INFORMATION MANUAL FOR HALFWAY GROUP HOLDINGS (PTY) LTDIN TERMS OF THE PROMOTION OF ACCESS TO INFORMATION ACT (PAIA)
INFORMATION MANUAL FOR HALFWAY GROUP HOLDINGS (PTY) LTDin terms ofTHE PROMOTION OF ACCESS TO INFORMATION ACT
1. LIST OF ACRONYMS AND ABBREVIATIONS
“CEO” Chief Executive Officer;
“DIO” Deputy Information Officer;
“Halfway” Shall mean Halfway Group Holdings (Pty) Ltd (registration number: 2015/274007/07), a private body incorporated in South Africa with subsidiaries and associates as set out in Annexure C;
“IO” Information Officer;
“Minister” Minister of Justice and Correctional Services;
“PAIA” Promotion of Access to Information Act No. 2 of 2000 (as Amended);
“POPIA” Protection of Personal Information Act No.4 of 2013;
“Regulator” Information Regulator; and
“Republic” Republic of South Africa.
2. PURPOSE OF PAIA MANUAL
The purpose of this PAIA Manual is to assist you with the following:
Provide you with the categories of records held by the various operating entities within the Halfway Group which are available without you having to submit a formal PAIA request;
Enable you to have a sufficient understanding of how to make a request for access to a record of any operating entity within the Halfway Group, by providing a description of the subjects on which an entity within the Halfway Group holds records and the categories of records held on each subject;
Provide you with a description of the records held by the various entities within the Halfway Group which are available in accordance with legislation;
Provide you with a description of the guide on how to use PAIA, as updated by the Regulator and how to obtain access to it;
To assist you to understand, that where the entities within the Halfway Group processes personal information, the purpose of processing of personal information and the description of the categories of data subjects and of the information or categories of information relating thereto.
Provide you with a description of the categories of data subjects and the information or categories of information relating thereto;
Provide you with the recipients or categories of recipients to whom the personal information may be supplied;
To make you aware of instances where an entity within the Halfway Group has planned to transfer or process personal information outside the Republic of South Africa and the recipients or categories of recipients to whom the personal information may be supplied; and
To make you aware of appropriate security measures the entities within the Halfway Group has in place to ensure the confidentiality, integrity and availability of the personal information which is to be processed.
This Policy must be read with the Halfway Group Privacy Policy and in particular the details of the Information Officers and Deputy Information Officers will apply to this Policy.
3. SCOPE
The Scope of this policy include entities within the Halfway Group as provided for in Annexure C. Please refer to the Halfway Group Privacy Policy for specific contact details for each operating entity and their respective Information and Deputy Information Officers.
The following entities are expressly excluded from the ambit of this policy:
Entities in which the Halfway Group holds a minority interest; and
Entities which are dormant.
4. KEY CONTACT DETAILS FOR ACCESS TO INFORMATION ABOUT THE HALFWAY GROUP
The Chief Executive Officer for Halfway Group Holdings (Pty) Ltd is Mr. J G Baikie.
5. GUIDE ON HOW TO USE PAIA AND HOW TO OBTAIN ACCESS TO THE GUIDE
The Regulator has, in terms of section 10(1) of PAIA, as amended, updated and made available the revised Guideon how to use PAIA (“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 PAIAand 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 14and 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 15and 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 22and 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 business hours.
The Guide can also be obtained-
upon request to the Information Officer of any of the entities within the Halfway Group;
A copy of this Guide is also available in the following two official languages namely English and IsiZulu, for public inspection during office hours.
