PAIA Manual.

1. Introduction
This manual has been compiled in accordance with section 51 of the Promotion of Access toInformation Act, 2000 (“PAIA”). This manual explains how requesters can submit requests
for access to information to CM.com in terms of PAIA.

2. The business
2.1

James Bayhack has been duly appointed as the head by the head of CM.com, as theInformation Officer for CM.com and is the person to whom requests for access toinformation must be made in terms of PAIA and in terms of the Protection of Personal
Information Act 4 of 2013 (“POPIA”).

3. CM.com’s Contact Details
This manual has been compiled in accordance with section 51 of the Promotion of Access toInformation Act, 2000 (“PAIA”). This manual explains how requesters can submit requests
for access to information to CM.com in terms of PAIA.

Details

Chief Executive Officer

Information Officer

Name:

Jeroen van Glabbeek

James Bayhack

Postal Address:

Mazars House, Rialto Rd

The Foundry, 16 Ebenezer Rd

Century City, Cape Town

Green Point, Cape Town

7441, South Africa

8001, South-Africa

Mazars House, Rialto Rd

The Foundry, 16 Ebenezer Rd

Century City, Cape Town

Green Point, Cape Town

7441, South Africa

8001, South-Africa

Telephone:+27 (21) 180 2560

+27 (21) 300 2258

E-mail:support@cm.com

James.Bayhack@cm.com

Physical Address:

4. The Section 10 Guide on how to use PAIA
4.1

The South African Human Rights Commission (“SAHRC”) has published a guide asprescribed by Section 10 of PAIA. This guide will be available from the SAHRC until
30 June 2021, in each official language, at the offices of the SAHRC and on its website,
listed below. Please direct any queries regarding this guide to:South African Human Rights Commission:
PAIA Unit
The Research and Documentation Department
Private Bag X2700, Houghton, 2041
Telephone number: (011) 877 3600
Telefax Number: (011) 403 0684
Website: www.sahrc.org.za
Email: info.sahrc.org.za

PAIA ManualPage 24.2

From 1 July 2021 onwards, the above guide, as updated by the Information Regulator,
will be available at the offices of the Information Regulator and on its website asprescribed by Section 10 of PAIA and in accordance with the Protection of Personal
Information Act, 2013 (“POPIA”). From 1 July 2021, please direct any queries
regarding this guide to:Information Regulator:
The Research and Documentation Department
33 Hoofd Street, Forum III, 3rd Floor Braampark
P.O. Box 31533, Braamfontein, Johannesburg, 2017
Telephone number: 010 023 5200
Website: www.justice.gov.za/inforeg/
Email (complaints): complaints.IR@justice.gov.za
Email (General enquiries): inforeg@justice.gov.za

Records that are available by CM in termsof other legislation
A requester may request information which is available in terms of the following legislation,
provided that the requester complies with the requirements set out in such legislation, thismanual and PAIA:

5.1Basic Conditions of Employment Act, 1997;

5.2

Broad-Based Black Economic Empowerment Act, 2003;

5.3

Companies Act, 2008;

5.4

Compensation for Occupational Injuries and Diseases Act, 1993;

5.5

Employment Equity Act, 1998;

5.6

Income Tax Act, 1962;

5.7

Labour Relations Act, 1995;

5.8

Occupational Health and Safety Act, 1993;

5.9

Promotion of Access to Information Act, 2000;

5.10 Protection of Personal Information Act, 2013;
5.11

Skills Development Levies Act, 1999;

5.12 Unemployment Insurance Act, 2001;
5.13 Value Added Tax Act, 1991;

PAIA ManualPage 36. Subjects and categories of information heldby CM.com
The subjects and categories of records held by CM.com are as follows:

SubjectCategoryCompany Records•

Constitutional documents (including incorporation
documents, the memorandum of incorporation and theshareholders agreement)•

4 Share registers, share certificates, registers and details
concerning shareholder meetings and resolutions•

Details concerning the identity of directors, directors’
meetings, director resolutions•

