GUERBET SOUTH AFRICA (PTY) LTD MANUAL
as prescribed by the provisions of
THE PROMOTION OF ACCESS TO INFORMATION ACT (PAIA), 2000
andTHE PROTECTION OF PERSONAL INFORMATION ACT (POPIA), 2013

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Contents
1.

DEFINITIONS ................................................................................................................................... 3

2.

PURPOSE OF THE MANUAL ............................................................................................................. 7

3.

COMPANY DETAILS ......................................................................................................................... 8

4.

CONTACT DETAILS OF THE INFORMATION OFFICER ....................................................................... 8

5.

PUBLICATION AND AVAILABILITY OF CERTAIN RECORDS IN TERMS OF THE PAIA ......................... 96.

SAHRC GUIDE .................................................................................................................................. 9

7.

RIGHT OF ACCESS TO RECORDS OF PRIVATE BODIES IN TERMS OF PAIA ..................................... 10

8.

GROUNDS FOR REFUSAL OF ACCESS TO RECORDS IN TERMS OF PAIA ........................................ 12

9.

INFORMATION OR RECORDS NOT FOUND ................................................................................... 13

10.
REMEDIES AVAILABLE TO THE REQUESTER UPON REFUSAL OF A REQUEST FOR ACCESS IN
TERMS OF PAIA ..................................................................................................................................... 13
11.

PROCEDURE FOR A REQUEST FOR ACCESS IN TERMS OF PAIA AND POPIA ............................. 14

12.

FEES ........................................................................................................................................... 15

13.

DECISION TO GRANT ACCESS TO RECORDS .............................................................................. 16

14.

PROTECTION OF PERSONAL INFORMATION THAT IS PROCESSED BY THE COMPANY.............. 17

15.

AVAILABILITY OF THE MANUAL................................................................................................. 22

16.

RESERVATION OF RIGHTS ......................................................................................................... 23

17.

REVISION HISTORY .................................................................................................................... 23

APPENDIX 1 ........................................................................................................................................... 24
APPENDIX 2 ........................................................................................................................................... 27
APPENDIX 3 ........................................................................................................................................... 29
APPENDIX 4 ........................................................................................................................................... 34
APPENDIX 5 ........................................................................................................................................... 36
APPENDIX 6 ........................................................................................................................................... 41
APPENDIX 7 ........................................................................................................................................... 42
APPENDIX 8 ........................................................................................................................................... 44

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1. DEFINITIONS
1.1

Companymeans

GuerbetSouth

Africa(Pty)

Ltd(RegistrationNo:

2012/184409/07), a company duly registered and incorporated with the company
laws of the Republic of South Africa and having its place of business situated at,
Hertford Office Park, Building I, 90 Bekker Road, Vorna Valley, Midrand, Gauteng,
1682
1.2

Conditions for Lawful Processing means the conditions for the lawful processingof Personal Information as fully set out in chapter 3 of the POPIA;

1.3

Constitution means the Constitution of the Republic of South Africa, 1996;

1.4

Client refers to any natural or juristic person that received or receives legal
services from the Guerbet South Africa (Pty) Ltd;

1.5

Data Subject has the meaning ascribed thereto in section 1 of the POPIA, which isa person to whom personal information relates, being a client, debtor or any
other third party;

1.6

Information Officer, in relation to a private body, means the head of the private
body as contemplated in Section 1 of the PAIA and Regulation 5.1 of the POPIA
Regulations, in this case being Mia Louw, who is the General Manager, as referred
to in clause 4;

1.7

Information Regulator means the Regulator established in terms of Section 39 of
the POPIA, with the powers, duties and functions as contained in Section 40 of the
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1.8

Manual means this manual prepared in accordance with section 51 of the PAIA
and regulation 4(1) (c) of the POPIA Regulations;

1.9

PAIA means the Promotion of Access to Information Act, 2000;

1.10

Personal Information has the meaning ascribed thereto in section 1 of the POPIA,
which means information relating to an identifiable, living, natural person, andwhere it is applicable, an identifiable, existing juristic person, including but notlimited to:a)information relating to the race, gender, sex, pregnancy, marital status,
national, ethnic or social origin, colour, sexual orientation, age, physical ormental health, well-being, disability, religion, conscience, belief, culture,
language and birth of the person;b)

information relating to the education or the medical, financial, criminal or
employment history of the person;c)any identifying number, symbol, e-mail address, physical address, telephone
number, location information, online identified or other particular(s)assignment to the person;d)the biometric information of the person;e)the personal opinions, views or preferences of the person;f)correspondence sent by the person that is implicitly or explicitly of a private
or confidential nature of further correspondence that would reveal thecontents of the original correspondence;g)

the views or opinions of another individual about the person; andh)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.

1.11

Personnel refers to any person who works for, or provides services to or on behalfof the Guerbet South Africa (Pty) Ltd, and receives or is entitled to receive
remuneration and any other person who assists in carrying out or conducting thebusiness of the Guerbet South Africa (Pty) Ltd, which includes, without limitation,

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directors (executive and non-executive), all permanent, temporary and part-time
staff as well as candidate attorneys and other contract workers;
1.12

POPIA means the Protection of Personal Information Act, 2013;

1.13

POPIA Regulations mean the regulations promulgated in terms of section 112(2)of POPIA;

1.14

Private Body has the meaning ascribed thereto in sections 1 of both the PAIA and
the POPIA which isa) a natural person who carries or has carried on any trade, business or
profession, but only in such capacity;b) a partnership which carries or has carried on any trade, business or profession;orc) any former or existing juristic person but excludes a public body.