6. AVAILABILITY OF RECORDS
Entities within the Halfway Group maintain 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:
Category:
Record:
Availability:
Purpose:
Data Subject:
PublicAffairs
Public Product Information
Freely Available
Convey Public Information
Organisation
Public Corporate Records
Freely Available
Convey Public Information
Organisation
Media Releases
Freely Available
Convey Public Information
Organisation
Published Newsletters
Freely Available
Convey Public Information
Organisation
Magazine Articles
Freely Available
Convey Public Information
Organisation
Regulatory & Administrative
FSP license
Freely Available
Statutory Requirement
Organisation
Promotion of Access to Information Manual
Freely Available
Statutory Requirement
Organisation
Website & Email Disclaimers
Freely Available
Statutory Requirement
Organisation
Privacy Policy
Freely Available
Statutory Requirement
Organisation
Conflict of Interest Management Policy
Freely Available
Statutory Requirement
Zanro Brokers (Pty) Ltd / Aston Financial Services (Pty) Ltd
Complaint’s resolution Policy
Freely Available
Statutory Requirement
Zanro Brokers (Pty) Ltd / Aston Financial Services (Pty) Ltd
Suspicious and unusual transactions Policy
PAIA Request
Statutory Requirement
Zanro Brokers (Pty) Ltd / Aston Financial Services (Pty) Ltd
Health & Safety Plan
PAIA Request
Statutory Requirement
Organisation
Memorandum of Incorporation
PAIA Request
Statutory Requirement
Organisation
Register of Board of Directors
PAIA Request
Statutory Requirement
Organisation
Internal correspondence (e-mails/memos)
PAIA Request
Internal Communications
Employees
Insurance Policies held by organization
PAIA Request
Risk Management
Organisation
HumanResources
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
Organisation
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
Organisation
Leave Records
PAIA Request
Internal Referencing
Employees
Training Records
PAIA Request
Internal Referencing
Employees
Training Manual
PAIA Request
Internal Referencing
Organisation
Financial
Financial Statements
PAIA Request
Statutory Requirement
Organisation
Financial and Tax Records
PAIA Request
Statutory Requirement
Organisation
Asset Register
PAIA Request
Internal Referencing
Organisation
Management Accounts and Reports
PAIA Request
Internal Referencing
Organisation
Vouchers, Cash Books and Ledgers
PAIA Request
Internal Referencing
Organisation
Banking Records and Statements
PAIA Request
Internal Referencing
Organisation
Electronic Banking Records
PAIA Request
Internal Referencing
Organisation
Marketing
Market Information
PAIA Request
Internal Referencing
Organisation
Product Brochures
PAIA Request
Internal Referencing
Organisation
Advertisement policy
PAIA Request
Internal Referencing
Organisation
Performance Records
PAIA Request
Internal Referencing
Organisation
Product / Service Sales Records
PAIA Request
Internal Referencing
Organisation
Marketing Strategies
PAIA Request
Internal Referencing
Organisation
Client /Customer
Customer / Client Database
PAIA Request
Internal Referencing
Customers
Customer / Client agreements
PAIA Request
Internal Referencing
Customers
Customer / Client Files
PAIA Request
Internal Referencing
Customers
Customer / Client Instructions
PAIA Request
Internal Communications
Customers
Customer / Client Correspondence
PAIA Request
External Communications
Customers
Third Party
Intermediary agreements
PAIA Request
Contractual Agreement
Zanro Brokers (Pty) Ltd / Aston Financial Services (Pty) Ltd
Binder agreements
PAIA Request
Risk Management
Zanro Brokers (Pty) Ltd / Aston Financial Services (Pty) Ltd
Referral agreements
PAIA Request
Contractual Agreement
Zanro Brokers (Pty) Ltd / Aston Financial Services (Pty) Ltd
Outsource agreements
PAIA Request
Contractual Agreement
Third Party
Non-disclosure agreements
PAIA Request
Contractual agreement
Third party
Lease agreements
PAIA Request
Contractual agreement
Third party
Service Provider agreements
PAIA Request
Contractual agreement
Third party
7. STATUTORY RECORDS
Administrative Adjudication of Road Traffic Offences
Basic Conditions of Employment Act
Broad Based Black Economic Empowerment Act
Companies Act
Competition Act
Compensation for Occupational Injuries and Diseases Act
Constitution of the Republic of South Africa
Copyright Act
Disaster Management Act
Electronic Communications Act
Electronic Communications and Transactions Act
Employment Equity Act
Financial Advisory and Intermediary Services Act
Financial Sector Regulation Act
Health and Safety Regulations
Income Tax Act
Insurance Act
Labour Relations Act
National Minimum Wage Act
National Payment System Act
National Qualifications Framework Act
Occupational Health and Safety Act
Policyholder Protections Rules 2017 Short Term Insurance
Prescription Amendment Act
Promotion of Equality and Prevention of Unfair Discrimination Act
Promotion of Access to Information Amendment Act
Protected Disclosures Act
Protection of Personal Information Act
Rental Housing Act
Skills Development Act
Skills Development Levies Act
Short Term Insurance Act
Tax Administration Act
Unemployment Insurance Act
Unemployment Insurance Contributions Act
Value-Added Tax Act
DESCRIPTION OF THE CATEGORIES OF DATA SUBJECTS AND THE INFORMATION OR CATEGORIES OF INFORMATION RELATING THERETO
Below is a description of all data subjects and the description of the nature or category of personal information to be processed.
Category of Data Subjects
Types of Information processed
Individuals (customer, policyholders etc.)
Name, surname, South African identity number or other identifying number (e.g., passport), date of birth, age, marital status, citizenship, telephone numbers, email address, physical and postal addresses, drivers’ licence, income tax number, employment information, occupation, financial information (e.g., remuneration), banking information including account numbers, claims and payment history, FICA documentation.