Statutory registers and minute books•

Budget reports•

Bank records•

Financial statements•

Management accounts•

Audit reports•

Insurance records•

Tax records

Strategic and operational•

Business plan		information•

Budget reports•

Minutes of management meetings•

Minutes of board meetings•

Annual reports•

Asset register		•Share certificates•

Trade marks schedule•

Debtors information•

Bank account reconciliation•

Loan agreements•

General ledger

Financial RecordsAssets

Liabilities

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SubjectCategory

Information technology•

Asset register•

Repair and maintenance records•

Software programmes•

Software licences•

IT policies and procedures•

Software records•

B-BBEE compliance records•

General policies and procedures•

Staff records•

Contracts of employment•

Statutory records•

Training and skills development records•

Employment equity records•

Leave records•

Beneficiary records•

HR policies and procedures•

Disciplinary procedures•

Salary information•

Pension fund information•

Medical aid information•

Contracts with customers•

Contracts with suppliers

Compliance

Human resources

Contractual relationships

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7. Description of personal information processing
in terms of POPIA
CM.com processes personal information as follows:

Subject

Category

Purpose of the processing•

Sale of products and services•

To market products and services to customers•

To comply with statutory obligations•

Customer relations purposes•

To conduct market research surveys•

Security, administrative and legal purposes•

To fulfil contractual obligations that we havewith customers or third parties

Data subject categories and•

Employees: record of employee life cycle

their personal information•

General public: general enquiries and viewing
the company website•

Industry bodies: membership records•

Media: records of media interactions•

Service providers: record of service provider
life cycle

Recipients of personal•

Employee pension funds

information•

Financial institutions•

Industry bodies•

Law enforcement•

Medical aid schemes•

Operators (service providers)•

Statutory authorities

Expected transnational•

Transfer of personal information to operatorstransfer of personal•Transfer of personal information to other members

information

PAIA Manualin the group

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SubjectCategory

Security measures to protect

Physical security measurespersonal information•

Access control measures•

Internal security measures

Cyber security measures•

Anti-spam measures•

Anti-virus measures•

Installing security firewalls•

Password control•

Training programs on information security•

Information security audits•

IT-related company policies

For more information on how we process personal information, please refer to our privacy policy available athttps://www.cm.com/en-gb/app/legal/cm-telecom-southafrica-pty-ltd/privacy-policy/

8. The request procedure
8.1

Prescribed form

8.1.1

A request for information must be made in the prescribed form, a copy of which isattached as Annexe A, must be addressed to the Information Officer and must besubmitted with the prescribed fee (see paragraph 8.3).

8.1.2

The prescribed request form is available from the Information Officer and from theSouth African Human Commission (if the request is before 1 July 8 2021) or theInformation Regulator (if the request is after 1 July 2021), whose contact details are set
out in paragraph 4 above.

8.2

Manner of request

8.2.1

The request must be made to the address, facsimile number or email address of [thecompany] set out in paragraph 3 above.

8.2.2

The requester must provide enough detail on the request form to enable theInformation Officer to identify the record and the requester. The requester should
also indicate which form (mode/method) of access is required. The requester should
indicate if it requires notice of the decision of the Information Officer in any manner,other than in writing.

8.2.3

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 orprotection of that right.

PAIA ManualPage 7

8.2.4

8.3

If a request is made on behalf of another person, the requester must submit proof ofthe capacity in which the requester is making the request to the satisfaction of theInformation Officer.
Fees

8.3.1

A requester who seeks access to a record containing personal information must pay
the required request fee.

8.3.2

The Information Office must by notice, require the requester to pay the prescribedfee, if any, before further processing the request.

8.3.3

The requester may lodge an application to the high court relating to the payment of
the request fee.

8.3.4

After the Information Officer has decided on the request, the requester must be
notified in the required form.