1.15

Processing has the meaning ascribed thereto in section 1 of the POPIA, which is
any operation or activity or any set of operations, whether or not by automaticmeans, concerning personal information, including: a) the collection, receipt, recording, organisation, collation, storage, updating or
modification, retrieval, alteration, consultation or use;b) dissemination by means of transmission, distribution or making available in any
other form; orc) merging, linking, as well as restriction, degradation, erasure or destruction of
information.

1.16

Responsible Party has the meaning ascribed thereto in section 1 of the POPIA,
which is a public or private body or any other person which, alone or in
conjunction with others, determines the purpose of and means for processing
personal information;

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1.17

Record has the meaning ascribed thereto in section 1 of the PAIA and Section 1 of
the POPIA, which means any recorded information, regardless or form or
medium, in the possession or under the control of a responsible party, whether or
not it was created by a responsible party, and regardless of when it came into
existence.

1.18

Requester has the meaning ascribed thereto in section 1 of the PAIA, whichmeans, in relation to the Company being a private body, any person, including but
not limited to, a public body or an official thereof, making a request for access toa record of that private body, or a person acting on behalf of the person
contemplated above. This is other than the Data Subject himself/herself/itself.

1.19

Request for Access has the meaning ascribed thereto in section 1 of the PAIA asread with Section 50 of the PAIA and Section 23 of the POPIA; and1.20

SAHRC means the South African Human Rights Commission.

Capitalised terms used in this Manual have the meanings ascribed thereto in section 1 of
the POPIA and the PAIA as the context specifically requires, unless otherwise defined
herein.

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2. PURPOSE OF THE MANUALThis Manual:
2.1 in general, provides the postal and street address, phone and email address of thehead of the Guerbet South Africa (Pty) Ltd;
2.2 for the purposes of the PAIA, details a description of the SAHRC guide in terms of
Section 10 of the PAIA and how to access it, contains the latest Section 52(2) Noticewith regards to the categories of record of Guerbet South Africa (Pty) Ltd, which areavailable without a person having to request access thereto, a description of therecords of Guerbet South Africa (Pty) Ltd, which are available in accordance with anyother legislation and sufficient detail of the procedure to be followed by a Requester
and the manner in which a Request for Access will be facilitated; and2.3 for the purposes of the POPIA, amongst other things, details the purpose for which
Personal Information may be processed; a description of the categories of Data
Subjects for whom Guerbet South Africa (Pty) Ltd Processes Personal Information as
well as the categories of Personal Information relating to such Data Subjects; therecipients to whom Personal Information may be supplied; the process should there
be any transborder flow of the personal information and a general description
allowing a preliminary assessment of the suitability of the information security
measures to be implemented by the Responsible Party to ensure confidentiality,
integrity and availability of the information which is to be processed.

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3. COMPANY DETAILS

3.1 The details of the Company are as follows:
Physical address

Guerbet South Africa (Pty) Ltd
Hertford Office Park
Building I
90 Bekker Road, Vorna Valley
MidrandGauteng
1682

Postal address:

As above

Email address:

orders.sa@guerbet.com

Tel number+27 10 0450300

4. CONTACT DETAILS OF THE INFORMATION OFFICER

4.1 The Information Officer’s contact details are as per Appendix 8 Registration
Certificate Information Regulator (South Africa).

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5. PUBLICATION AND AVAILABILITY OF CERTAIN RECORDS IN TERMS OF THE PAIA

5.1 Schedule of Records
The Schedule of Records as contained in Appendix 1 of this Manual details the
Records that are held and/or Processed by Guerbet South Africa (Pty) Ltd for the
purposes of the PAIA and the POPIA respectively. Access to such Records may not be
granted if they are subject to the grounds of refusal which are specified in clause 7
below. In terms of Regulation 9A, Guerbet South Africa (Pty) Ltd voluntarily /automatically avails its online articles and this Manual for access to the public.
5.2 List of applicable legislation
5.2.1

Guerbet South Africa (Pty) Ltd retains records which are required in terms oflegislation other than the PAIA.
5.2.2

Certain legislation provides that private bodies shall allow certain persons

access to specified records, upon request. Legislation that may be consulted toestablish whether the Requester has a right of access to a record other than interms of the procedure set out in the PAIA are set out in Appendix 2.
6. SAHRC GUIDE

6.1 A guide has been complied in terms of Section 10 of the PAIA by the Human Rights
Commission. It contains information required by a person wishing to exercise any
right, contemplated by the PAIA. It is available in all the official languages.
6.2 The Guide is available for inspection, inter alia, at the offices of the Human Rights
Commission, contact details of which are as follows:

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Address:
29 Princess of Wales Terrace
Cnr York and St. Andrews Street
Parktown
2193
Postal:South African Human Rights Commission
Promotion of Access to Information Act Unit
Private Bag 2700
Houghton
2041
Telephone: (011) 484-8300
Telefax: (011) 484-0582
Website: www.sahrc.org.za
E-mail: paiar.sahrc.org.za

7. RIGHT OF ACCESS TO RECORDS OF PRIVATE BODIES IN TERMS OF PAIA

A Requester must be given access to any record of a private body if the record isrequired for the exercise or protection of any rights, that requester complies withthe procedure relating to access and access to that record is not refused on a groundin terms of Part 3, Chapter 4 of this Act. Such request shall include a request foraccess to a record containing personal information about the requester or the
person on whose behalf the request is made. Should a public body require access toa record for the exercise or protection of any rights other than its own rights, then it
must be acting in the public interest.

