ANNEXURE F: PRESCRIBED FEES

No.

Description

Fee

ANNEXURE G: PROCESSING OF PERSIONAL INFORMATION

Categories of Data Subjects

Personal Information that may be processed

ANNEXURE H: OUTCOME OF REQUEST AND OF FEES PAYABLE

Regulatory