KLA

Insights Consultancy

PAIA MANUAL

Prepared in terms of Section 51 of the Promotion of Access to Information Act 2 of 2000 (as amended)

PURPOSE OF THIS PAIA MANUAL

This PAIA Manual has been compiled by Kaufman Levin Associates (Pty) Ltd (“KLA”) in accordance with section 51 of the Promotion of Access to Information Act 2 of 2000 (as amended) (“PAIA”), read together with the Protection of Personal Information Act 4 of 2013 (“POPIA”). The Manual is intended to assist members of the public to:

• Understand the categories of records held by KLA that are available without a formal PAIA request;
• Know how to submit a request for access to KLA’s records, including a description of the subjects on which KLA holds records and the categories of records held on each subject;
• Understand which records are automatically available in terms of other applicable legislation;
• Access the contact details of KLA’s Information Officer and Deputy Information Officer;
• Obtain the Regulator’s guide on how to use PAIA and POPIA, and understand how to access it;
• Know whether KLA processes personal information, the purposes of such processing, and the categories of data subjects and information concerned;
• Know the recipients or categories of recipients to whom personal information may be disclosed;
• Know whether KLA transfers personal information outside the Republic of South Africa;
• Understand the security measures KLA implements to protect the confidentiality, integrity, and availability of personal information.

GUIDE ON HOW TO USE PAIA

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

The Guide is available in each of South Africa’s eleven official languages and in Braille.

The Guide contains descriptions of, among others:

• The objects of PAIA and POPIA;
• Postal and street addresses, phone and fax numbers, and email addresses of Information Officers of every public body, and Deputy Information Officers of every public and private body;
• The manner and form of a request for access to records of a public body (section 11) and a private body (section 50);
• Assistance available from the IO of a public body and from the Regulator;
• All remedies in law available for acts or failures to act in respect of rights under PAIA and POPIA, including internal appeals, complaints to the Regulator, and court applications;
• Provisions requiring public and private bodies to compile manuals;
• Provisions for voluntary disclosure of categories of records;
• Notices regarding applicable fees; and
• Regulations made in terms of section 92 of PAIA.

Members of the public may inspect or obtain copies of the Guide at:

• The offices of the Information Regulator during normal working hours;
• KLA’s head office, upon request to the Information Officer;
• The Regulator’s website: https://inforegulator.org.za/paia/

The Guide is also available in the following official languages at KLA’s offices for public inspection during normal working hours:

• English

A requester wishing to obtain access to a record held by KLA must submit a written request using the prescribed Form C (also referred to as Form 2), available from the Information Regulator’s website at https://inforegulator.org.za/paia/. The completed form must be directed to the Information Officer or Deputy Information Officer of KLA at the contact details set out in Section 3 of this Manual. KLA is required to respond to a request within 30 days of receipt, which period may be extended by a further 30 days in the circumstances contemplated in section 57 of PAIA. A request fee may be required before further processing of the request, as contemplated in section 54 of PAIA.

Should a requester be dissatisfied with KLA’s decision regarding a request for access to records (including a refusal or deemed refusal), the following remedies are available:

• Lodge a complaint with the Information Regulator at [email protected] or [email protected]; or
• Apply to a court of competent jurisdiction for appropriate relief in terms of section 78 of PAIA.

PROCESSING OF PERSONAL INFORMATION

 Purpose of Processing Personal Information

KLA processes personal information for the following purposes:

• Recruiting, employing, and managing employees and contractors (including payroll, performance management, HR administration, and skills development);
• Entering into, managing, and fulfilling client agreements and research project deliverables;
• Engaging and managing service providers, suppliers, and freelance contractors;
• Conducting market research, consumer insights studies, and fieldwork on behalf of clients (in which case respondent data is processed under contract in accordance with applicable data processing agreements);
• Complying with statutory and regulatory requirements (tax, employment equity, UIF, skills development, B-BBEE, POPIA, etc.);
• Managing financial transactions, invoicing, and accounting;
• Maintaining IT and systems security and access controls;
• Marketing and business development activities;
• Direct communication with clients, prospects, and partners; and
• Any other purpose incidental to or consistent with the above.

Categories of Data Subjects and Personal Information Processed

Information Security Measures

KLA implements reasonable technical and organisational measures to protect the confidentiality, integrity, and availability of personal information in its possession or under its control. These measures include, but are not limited to:

• Access controls and role-based permissions for all systems (Microsoft SharePoint);
• Password policies and multi-factor authentication where supported;
• Data encryption in transit and at rest (via cloud service provider infrastructure);
• Regular system and software updates, patching, and antivirus / anti-malware controls;
• Secure email practices and employee awareness;
• Confidentiality clauses in employment contracts and supplier/contractor agreements;
• Data processing agreements with third-party service providers;
• Internal policies governing data access, retention, and disposal; and
• Incident response procedures for managing data breaches in accordance with POPIA.

AVAILABILITY OF THIS MANUAL

A copy of this Manual is available:

• https://kla.co.za/ – available for download on KLA’s website;
• At KLA’s head office in Johannesburg for public inspection during normal business hours;
• Upon request to the Information Officer, against payment of a reasonable prescribed fee (per the PAIA Regulations); and
• To the Information Regulator upon request.

 A fee for reproduction or copying of this Manual or any other records, as contemplated in Annexure B of the PAIA Regulations, shall be payable per each A4-size photocopy made. In addition, a request fee of R50.00 is payable before further processing of any formal PAIA request for access to records, with additional fees for search, preparation, and reproduction of records as prescribed in terms of section 54 of PAIA and the applicable Regulations.

AVAILABILITY OF THIS MANUAL

A copy of this Manual is available:

• https://kla.co.za/ – available for download on KLA’s website;
• At KLA’s head office in Johannesburg for public inspection during normal business hours;
• Upon request to the Information Officer, against payment of a reasonable prescribed fee (per the PAIA Regulations); and
• To the Information Regulator upon request.

 A fee for reproduction or copying of this Manual or any other records, as contemplated in Annexure B of the PAIA Regulations, shall be payable per each A4-size photocopy made. In addition, a request fee of R50.00 is payable before further processing of any formal PAIA request for access to records, with additional fees for search, preparation, and reproduction of records as prescribed in terms of section 54 of PAIA and the applicable Regulations.

UPDATING OF THIS MANUAL

The Information Officer of Kaufman Levin Associates (Pty) Ltd will review and update this Manual on a regular basis (at minimum annually, or upon any material change to KLA’s structure, operations, or applicable legislation). All updated versions will be made available in the same manner as described in Section 9 above.

ISSUANCE AND AUTHORISATION

Issued by:

Babalwa Donkrag
Managing Director
KLA