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As contemplated in Sections 23 and 24 of the POPIA, a Data Subject may, upon proofof adequate identification, within a reasonable time and at a reasonable fee, request
access to the personal information held by Guerbet South Africa (Pty) Ltd which
personal information relates to the Data Subject, including information about theidentity of all third parties or categories of third parties who have or have had accessto such personal information. The Data Subject must comply with clause 11 below inrespect of requests for access.
The Data Subject is further entitled to request a correction or deletion of theirpersonal information, which request must be in the correct format, on the following
grounds:
1) In light of the purpose for processing the information, it is inaccurate, irrelevant,excessive, out of date, incomplete, misleading or has been obtained unlawfully;or2) The Company is no longer authorised to retain such personal information.
Form 2 of the POPIA Regulations is used for correction / deletion of personal
information and is appended hereto as Appendix 3A
Upon request in terms of the POPIA, Guerbet South Africa (Pty) Ltd must give theData Subject a written estimate of the fee for providing the services and request thata deposit is paid. The PAIA has prescribed statutory fees for any request in terms
thereof, where any person other than the Data Subject itself has requested access torecords. However, the same fees shall be applicable to any request made in terms of
Section 23 and 24 of the POPIA for uniformity purposes.

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8. GROUNDS FOR REFUSAL OF ACCESS TO RECORDS IN TERMS OF PAIA

The following are the grounds on which Guerbet South Africa (Pty) Ltd may, subject tothe exceptions contained in Part 3, Chapter 4 of the PAIA, refuse a Request for Access inaccordance with Chapter 4 of the PAIA:
8.1 mandatory protection of the privacy of a third party who is a natural person,
including a deceased person, where such disclosure of Personal Information would
be unreasonable.
8.2 mandatory protection of the commercial information of a third party, if the Records
contain:
8.2.1 trade secrets of that third party;
8.2.2

financial, commercial, scientific or technical information of the third

party, the disclosure of which could likely cause harm to the financial orcommercial interests of that third party; and/or
8.2.3

information disclosed in confidence by a third party to Guerbet South

Africa (Pty) Ltd, the disclosure of which could put that third party at a
disadvantage in contractual or other negotiations or prejudice the third party
in commercial competition;
8.3 mandatory protection of confidential information of third parties if it is protected interms of a duty of confidence owed to the third party in terms of an agreement;
8.4 mandatory protection of the safety of individuals and the protection of property;
8.5 mandatory protection of Records that would be regarded as privileged in legal
proceedings;

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8.6 protection of the commercial information of the Company, which may include:
8.6.1

trade secrets;

8.6.2

financial/commercial,scientificortechnical

information,

thedisclosure of which could likely cause harm to the financial orcommercial interests of Guerbet South Africa (Pty) Ltd;
8.6.3

information which, if disclosed, could put the Company at a
disadvantage in contractual or other negotiations or prejudice
Guerbet South Africa (Pty) Ltd in commercial competition; and/or

8.6.4

computer programs which are owned by Guerbet South Africa (Pty)
Ltd, and which are protected by copyright and intellectual property
laws;

8.7 research information of Guerbet South Africa (Pty) Ltd or a third party, if suchdisclosure would place the research or the researcher at a serious disadvantage; and8.8 Requests for Records that are clearly frivolous or vexatious, or which involve an
unreasonable diversion of resources.
9. INFORMATION OR RECORDS NOT FOUND

If Guerbet South Africa (Pty) Ltd cannot find the records that the Requester is looking fordespite reasonable and diligent search and it believes either that the records are lost orthat the records are in its possession but unattainable, the Requester will receive a noticein this regard from the Information Officer in the form of an affidavit setting out themeasures taken to locate the document and accordingly the inability to locate thedocument.
10. REMEDIES AVAILABLE TO THE REQUESTER UPON REFUSAL OF A REQUEST FORACCESS IN TERMS OF PAIA

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10.1 The Company does not have internal appeal procedures. As such, the decision madeby the Information Officer is final, and Requesters will have to exercise such external
remedies at their disposal if the Request for Access is refused
10.2 In terms of Section 77A of the PAIA, a requester may submit a complaint to the
Information Regulator within 180 days of Guerbet South Africa (Pty) Ltd decision,
The Information Regulator will then investigate the complaint and advise therequester of the decision accordingly. The Information Regulator may issue an
Enforcement Notice to the Company which obliges Guerbet South Africa (Pty) Ltd tocomply with the request.
10.3 In accordance with sections 56(3) (c) and 78 of the PAIA, a Requester may apply to a
court for relief within 180 days of notification of the decision for appropriate relief, if
the requester has exhausted the Company’s internal remedies or has referred thematter to the Information Regulator in terms of Section 77A without any success.
11. PROCEDURE FOR A REQUEST FOR ACCESS IN TERMS OF PAIA AND POPIA

