Privacy Policy PAIA

Manual Of

Glow Innovations CC (Private Body)

Prepared and compiled on 2022-01-17 in accordance with Section 51 of
the Promotion of Access to Information Act, No 2 of 2000 (as amended)
in respect of Glow Innovations CC.

Registration number:
2001/022823/23

Update:
2022-01-17

Table of Contents

1. INTRODUCTION

2. THE ACT

3. PURPOSE OF THE MANUAL

4. CONTACT DETAILS

5. GUIDE ON HOW TO USE PAIA AND HOW TO OBTAIN ACCESS TO THE GUIDE

6. RECORDS AUTOMATICALLY AVAILABLE TO THE PUBLIC

7. RECORDS OF THE PRIVATE BODY

8. RECORDS REQUIRED IN TERMS OF LEGISLATION

9. PROCESSING OF PERSONAL INFORMATION

10. REQUEST PROCEDURE FOR OBTAINING INFORMATION

11. FEES

12. GROUNDS FOR REFUSAL OF ACCESS TO INFORMATION

13. DECISION

1. INTRODUCTION

Glow Innovations CC conducts business as a Steel Manufacturing
Specialist with a focus on Pedestrian & Driveway Gates. We have an
electronics division which install and service gate automation and
electric fencing. We are an industry expert, ready to assist any client
in our areas of service.

2. THE ACT

The Promotion of Access to Information Act, No 2 of 2000 (“The Act”)
was enacted on

3 February 2000, giving effect to the right of access to any
information held by Government, as well as any information held by
another person who is required for the exercising or protection of any
rights. This right is entrenched in the Bill of Rights in the
Constitution of South Africa. Where a request is made in terms of The
Act, the body to which the request is made is not obliged to release
the information, except where The Act expressly provides that the
information may or must be released. The Act sets out the requisite
procedural issues attached to such request.

3. PURPOSE OF THE MANUAL

In order to promote effective governance of private bodies, it is
necessary to ensure that everyone is empowered and educated to
understand their rights in terms of The Act in order for them to
exercise their rights in relation to public and private bodies.

Section 9 of The Act, however, recognizes that such right to access to
information cannot be unlimited and should be subject to justifiable
limitations, including, but not limited to:

• Limitations aimed at the reasonable protection of privacy;
• Commercial confidentiality; and
• Effective, efficient and good governance

And in a manner that balances that right with any other rights,
including such rights contained in the Bill of Rights in the
Constitution.

Wherever reference is made to “Private Body” in this manual, it will
refer to Glow Innovations CC.

This PAIA Manual assist you to-

3.1 check the categories of records held by Glow Innovations CC which
are available without a person having to submit a formal PAIA request;

3.2 have a sufficient understanding of how to make a request for access
to a record of Glow Innovations CC, by providing a description of the
subjects on which Glow Innovations CC holds records and the categories
of records held on each subject;

3.3 know the description of the records of Glow Innovations CC which
are available in accordance with any other legislation;

3.4 access all the relevant contact details of the Information Officer
and Deputy Information Officer who will assist you with the records you
intend to access;

3.5 know the description of the guide on how to use PAIA, as updated by
the Regulator and how to obtain access to it;

3.6 know if Glow Innovations CC will process 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;

3.7 know the description of the categories of data subjects and of the
information or categories of information relating thereto;

3.8 know the recipients or categories of recipients to whom the
personal information may be supplied;

3.9 know if Glow Innovations CC 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

3.10 know whether Glow Innovations CC has appropriate security measures
to ensure the confidentiality, integrity and availability of the
personal information which is to be processed.

4. CONTACT DETAILS:

Information Officer: Daniel Enticott

Postal Address:

Units 2 – 4

7 Greenville Terrace Road Diep River

Cape Town 7800

Physical Address:

Units 2 – 4

7 Greenville Terrace Road Diep River

Cape Town 7800

Telephone No:

021 706 0733

E-mail: info@glowinn.co.za

Deputy Information Officer: Oshana Cook, Sharon Tockley

GENERAL INFORMATION:

Name of Private Body: Glow Innovations CC

Registration No: 2001/022823/23

Postal Address:

Units 2 – 4

7 Greenville Terrace Road Diep River

Cape Town

7800

Physical Address (or principal place of business):

Units 2 – 4

7 Greenville Terrace Road Diep River

Cape Town 7800

Telephone No:

021 706 0733

E-mail:

info@glowinn.co.za

Website:

www.glowinn.co.za

5. GUIDE ON HOW TO USE PAIA AND HOW TO OBTAIN ACCESS TO THE GUIDE

5.1. The Regulator has, in terms of section 10(1) of PAIA, as amended,
updated and made available the revised Guide on how to use PAIA
(“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.