Entities (Corporate Customers, Companies, Close Corporations, Trusts and Partnerships)
Entity name, registration number, tax-related information, contact details for representatives, FICA documentation, beneficial owners’ personal information (as for Individuals).
Directors, Members, Partners & Trustees
Identity numbers, names, physical and postal address, contact numbers, email address & FICA documentation.
Employees (potential employees, new recruitments, independent contractors)
Name, surname, South African identity number or other identifying number (e.g., passport number), contact details, physical and postal address, date of birth, age, marital status, race, disability, information, employment history, criminal background checks, fingerprints, CVs, education history, banking details, income tax reference number, remuneration and benefit information, drivers’ licence, health information, details related to employee performance, disciplinary procedure information. May also include the personal information of children / minors, if they are listed as beneficiaries or dependants.
Service providers (including outsourced or hosted services, auditors, etc.)
Company registration details, identity numbers, BEE certificates, tax clearance, income tax and VAT registration details, payment information including bank account numbers, invoices, contractual agreements, addresses, contact details.
9. THE CATEGORIES OF RECIPIENTS TO WHOM THE PERSONAL INFORMATION MAY BE SUPPLIED
Below is a description of recipients to whom your personal information may be shared:
Service providers who are involved in the delivery of products or services to you. We have agreements in place to ensure that they comply with the privacy requirements as required by the Protection of Personal Information Act.
Entities within the Group. We only do this, in instances where we have received your express consent to do so.
Insurers, intermediaries, administrators, and Underwriting Managers.
Provident Funds and their Trustees and Principal Officers.
Medical aid companies.
Recruitment organisations that may collect information on our behalf.
Regulators and Law Enforcement Agencies.
Motor Licencing Bureau.
Original Equipment Manufacturers (OEMs).
Banks and other financing Institutions.
The South African Revenue Service (SARS).
Auditors and External Compliance Practices
10. PLANNED TRANSBORDER FLOWS OF PERSONAL INFORMATION
Entities within the Halfway Group make use of hosted services provided by third parties. These operations may be hosted in various countries resulting in the transfer of personal information.
In general, entities within the Halfway Group try as far as possible to ensure that these service providers are located in jurisdictions with strong data protection legislation, such as the European Union or the United Kingdom. Where this is not possible, data protection requirements are enforced by means of contractual agreement.
GENERAL DESCRIPTION OF INFORMATION SECURITY MEASURES TO BE IMPLEMENTED BY THE RESPONSIBLE PARTY TO ENSURE THE CONFIDENTIALITY, INTEGRITY AND AVAILABILITY OF THE INFORMATION.
Entities within the Halfway Group take every reasonable precaution to protect your personal information (including information about your activities) from theft, unauthorized access, and disruption of services.
Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, and availability. We regularly test our website, data centers, systems, and other assets for security vulnerabilities.
Our security policies and procedures cover:
Physical and environmental security controls.
Network security.
Protection from viruses and other malware.
Restricted access and password control to personal information.
Secure communications (email encryption).
Secure remote working (VPN access only to the networks).
Acceptable usage of IT equipment and mobile devices (Exit and entry procedures for staff).
Clean Desk Policy.
Lockable cabinets for physical storage of records with restricted access.
IT disaster recovery and backup procedures.
Training and awareness initiatives.
Retention and disposal of information (Shred it).
Cyber Security Incident Response.
Active monitoring and review of the IT and business environment.
When we contract with third parties, we impose appropriate security, privacy, and confidentiality obligations on them to ensure that personal information that we remain responsible for, is kept secure. We will ensure that anyone to whom we pass your personal information agrees to treat your information with the same level of protection as we are obliged to.
12 REQUEST FOR INFORMATION PROCEDURE
To facilitate the processing of your information request, kindly complete the form marked Annexure A. The form must be submitted to the Information Officer or Deputy Information Officer whose details appear in the Halfway Group Privacy Policy.
The Information Officer or Deputy Information Officer will notify you that a request for access has been received and that the prescribed fee (if any) is payable prior to processing the request. Please refer to Annexure B for a full breakdown of fees payable.
Please be advised that PAIA provides a number of grounds on which a request for access to information may be refused. These grounds mainly comprise instances where:
the privacy and interests of other individuals are protected.
where such records are already otherwise publicly available.
instances where public interest are not served.
the mandatory protection of commercial information of a third party.
the mandatory protection of certain confidential information of a third party.
When completing the form below please:
indicate the identity of the person seeking access to the information.
provide sufficient particulars to enable the Information or Deputy Information Officer to identify the information requested.
specify the format in which the information is required.
indicate the contact details of the person requiring the information.
indicate the right to be exercised and/or to be protected, and specify the reasons why the information required will enable the person to protect and/or exercise the right.
where the person requesting the information wishes to be informed of the decision of the request in a particular manner, state the manner and particulars to be so informed.
if the request for information is made on behalf of another person, submit proof that the person submitting the request, has obtained the necessary authorisation to do so.