11.1 A Requester must comply with all the procedural requirements as contained in
section 53 of PAIA relating to a Request for Access to a Record.
11.2 A Requester must complete the prescribed Request for Access form attached as
Appendix 3 and submit the completed Request for Access form as well as paymentof a request fee (if applicable) and a deposit (if applicable), to the Information Officer
at the postal or physical address, facsimile number or electronic mail address statedin clause 4 above.
11.3 The Request for Access form must be completed with enough detail to enable theInformation Officer to identify the following:
11.3.1 the Record/s requested;
11.3.2 the identity of the Requester;
11.3.3 the form of access that is required, if the request is granted;
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11.3.4 the postal address or fax number of the Requester; and11.3.5 the right that the Requester is seeking to protect and an explanation as towhy the Record is necessary to exercise or protect such a right.
11.4 If a Request for Access is made on behalf of another person, the Requester must
submit proof of the capacity in which the Requester is making the request to thereasonable satisfaction of the Information Officer.
11.5 If an individual is unable to complete the prescribed form because of illiteracy ordisability, such a person may make the request orally.
11.6 Guerbet South Africa (Pty) Ltd will voluntarily provide the requested Records to a
Personal Requester (as defined in section 1 of the PAIA). The prescribed fee forreproduction of the Record requested by a Personal Requester will be charged inaccordance with section 54(6) of the PAIA and paragraph 11 below.
12. FEES

12.1 When the Request for Access is received by the Information Officer, the Information
Officer will by notice require the Requester, other than a Personal Requester, to pay
the prescribed request fee (if any) before further processing of the Request forAccess.
12.2 Prescribed request fees are set out in Appendix 4.
12.3 If the search for a Record requires more than the prescribed hours for this purpose,
the Information Officer will notify the Requester to pay as a deposit, the prescribed
portion of the access fee (being not more than one third) which would be payable if
the Request for Access is granted.
12.4 The Information Officer will withhold a Record until the Requester has paid the fees
set out in Appendix 4.
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12.5 A Requester whose Request for Access to a Record has been granted, must pay anaccess fee for reproduction and for search and preparation, and for any time
reasonably required more than the prescribed hours to search for and prepare theRecord for disclosure, including making arrangements to make it available in arequested form provided for in the PAIA.
12.6 If a deposit has been paid in respect of a Request for Access which is refused, theInformation Officer will repay the deposit to the Requester.
13. DECISION TO GRANT ACCESS TO RECORDS

13.1 Guerbet South Africa (Pty) Ltd will decide whether to grant or decline the Request
for Access within 30 days of receipt of the Request for Access and must give noticeto the Requester with reasons (if required) to that effect.
13.2 The period referred to above may be extended for a further period of not morethan 30 days if the Request for Access is for a large number of Records or theRequest for Access requires a search for Records held at an off-site storage facility
and the Records cannot reasonably be obtained within the original 30-day period.
13.3 Guerbet South Africa (Pty) Ltd will notify the Requester in writing should anextension of time as contemplated above be required.
13.4 If, in addition to a written reply from the Information Officer, the Requester wishes
to be informed of the decision on the Request for Access in any other manner, theRequester must state the manner and particulars so required.

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14. PROTECTION OF PERSONAL INFORMATION THAT IS PROCESSED BY THE COMPANY

14.1 Chapter 3 of the POPIA provides for the minimum Conditions for Lawful Processingof Personal Information by a Responsible Party. These conditions may not bederogated from unless specific exclusions apply as outlined in the POPIA.
The conditions are as follows:
1) Accountability (Section 8);2) Processing limitation (Sections 9 to 12);3) Purpose specification (sections 13 to 14);4) Further processing limitation (Section 15);
5) Information quality (Section 16);6) Openness (Sections 17 to 18);
7) Security safeguards (Sections 19 to 22); and
8) Data subject participation (Sections 23 to 25).
14.2 Guerbet South Africa (Pty) Ltd needs Personal Information relating to bothindividual and juristic persons to carry out its business and organisational functions.
Guerbet South Africa (Pty) Ltd provides a variety of legal services including inter alia
winding-up of deceased estates, conveyancing, court proceedings and commercial
legal services, and as such processes the personal information in accordance thereto.
14.3 The way this information is Processed and the purpose for which it is Processed isdetermined by Guerbet South Africa (Pty) Ltd according to the action authorised by
the Client. Guerbet South Africa (Pty) Ltd requires its Clients to conclude mandates
with the respective company representatives, which mandates shall outline thereason for processing the personal information and the action which the Client
requires in respect of legal services to be rendered.

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14.4 Guerbet South Africa (Pty) Ltd is accordingly a Responsible Party for the purposes of
the POPIA and will ensure that the Personal Information of a Data Subject:
14.4.1 is processed lawfully, fairly, transparently and in a reasonable manner that
does not infringe the privacy of the Data Subject. This includes obtaining therequisite consent from the Data Subject in the form of a privacy or datacollection notice, unless:1.

the processing is necessary to carry out the actions for the conclusion or
performance of a contract to which the Data Subject is a party;2.

the processing complied with an obligation imposed by law on the
responsible party;3.

the processing protects a legitimate interest of the Data Subject; or4.

the processing is necessary for pursuing the legitimate interest of theCompany or of a third party to whom the personal information is
supplied.

14.4.2 is collected directly from the Data Subject unless such personal information
forms public record, collection from another source is necessary for the
conduct of proceedings in any court or tribunal that have commenced or arereasonably contemplated, collection from another source would benecessary to maintain the legitimate interests of the responsible party or of athird party, or obtaining consent would prejudice a lawful purpose of thecollection or not be reasonably practicable in the circumstances;
14.4.3 is processed only for the purposes for which it was collected, which purpose
is related to a function or activity of the Company as stipulated above;
14.4.4 will not be processed for a secondary purpose unless inter alia thatprocessing is compatible with the original purpose, or the Data Subject hasconsented to the further processing, or the further processing is relevant forthe conduct of proceedings in any court or tribunal that have commenced or
are reasonably contemplated.
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14.4.5 is accurate and kept up to date, with Guerbet South Africa (Pty) Ltd taking
reasonably practicable steps to ensure such information is updated including
obtaining updated information from the Data Subject directly or from a third
party, as the case may be;
14.4.6 will be retained for a period of five years as required by relevant law unlessstated otherwise, and shall be destroyed or deleted as soon as reasonably
practicable after Guerbet South Africa (Pty) Ltd is no longer permitted toretain such information;
14.4.7 is processed in accordance with integrity and confidentiality principles; thisincludes physical and organisational measures to ensure that Personal
Information, in both physical and electronic form, are subject to an
appropriate level of security when stored, used and communicated by
Guerbet South Africa (Pty) Ltd or Data Subject, in order to protect against
access and acquisition by unauthorised persons and accidental loss,
destruction or damage. Considering this, the Company has established thefollowing safety measures:1.