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

5.3. The aforesaid Guide contains the description of-

5.3.1. the objects of PAIA and POPIA;

5.3.2. the postal and street address, phone and fax number and, if
available, electronic mail address of-

5.3.2.1 the Information Officer of every public body, and

5.3.2.2 every Deputy Information Officer of every public and private
body designated in terms of section 17(1) of PAIA and section 56 of
POPIA;

5.3.3 the manner and form of a request for-

5.3.3.1 access to a record of a public body contemplated in section 11
of PAIA; and

5.3.3.2 access to a record of a private body contemplated in section 50
of PAIA;

5.3.4 the assistance available from the IO of a public body in terms of
PAIA and POPIA;

5.3.5 the assistance available from the Regulator in terms of PAIA and
POPIA;

5.3.6 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-

5.3.6.1 an internal appeal;

5.3.6.2 a complaint to the Regulator; and

5.3.6.3 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;

5.3.7 the provisions of sections 14 and 51 of PAIA requiring a public
body and private body, respectively, to compile a manual, and how to
obtain access to a manual;

5.3.8 the provisions of sections 15 and 52 of PAIA providing for the
voluntary disclosure of categories of records by a public body and
private body, respectively;

5.3.9 the notices issued in terms of sections 22 and 54 of PAIA
regarding fees to be paid in relation to requests for access; and

5.3.10 the regulations made in terms of section 92 of PAIA.

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

5.5 The Guide can also be obtained-

5.5.1 upon request to the Information Officer;

5.5.2 from the website of the Regulator (

https://www.justice.gov.za/inforeg/

).

5.6 A copy of the Guide is also available in two official languages,
for public inspection during normal office hours.

6. RECORDS AUTOMATICALLY AVAILABLE TO THE PUBLIC

7. RECORDS OF THE PRIVATE BODY

This clause serves as a reference to the records that the Private Body holds in order to facilitate a request in
terms of The Act.

The information is classified and grouped according to records relating
to the following subject and categories: It is recorded that the
accessibility of the documents listed herein below, may be subject to
the grounds of refusal set out hereinafter.

8. RECORDS REQUIRED IN TERMS OF LEGISLATION

Records are kept in accordance with legislation applicable to Glow
Innovations CC, which includes but is not limited to, the following –

Basic Conditions of Employment Act 75 of 1997

Broad-Based Black Economic Empowerment Act 53 of 2003 Close
Corporations Act 69 of 1984

Companies Act 61 of 1973

Compensation for Occupational Injuries and Health Diseases Act 130 of
1993

Consumer Protection Act 68 of 2008

Electronic Communications and Transactions Act 25 of 2002 Electronic
Communications Act, 36 of 2005

Employment Equity Act 55 of 1998

Financial Advisory and Intermediary Services Act 37 of 2002 Financial
Intelligence Centre Act 38 of 2001

Income Tax Act 58 of 1962

Labour Relations Act 66 of 1995 Occupational Health & Safety Act 85
of 1993

Protection of Personal Information Act 4 of 2013 Promotion of Access to
Information Act 2 of 2000 Skills Development Act 97 of 1998

Skills Development Levies Act 9 of 1999 Unemployment Contributions Act
4 of 2002

Unemployment Insurance Act 30 of 1966 Value Added Tax Act 89 of 1991

Such other legislation as may from time to time be applicable

Reference to the above-mentioned legislation shall include subsequent
amendments and secondary legislation to such legislation.

Reference to the above-mentioned legislation shall include subsequent
amendments and secondary legislation to such legislation.

9. PROCESSING OF PERSONAL INFORMATION

9.1
Purpose of Processing Personal Information

We only process personal information for:

• Staff Records

• Client Profiles

• Job Specific Documentation Completion

9.2

Description of the categories of Data Subjects and of the
information or categories of information relating thereto

9.3

The recipients or categories of recipients to whom the personal
information may be supplied

SEO Company:

Our SEO Cape Town, BrandSeed, a leading SEO company, only has anonymously aggregated data as per Google measurement platforms. Their SEO services only rank the website and are not individually related to any user.

9.4
Planned transborder flows of personal information

We transfer information to the following web servers:

• Amazon Web Servers

• Microsoft Web Servers

• Dear Systems Web Servers

The following categories of information is transferred outside the
borders of South Africa:

• Client contact details secured on the cloud

• Supplier contact details secured on the cloud

9.5

General description of Information Security Measures to be
implemented by the responsible party to ensure the confidentiality,
integrity and availability of the information

• Locked Offices (Restricted Access)

• Locked Filing Cabinets (Restricted Access)

• Password protected computers

• Encrypted cloud storage

10. REQUEST PROCEDURE FOR OBTAINING INFORMATION

Access to records held by the PRIVATE BODY

Records held by the Private Body may be accessed by
request only once the prerequisites for access have been met.