8.3.5

If the request is granted, a further access fee must be paid for the search,
reproduction, preparation and for any time, in excess of the prescribed hours, required
to search and prepare for the record disclosure.

8.3.6

The prescribed fees are available from the Information Officer and from the South
African Human Commission (if the request is before 1 July 9 2021) or the Information
Regulator (if the request is after 1 July 2021), whose contact details are set out inparagraph 3 above.

8.4

Availability of this manualThis manual is available for inspection at:
9.1

CM.com’s website, www.cm.com;

9.2

CM.com’s principal place of business set out in paragraph 3 above, during normal
business hours;

9.3

the SAHRC until 1 July 2021 (see contact details in paragraph 4.1 above); and9.4

the Information Regulator from 1 July 2021 onwards (see contacts details in paragraph
4.2 above).

PAIA Manual

Page 8Request for access to record

1Annexe A

Particulars of (the company)
Name of (the company):
Registration number:
The Head:
Physical Address:
Postal Address:
Telephone:Telefacsimile:
E-mail:2

Particulars of person requesting access to the record
2.1

The full particulars of the person who requests access to the record must be given below.

2.2

The address and/or fax number in the Republic to which the information is to be sent must be given.

2.3

Proof of the capacity in which the request is made, if applicable, must be attached.

Full names and surname:Identity Number:
Postal Address:
Fax Number:
Telephone Number:
E-mail:Capacity in which request is madewhen made on behalf of another person:

3

Particulars of person on whose behalf request is madeThis section must be completed ONLY if a request for information is made on behalf of another person.

Full names and surname:Identity Number:

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4

Particulars of record
4.1

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.

4.2

If the space is inadequate, please continue on a separate folio and attach it to this form.
The requester must sign all the additional folios.

Description of record or relevant part of the record:

Reference number, if available:

Any further particulars of record:

5Fees
5.1

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.

5.2

You will be notified of the amount required to be paid as the request fee.

5.3

The fee payable for access to a record depends on the form in which access isrequired and the reasonable time required to search for and prepare a record.

5.4

If you qualify for exemption of the payment of any fee, please state the reason for exemption.

Reason for exemption from payment of fees:

6Form of access to record
If you are prevented by an impediment or disability to read, view or listen to the recordin the form of access provided for in 1 to 4 hereunder, state your disability and indicate inwhich form the record is required.

Description of record or relevant part of the record:

Reference number, if available:

PAIA ManualPage 10

Choose the appropriate boxes in the form below.
6.1

Compliance with your request in the specified form may depend on the form in which
the record is available.

6.2

Access in the form requested may be refused in certain circumstances. In such case,
you will be informed if access will be granted in another form.

6.3

The fee payable for access to the record, if any, will be determined partly by the form
in which access is requested.

If the record is written or printed form:

Copy of record*

Inspection of record

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

View the images

Copy of the images*

Transcription of the images*

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

Listen to thesoundtrack(Audio cassette)

Transcription of soundtrack(Written or printed
document)

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

Printed copyof record*

Printed copy ofinformation derived
from the record*

Copy in computerreadable form* (Stiffy orcompact disc)*If you requested a copy or transcription of a record (above), do you wish the copy
or transcription to be posted to you? Postage is payable.

Yes

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7Particulars of the right to be exercised or protected
If the provided space is inadequate, please continue on a separate folio and attach itto this form. The requester must sign all the additional folios.

Indicate which right is to be exercised or protected:Explain why the record requested is required for the exercise orprotection of the aforementioned right:

8

Notice of decision regarding request of 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 thenecessary particulars to enable compliance with your request.

Date:

Signature of requester/person onwhose behalf this request is made

PAIA ManualPage 12

CM.com (AMS: CMCOM) is a global leader in cloud software for conversational commerce that enables businesses
to deliver a superior customer experience. Our communications and payments platform empowers marketing,sales and customer support to automate engagement with customers across multiple mobile channels, blended
with seamless payment capabilities that drive sales, gain customers and increase customer happiness.
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