locked cabinet storage which requires prior authorised access;2.

confidentiality and privacy internal workplace policies binding all
Company personnel to the provisions therein; and3.

online security measures to ensure authorised access to third party
databases to process personal information;

4.
14.4.8agreements of confidentiality with third party service providers.
is processed in accordance with the rights of Data Subjects ascontemplated in Sections 5, 11(2), 11(3), 23 and 24 of POPIA, whereapplicable. Data Subjects have the right to:

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14.4.8.1

be notified that their Personal Information is being collected

by. Guerbet South Africa (Pty) Ltd. The Data Subject also has the right tobe notified in the event of a data breach;
14.4.8.2

know whether Guerbet South Africa (Pty) Ltd holds Personal

Information about them, and to access that information. Any request for
information must be handled in accordance with the provisions of thisManual;14.4.8.3

request the correction or deletion of inaccurate, irrelevant,excessive, out of date, incomplete, misleading or unlawfully obtained
personal information;
14.4.8.4

object to Guerbet South Africa (Pty) Ltd use of their Personal

Information and request the deletion of such Personal Information(deletion would be subject to the Company’s record keeping
requirements);
14.4.8.5

object to the processing of Personal Information for purposesof direct marketing by means of unsolicited electronic communications;and14.4.8.6

complain to the Information Regulator regarding an alleged

infringement of any of the rights protected under POPIA and to institutecivil proceedings regarding the alleged non-compliance with theprotection of his, her or its personal information.
14.5 Personal Information of Children
Guerbet South Africa (Pty) Ltd shall only process personal information of children withthe prior consent of the Data Subject or if it is necessary for the establishment, exercise
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or defence of a right or obligation in law. The Company respects the rights of the child.
The purposes for processing such information, if necessary, are outlined in Part 1 ofAppendix 5.
14.6 Purpose of the Processing of Personal Information by Guerbet South Africa (Pty) Ltd
As outlined above, Personal Information may only be Processed for a specific purpose.
The purposes for which the Company Processes or will Process Personal Information isset out in Part 1 of Appendix 5.

14.7 Categories of Data Subjects and Personal Information/special Personal Information
relating thereto
As per section 1 of POPIA, a Data Subject may either be a natural or a juristic person. Part
2 of Appendix 5 sets out the various categories of Data Subjects that the Company
Processes Personal Information on and the types of Personal Information relating
thereto.
Recipients of Personal Information
Part 3 of Appendix 5 outlines the recipients to whom the Company may provide a Data
Subjects Personal Information to.
14.8 Description of information security measures to be implemented by Guerbet South
Africa (Pty) Ltd
Part 4 of Appendix 5 sets out the types of security measures to implemented by Guerbet
South Africa (Pty) Ltd to ensure that Personal Information is respected and protected. A
preliminary assessment of the suitability of the information security measures
implemented or to be implemented by the Company may be conducted to ensure that
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the Personal Information that is processed by the Company is safeguarded and Processedin accordance with the Conditions for Lawful Processing.
14.9 Objection to the Processing of Personal Information by a Data Subject
Section 11 (3) of the POPIA and regulation 2 of the POPIA Regulations provides that a
Data Subject may, at any time object to the Processing of his/her/its Personal
Information in the prescribed statutory form attached to this manual as Appendix 6
subject to exceptions contained in the POPIA.
14.10

Request for correction or deletion of Personal Information

Section 24 of the POPIA and regulation 3 of the POPIA Regulations provides that a Data
Subject may request for their Personal Information to be corrected/deleted in theprescribed form attached as Appendix 7 to this Manual.
15. AVAILABILITY OF THE MANUAL

15.1 This Manual is made available in terms of the PAIA and section 4 of the Regulations
to the POPIA.
15.2 This Manual is also available at: https://www.guerbet.com/en-za/

15.3 This Manual is further available at the offices of by Guerbet South Africa (Pty) Ltd forinspection during normal business hours. No fee will be levied for inspection ascontemplated in this clause.
15.4 Copies of the Manual can be obtained from the Information Officer. A fee will belevied for copies of the manual in accordance with Appendix 4.
15.5 Access forms are also available at https://www.justice.gov.za/inforeg/docs2-f.html
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16. RESERVATION OF RIGHTS

Nothing in this manual is to be construed as a waiver of the right to the confidentiality ofany document or any legal privilege or right of non-disclosure attaching to any document
mentioned herein, whether in terms of any statute or under the common law. All rights
in this regard are fully reserved.
17. REVISION HISTORY