The requester must fulfil the prerequisites for access in terms of The Act, including the payment of a requested access
fee.

The requester must comply with all the procedural requirements
contained in The Act

relating to the request for access to a record.

The requester must complete the prescribed Form and submit same as well
as payment of a request fee and a deposit, if applicable, to the
Information Officer at the postal or physical address, fax number or
electronic mail address as stated herein.

The prescribed form must be filled in with enough particulars to at
least enable the Information Officer to identify –

• The record or records requested;
• The identity of the requester,
• Which form of access is required, if the request is granted;
• The postal address or fax number or email address of the requester.

The requester must state that he/she requires the information in order
to exercise or protect a right, and clearly state what the nature of
the right to be exercised or protected is. In addition, the requester
must clearly specify why the record is necessary to exercise or protect
such a right.

The Private Body will process the request within 30
days, unless the requester has stated a special reason that would
satisfy the Information Officer that circumstances dictate that the
above time periods are not complied with.

The requester shall be informed whether access has been granted or
denied. If, in addition, the requester requires the reason for the
decision in any other manner, he / she must state the manner and the
particulars so required.

If a request is made on behalf of another person, then the requester
must submit proof of the capacity in which the requesters making the
request, to the reasonable satisfaction of the Information Officer.

If an individual is unable to complete the prescribed form because of
illiteracy or disability, such a person may make the request orally.

The requester must pay the prescribed fee before any further processing
can take place.

11. FEES

When the Information Officer receives the request, such Officer shall
by notice require the requester to pay the prescribed request fee (if
any), before any further processing of the request.

If the search for the record has been made in the preparation of the
record for disclosure, including arrangements to make it available in
the requested form, and it requires more than the hours prescribed in
the regulation for this purpose, the Information Officer shall notify
the requester to pay as a deposit the prescribed portion of the access
fee which would be payable if the request is granted.

The Information Officer shall withhold a record until the requester has
paid the Fees as indicated.

A requester, whose request for access to a record has been granted,
must pay an access fee for reproduction and for search and preparation,
and for any time reasonably required in excess of the prescribed hours
to search for and prepare the record for disclosure, including making
arrangements to make it available in the requested form.

If a deposit has been paid in respect of a request for access, which is
refused, then the Information Officer concerned must repay the deposit
to the requester.

12. GROUNDS FOR REFUSAL OF ACCESS TO INFORMATION

The main grounds for the Private Body to refuse a
request for information relates to the:

Mandatory protection of the privacy of a third party that is a natural
person that would involve the unreasonable disclosure of personal
information of that natural person;

Mandatory protection of the commercial information of a third party, if
the record contains:

– Trade secrets of that third party;

– Financial, commercial, scientific or technical information,
disclosure of which could likely cause harm to the financial or
commercial interests of that third party;

– Information disclosed in confidence by a third party to the Private
Body, if the disclosure could put that third party at a disadvantage in
negotiations or commercial competition

Mandatory protection of confidential information of third parties if it
is protected in terms of any agreement;

Mandatory protection of confidential information of the protection of
property; Mandatory protection of records that would be regarded as
privileged in legal proceedings;

The commercial activities of the Private Body, which
may include:

• Trade secrets of the Private Body;
• Financial, commercial, scientific or technical information,
  disclosure which could likely cause harm to the financial or
  commercial interest of the Private Body;
• Information which, if disclosed could put the Private Body at a disadvantage in negotiations or
  commercial competition;
• A computer program, owned by the Private Body, and
  protected by copyright.

The research information of the Private Body or a
third party, if its disclosure would reveal the identity or the Private Body, the researcher or the subject matter of
the research and would place the research at a serious disadvantage;

Requests for information that are clearly frivolous or vexatious, or
which would involve an unreasonable diversion of resources shall be
refused.

13. DECISION

The Private Body will within 30 days of receipt of the
request, decide whether to grant or decline the request and give notice
with reasons (if required) to that effect.

The 30 day period within which the Private Body has to
decide whether to grant or refuse the request, may be extended for
further period of not more than thirty days if the request is for a
large amount of information, or the request requires a search for
information held at another office of the Private Body and the information cannot reasonably be
obtained within the original 30 day period. The Private Body will notify the requester in writing
should an extension be sought.

AVAILABILITY OF THE MANUAL

The manual of the Private Body is available at the
premises of the Private body as well as on the website of the Private Body.