AVAILABILITY OF THE MANUAL
A copy of the Manual is available-
On the various operating entities websites as well as on halfwaygroup.co.za;
at each entity’s physical place of business 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 B, shall be payable per each A4-size photocopy made.
14. POLICY REVIEW
This policy will be reviewed on an ad hoc basis if there are any changes to the business operations or legislation that warrant such change. Alternatively, the policy will be reviewed once annually.
Name of the policy
Version NO
Reason for change
Author
Approver
Approver
Effective date
PAIA MANUAL
CoSEC01V1
Amendment to Policy
Craig Humphreys
George Baikie
1 January 2022
ANNEXURE A: REQUEST FOR INFORMATION PROCEDURE
A. Particulars of Private Body
The Head:
B. Particulars of person requesting access to the record
(i) The particulars of the person who requests access to the record must be recorded below
(ii) Furnish an address and/or fax number in the Republic to which information must be sent
(iii) Proof of the capacity in which the request is made, if applicable, must be attached
Full names & surname:
Identity number:
Postal address:
Fax number:
Telephone number:
Email address:
Capacity:
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
Full names & surname:
Identity number:
D. Particulars of Record
(i) Provide full particulars of the record to which access is requested, including the reference number if that is known to you
(ii) If the provided space is inadequate, please continue on a separate page and attach to this form. Please sign any additional pages
Description of record:
Reference number:
Any further particulars:
E. Fees
(i) 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
(ii) You will be notified of the amount required to be paid as the request fee
(iii) 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
(iv) If you qualify for exemption of the payment of any fee, please state the reason therefor
Reason for exemption:
F. Form of access to record Financial Statements
If you are prevented by a disability to read, view or listen to the record in the form of access provided hereunder, please state your disability and indicate in which form the record is required
Disability:
Form in which required:
Mark the appropriate box with an “X”
(i) Your indication as to the required form of access depends on the form in which the record is available
(ii) Access in the form requested may be refused in certain circumstances, In such a case you will be informed of access will be granted in another form
(iii) The fee payable for access to the record, if any, will be determined partly by the form in which access is requested
1) If the record is in written or printed form:
§ copy of record
§ inspection of record
2) If record consists of visual images:
§ view the images
§ copy of the images
§ transcription of the images
3) If the record consists of recorded words or information which can be reproduced in sound:
§ listen to the soundtrack
§ transcription of the soundtrack
4) If the record is held on computer or in an electronic or machine-readable form:
§ printed copy of record
§ copy in computer readable form
Please indicate the preferred method of delivery
§ By hand
§ Email
§ Post
§ Fax
G. 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 additional folios.
Indicate which right is to be exercised or protected:
Explain why the record requested is required for the exercise or protection of the aforementioned right:
H. Notice of decision regarding the request for access
You will be notified in writing whether your request has been approved / denied. If you wish to be informed thereof 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?
I. Signature page
Signed at:
Date:
Signature of Requester / Person on whose behalf request is made:
ANNEXURE B: PRESCRIBED FEES
No.
Description
Fee
1.
The request fee payable by every requester
R140.00
2.
Photocopy/printed black & white copy of A4-size page
R2.00
3.
Printed copy of an A4 size page
R2.00
4.
For a copy in a computer-readable form on:
i. Flash drive (to be provided by requester)
R40.00
ii. Compact disc:
– If provided by requestor
R40.00
– If provided to the requestor
R60.00
5.
For a transcription of visual images per A4-size page
Service to be outsourced. Will depend on quotation from Service provider.
6.
Copy of visual images
7.
Transcription of an audio record, per A4-size page
R24.00
8.
Copy of an audio record on:
i. Flash drive (to be provided by requester)
R40.00
ii. Compact disc:
– If provided by requestor
R40.00
– If provided to the requestor
R60.00
9.
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 C: OPERATING ENTITIES INCORPORATED INTO THIS MANUAL
Please refer to the Halfway Group Privacy Policy for the names and contact details of the Information and Deputy Information Officers.
LEGAL ENTITY NAME
TRADING AS
REGISTRATION NUMBER
30-34 Rockview (Pty) Ltd
2015/378191/07
4 Wheel Drive Motor Distributors (Pty) Ltd
Halfway Toyota Honeydew / Hino Honeydew
1984/010172/07
4 Wheel Drive Property Holdings (Pty) Ltd
2015/371475/07
Alfred County Auto (Pty) Ltd
Halfway Ford Port Shepstone / Halfway Ford Waterfall / Halfway Ford Goodwood / Halfway Ford Kuils River
Halfway Group Holdings (Pty) Ltd