VersionDescription of Changes

1

New

2

Updated with new physical address from Guerbet South Africa (Pty) Ltd

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APPENDIX 1

Description of the subjects on which by Guerbet South Africa (Pty) Ltd holds records, andthe categories of records held on each subject. Each of these records are available on
request in terms of the PAIA, subject to the provisions of the Act and subject to Attorney
Client privilege, in terms of Clause 7 above:
1. Client Records
1.1. Correspondence (recorded in writing, verbal or on WhatsApp or SMS); contact
numbers; email address; physical and postal address; fee records; contracts andmandates; business information; identity/passport document; proof of residence;banking records; consultation notes;
1.2. Management agreements; resolutions; minutes of meetings; memorandum ofincorporation; CIPC documentation; other legal documentation and contracts.
1.3. Accounting records; banking records; remittances; invoices and statements; tax
records and returns.
1.4. Personnel information; general terms of employment; letters of employment; policies
and codes of conduct; salary slips.
2. Property
Company / Client leases; building plans; asset register; finance and lease agreements formovable property
3. Legal
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Complaints; pleadings; briefs and other documents pertaining to any actual, pending or
threatened litigation, arbitration, or investigation; material licenses, permits andauthorizations.
4. Corporate Governance
Codes of conduct; staff and board meeting minutes; legal compliance records; policies;
Certificate of Incorporation; Memorandum and Articles of Association; Certificate toCommence Business; Minute Book, CM25 and CM26, as well as Resolutions passed at
general/class meetings.

5. Marketing
Brochures, newsletters, and advertising material; articles; public relations policies andprocedures.

6. Finance and Administration

Accounting

records; annual

financialstatements;

agreements; banking records;

correspondence; remittances; invoices and statements; tax records and returns; Books of
Account regarding information required by the Companies Act, 1973; invoices, statements,
receipts, vouchers and bills of exchange; databases; Law Society Records; internalcorrespondence; external correspondence; securities.
7. Human Capital

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BEE statistics; personnel information; employment equity reports; general terms of
employment; letters of employment; leave records; PAYE records and returns; performance
management records; assessments; Policies and procedures; UIF returns; salary or wage
information; aattendance register; staff records [including former staff members]; study
assistance schemes; staff loan schemes.

8. Information Management and Technology
Agreements; equipment register; information policies; standards, procedures andguidelines; insurance policies; software information and policies; agreements with online
service providers; hardware; operating systems; telephone exchange equipment; telephonelines, leased lines and data lines; LAN installations; software packages; disaster recovery;
internal system support and programming/development; capacity and utilisation of current
systems; development or investment plans; agreements, licenses and audits.

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APPENDIX 2

LIST OF APPLICABLE LEGISLATION
Administration of Deceased Estates Act 66 of 1965 (as amended)
Attorneys Act No. 53 of 1979
Basic Conditions of Employment Act 75 of 1997
Bills of Exchange Act 34 of 1964
Broad-Based Black Economic Empowerment Act 53 of 2003
Children’s Act 38 of 2005 (as amended)Child Justice Act 41 of 2007
Community Schemes Ombud Service Act 9 of 2011
Companies Act 71 of 2008
Compensation for Occupational Injuries and Diseases Act 130 of 1993
Competition Act 89 of 1998
Constitution of South Africa Act 108 of 1996
Consumer Protection Act 68 of 2009
Criminal Procedure Act 51 of 1977
Debt Collectors Act 114 of 1998 (as amended)
Disaster Management Act 57 of 2002 (as amended)
Divorce Act 70 of 1979 (as amended)
Domestic Violence Act 116 of 1998 (as amended)
Electronic Communications and Transactions Act 2 of 2000
Employment Equity Act 55 of 1998
Financial Intelligence Centre Act 38 of 2001
Formalities in Respect of Leases of Land Act 18 of 1969
Health Act 63 of 1977
Income Tax Act58 of 1962
Insolvency Act 24 of 1936
Institution of Legal Proceedings Against Certain State Organs Act 40 of 2002
Justice of the Peace and Commissioners of Oaths Act 16 of 1963
Labour Relations Act 66 of 1995
Legal Practice Act 28 of 2014
Local Government: Municipal Systems Act 32 of 2000
Magistrates’ Court Act 32 of 1944 (as amended)
Maintenance Act 99 of 1998 (as amended)
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Matrimonial Property Act 88 of 1984
National Credit Act 34 of 2005
Occupational Health and Safety Act 85 of 1993
Prescription Act 18 of 1943
Prevention & Combating of Corrupt Activities Act 12 of 2004
Prevention of Constitutional Democracy Against Terrorist & Related Activities Act 33 of 2004
Prevention of Organised Crime Act 121 of 1998
Promotion of Equality and Prevention of Unfair Discrimination Act 4 of 2000
Protected Disclosures Act 26 of 2000
Regulation of Interception of Communications and Provisions of Communication RelatedInformation Act 70 of 2002
Rental Housing Act 50 of 1999 (as amended)
Road Accident Fund Act 56 of 1996 (as amended)
Sectional Title Scheme Management Act 8 of 2011
Share Blocks Control Act 59 of 1980 (as amended)South African Reserve Bank Act 90 of 1989
Superior Courts Act 10 of 2013
Unemployment Insurance Act 63 of 2001
Unemployment Insurance Fund Contributions Act 4 of 2002
Value-Added Tax Act 89 of 1991
Although we have used our best endeavors to supply a list of applicable legislation, it ispossible that this list may be incomplete. Whenever it comes to our attention that existingor new legislation allows a Requester access on a basis other than as set out in PAIA, weshall update the list accordingly. If a Requester believes that a right of access to a record
exists in terms of other legislation listed above or any other legislation, the Requester isrequired to indicate what legislative right the request is based on, to allow the Information
Officer the opportunity of considering the request in light thereof.

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APPENDIX 3

ACCESS REQUEST FORM - RECORD OF PRIVATE BODY
(Section 53(1) of the Promotion of Access to Information Act, 2000)[Regulation 10]
COMPLETION OF ACCESS REQUEST FORM
1

The Access Request Form is available must be completed.

2

Proof of identity is required to authenticate the identity of the requester. Attach a
copy of the requester’s identification document.

3

Type or print in BLOCK LETTERS an answer to every question.

4

If a question does not apply, state “N/A”.

5

If there is nothing to disclose in reply to a question, state “nil”.

6

When there is insufficient space on a printed form, additional information may beprovided on an attached folio, and each answer on such folio must reflect theapplicable title.

7

Form is available in pdf / hardcopy.

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APPENDIX 4

FEES
1. The fee for a copy of the manual as contemplated in regulation 9(2)(c) is R1,10 for every
photocopy of an A4-size page or part thereof.
2. The fees for reproduction referred to in regulation 11(1) are as follows:a)

For every photocopy of an A4-size page or part thereof

R 1,10b)

For every printed copy of an A4-size page or part thereof held R 0,75
on a computer or in electronic or machine-readable formc)

For a copy in a computer-readable form on: -i)

Stiffy discR 7,50ii)

Compact Disc / Memory stick

R 70,00d)

For a transcription of visual images, for an A4-size page or part R 40,00

i)thereofii)

For a copy of visual imagese)

For a transcription of an audio record, for an A4-size page or R 20,00

i)part thereofii)

For a copy of an audio record

R 60,00

R 30,00

3. The request fee payable by a requester, other than a personal requester, referred to in
regulation 11(2) is R50,00.
4. The access fees payable by a requester referred to in regulation 11(3) are as follows:

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a)For every photocopy of an A4-size page or part thereof

R 1,10b)

For every printed copy of an A4-size page or part thereof held R 0,75
on a computer or in electronic or machine-readable formc)

For a copy in a computer-readable form on: -i)

Stiffy discR 7,50ii)

Compact Disc / Memory stick

R 70,00d)

For a transcription of visual images, for an A4-size page or part R 40,00

i)thereofii)

For a copy of visual imagese)

For a transcription of an audio record, for an A4-size page or R 20,00

i)part thereofii)

For a copy of an audio record

R 60,00

R 30,00(f)

To search for and prepare the record for disclosure, R30,00 for each hour or part ofanhour reasonably required for such search and preparation.

5. For purposes of section 54(2) of PAIA, the following applies:
5.1. Six hours as the hours to be exceeded before a deposit is payable; and5.2. one third of the access fee is payable as a deposit by the requester.
6. The actual postage is payable when a copy of a record must be posted to a requester.

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APPENDIX 5

Part 1PROCESSING OF PERSONAL INFORMATION IN ACCORDANCE WITH POPIA
Purpose of the Processing of Personal Information

Type of Processing

To provide services to the Client in accordance with terms agreed toCollection, recording,by the Client;organization,

To undertake activities related to the provision of legal services
including:

structuring, storage,
adaptation oralteration, retrieval,- deceased estates and trusts;- court proceedings or proceedings in other tribunals / forums;- property transfers;- registration of notarial deeds, mortgage bonds and other related
activities;- correspondences and attendances involved in debt recovery;- drafting and vetting commercial agreements, corporate documents
and other commercial documentation;

consultation, use,
disclosure bytransmission,
dissemination orotherwise making
available, alignment
or combination,
restriction, erasure

The purposes related to any authorised disclosure made in terms ofor destruction.

agreement, law or regulation
Any additional purposes expressly authorised by the Client or
relevant law; andAny additional purposes as may be notified to the Client or Data
Subjects in any notice provided by the Company

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Part 2Categories of Data Subjects and categories of Personal Information relating thereto
Categories of Data Subjects of andData Subject

Personal Information

categoriesof Personal Information

Processed

relating thereto
Cliento Corporate•Natural Persons;

Personal data relating to a

Client Profile information including,•Juristic Persons.

Data Subject received byaccount details, payment information,or

on behalf of thecorporate structure, other customer

Company from the Client,information including to the extent the

Client affiliates and theircategories of information nrelate torespective representatives

individuals or representatives of theand related parties whileclient (e.g., shareholders, directors etc.)

providingrequired for the above-mentioned

services to the Client or in

purposesconnection

accounts

and

with

a

transaction or services.
o Individual;

Client personal data may

Name; contact details, client details

include(HomeFacsimile Number, Home Postal

details, identification andAddress, Home Telephone Number,verification

Personal Cellular, Mobile Or Wirelessnationality and residency

Number, Personal E-Mail Address);

information,

regulatory identifiers;Accountnumbers, bank account to

information; credit information;

theownership of property (immovable andamount to personal data

movable); photographs; other

under POPIA

names,

extentcontact

information,
VAT
that

these

identification and verification data as
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contained in images of ID card, passportand other ID documents; images ofcustomer signatures.

Payment beneficiaries (payments to•Sheriff

Personal information

third parties)•Advocate

relating to accounts held

Bank account information; beneficiary•Correspondentat beneficiaries; name ofaddress; VAT numbers (if applicable).

Attorneysaccount and recipients of•Courier/ payment; may include

Messenger Kingother information related•Lodging Agentsto the Data Subject for•Municipality

purposes of affecting thenecessary payments

Personnel
Name; ID number and card/book;•Attorneys

Personal information to becontact details (telephone number;•Candidate

processed for purposes ofaddress); employment history;

Attorneys

employment; necessary tocredentials (academic transcript, degree•Secretaries

assess suitability tocertificate); tax number; marital status.

•Debt Collectors

position and to be•Otherstaff

support updated when necessary.
Personal Information will
include name, ID number
and documents, contact
details, address,
employment history andacademic credentials.

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Part 3
Recipients of Personal Information
The Company, its operators / third parties, Clients (where they are not Data Subjects and inrespect of their specific matter, without breach of confidentiality) and their respective
representatives.
Part 4
Description of information security measures
The Company undertakes to institute and maintain the data protection measures toaccomplish the following objectives outlined below. The details given are to be interpreted
as examples of how to achieve an adequate data protection level for each objective. The
Company may use alternative measures and adapt to technological security development,
as needed, provided that the objectives are achieved.
1. Access Control of Persons
The Company shall implement suitable measures in order to prevent unauthorized persons
from gaining access to the data processing equipment where the data are processed,
including the storage room, storage cabinets, client and personnel files and online
databases.
2. Data Media Control
The Company undertakes to implement suitable measures to prevent the unauthorized
manipulation of media, including reading, copying, alteration or removal of the data media
used by the Company and containing personal data of Clients.
3. Data Memory Control
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The Company undertakes to implement suitable measures to prevent unauthorized input
into data memory and the unauthorized reading, alteration or deletion of stored data.
4. User Control
The Company shall implement suitable measures to prevent its data processing systems
from being used by unauthorized persons by means of data transmission equipment.
5. Access Control to Data
The Company represents that the persons entitled to use the Company’s data processing
system are only able to access the data within the scope and to the extent covered by theirrespective access permissions (authorization).
6. Transmission Control
The Company shall be obliged to enable the verification and tracing of the locations /destinations to which the personal information is transferred by utilization of theCompany’s data communication equipment / devices.
7. Transport Control
The Company shall implement suitable measures to prevent Personal Information frombeing read, copied, altered, or deleted by unauthorized persons during the transmission
thereof or during the transport of the data media, including concluding the necessary
agreements and reasonable safety measures with couriers, Sheriffs and Messenger King.
8. Organisation Control
The Company shall maintain its internal organisation in a manner that meets therequirements of this Manual.
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APPENDIX 6OBJECTION TO THE PROCESSING OF PERSONAL INFORMATION IN TERMS OFSECTION 11(3) OF THE
PROTECTION OF PERSONAL INFORMATION ACT, 2013

REGULATIONS RELATING TO THE PROTECTION OF PERSONALINFORMATION, 2018
Note:
1
2
3

Affidavits or other documentary evidence as applicable in support of the objection
may be attached.
If the space provided for in this Form is inadequate, submit information as
an Annexure to this Formand sign each page.
Complete as is applicable.
A

DETAILS OF DATA SUBJECT

Name(s) and surname/ registered name of datasubject:
Unique Identifier/ Identity Number
Residential, postal or business address:
Contact number(s):Fax number / E-mail address:
B

DETAILS OF RESPONSIBLE PARTY

Name(s) and surname/ registered name of datasubject:
Residential, postal or business address:
Contact number(s):Fax number / E-mail address:C

REASONS FOR OBJECTION IN TERMS OF
SECTION 11(1)(d) to (f) (Please provide
detailed reasons for the objection)

Signed at .......................................... this ...................... day of ...........................20………...

............................................................
Signature of data subject/designated person
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APPENDIX 7

REQUEST FOR CORRECTION OR DELETION OF PERSONAL INFORMATION OR DESTROYING OR
DELETION OF RECORD OF PERSONAL INFORMATION IN TERMS OF SECTION 24(1) OF THE
PROTECTION OF PERSONAL INFORMATION ACT, 2013

REGULATIONS RELATING TO THE PROTECTION OF PERSONALINFORMATION, 2018
[Regulation 3]

Note:
1.

Affidavits or other documentary evidence as applicable in support of the request may
be attached.

2.

If the space provided for in this Form is inadequate, submit information as an
Annexure to this Form andsign each page.

3. Complete as is applicable.

Mark the appropriate box with an "x".
Request for:

Correction or deletion of the personal information about the data subject
which is inpossession or under the control of the responsible party.
Destroying or deletion of a record of personal information about thedata subject which isin possession or under the control of the
responsible party and who is no longer authorised to retain the recordof information.

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A

DETAILS OF DATA SUBJECT

Name(s) and surname/ registered name ofdatasubject:
Unique Identifier/ Identity Number
Residential, postal or business address:
Contact number(s):Fax number / E-mail address:
B

DETAILS OF RESPONSIBLE PARTY

Name(s) and surname/ registered name ofdatasubject:
Residential, postal or business address:
Contact number(s):Fax number / E-mail address:C

REASONS FOR OBJECTION IN TERMS OF
SECTION 11(1)(d) to (f) (Please provide
detailed reasons for the objection)D

REASONS FOR *CORRECTION OR
DELETION OF THE PERSONALINFORMATION ABOUT THE DATA SUBJECTIN TERMS OF SECTION 24(1)(a) WHICH IS
INPOSSESSION OR UNDER THE CONTROLOF THE RESPONSIBLE PARTY ; and or
REASONS FOR *DESTRUCTION OR
DELETION OF A RECORD OF PERSONALINFORMATION ABOUT THE DATA SUBJECTIN TERMS OF SECTION 24(1)(b) WHICH THE
RESPONSIBLE PARTY IS NO LONGER
AUTHORISED TO RETAIN. (Please provide
detailed reasons for the request)

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APPENDIX 8

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