RCI

PAIA - Promotion of Access to Information Act

Registration Number of Company: 1990/005818/07

VACATION EXCHANGES INTERNATIONAL (PROPRIETARY) LTD (Operating as RCI South Africa)

PAIA MANUAL

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

DATE OF COMPILATION: 01/10/2021

DATE OF REVISION: 28/12/2021

TABLE OF CONTENTS

1. ACRONYMS AND ABBREVIATIONS

2. PURPOSE OF THE PAIA MANUAL

3. CONTACT DETAILS FOR ACCESS TO INFORMATION

4. THE PAIA GUIDE

5. CATEGORIES OF RECORDS WITHOUT HAVING TO REQUEST ACCESS

6. RECORDS AVAILABLE IN ACCORDANCE WITH LEGISLATION

7. RECORDS HELD ON DATA SUBJECTS

8. POCESSING OF PERSONAL INFORMATION

9. AVAILABILITY OF MANUAL

10. UPDATING THE MANUAL

1. LIST OF ACRONYMS AND ABBREVIATIONS

1.1 “CEO” Chief Executive Officer

1.2 “DIO” Deputy Information Officer;

1.3 “IO“ Information Officer;

1.4 “Minister” Minister of Justice and Correctional Services;

1.5 “PAIA” Promotion of Access to Information Act No. 2 of 2000(as Amended;

1.6 “POPIA” Protection of Personal Information Act No.4 of 2013;

1.7 “Regulator” Information Regulator; and

1.8 “Republic” Republic of South Africa

2. PURPOSE OF PAIA MANUAL

This PAIA Manual is useful for the public to-

2.1 check the categories of records held by a body which are available without a person having to submit a formal PAIA request;

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

2.3 know the description of the records of the body which are available in accordance with any other legislation;

2.4 access all the relevant contact details of the Information Officer and Deputy Information Officer who will assist the public with the records they intend to access;

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

2.6 know if the body 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;

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

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

2.9 know if the body 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

2.10 know whether the body has appropriate security measures to ensure the confidentiality, integrity and availability of the personal information which is to be processed.

3. KEY CONTACT DETAILS FOR ACCESS TO INFORMATION OF RCI SOUTH AFRICA

3.1. Chief Information Officer

Name:	Mrs Alyson Benjamin
Tel:	(011) 258-1000
Email:	compliance@rci.com

3.2. Deputy Information Officers

Name:	Mrs Leanne Bruwer
Tel:	(011) 258-1000
Email:	compliance@rci.com

Name:	Ms Sonnika Otto
Tel:	(011) 258-1000
Email:	compliance@rci.com

3.3. Access to information general contacts

Email:

compliance@rci.com

3.4 National or Head Office

Postal Address:	P.O. Box 783940 Sandton, 2146
Physical Address:	RCI, The Core, Corner Leeuwkop & Kikuyu Roads, Sunninghill, 2157, Johannesburg
Telephone:	(011) 258-1000
Email:	compliance@rci.com
Website:	RCI.co.za

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

4.1. 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.

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

4.3. The aforesaid Guide contains the description of-

4.3.1. the objects of PAIA and POPIA;

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

4.3.2.1. the Information Officer of every public body, and

4.3.2.2. every Deputy Information Officer of every public and private body designated in terms of section 17(1) of PAIA[1] and section 56 of POPIA[2];

4.3.3. the manner and form of a request for-

4.3.3.1. access to a record of a public body contemplated in section 11[3]; and

4.3.3.2. access to a record of a private body contemplated in section 50[4];

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

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

4.3.6. 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-

4.3.6.1. an internal appeal;

4.3.6.2. a complaint to the Regulator; and

4.3.6.3. 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;

4.3.7. the provisions of sections 14[5] and 51[6] requiring a public body and private body, respectively, to compile a manual, and how to obtain access to a manual;

4.3.8. the provisions of sections 15[7] and 52[8] providing for the voluntary disclosure of categories of records by a public body and private body, respectively;

4.3.9. the notices issued in terms of sections 22[9] and 54[10] regarding fees to be paid in relation to requests for access; and

4.3.10. the regulations made in terms of section 92[11].

4.4. 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.

4.5. The Guide can also be obtained-

4.5.1. upon request to the Information Officer;

4.5.2. from the website of the Regulator (https://www.justice.gov.za/inforeg/).

4.6 A copy of the Guide is also available in English, for public inspection during normal office hours at our office. When a copy in another official language is made available by the South African Human Rights Commission, we will also provide a non-English copy.

5. CATEGORIES OF RECORDS OF RCI SOUTH AFRICA WHICH ARE AVAILABLE WITHOUT A PERSON HAVING TO REQUEST ACCESS

This section of the PAIA Manual sets out the categories and descriptions of records held by RCI South Africa. Some of these records are not automatically available without a request in terms of PAIA. The inclusion of any category of records should not be taken to mean that records falling within that category will be made available under PAIA. In particular, certain grounds of refusal as set out in PAIA may be applicable to a request for such records.

Category of records	Type of records	Available on website	Availability may be requested
Public Affairs	Public Product Information Public Corporate Records Media Releases	x
Finance	Financial records Annual reports Strategic Plans Budgets		x
Human Resources	Policies and Procedures Compliance Records Employee Records Recruitment Information (CV’s & checks)		x
Operations	Member Records		x
Compliance	Contracts Compliance Records Operational Records Policies and Procedures		x
Information Technology	Contracts Policies and Procedures Insurance Records License Records Project Records Reports Product Development Records		x
Business Development	Contracts Operational Records Annual reports		x
Marketing	Member Database Marketing Strategies Sales records Customer referrals		x
Marketing	Public product information	x

6. DESCRIPTION OF THE RECORDS OF RCI SOUTH AFRICA WHICH ARE AVAILABLE IN ACCORDANCE WITH ANY OTHER LEGISLATION

Pension Funds Act, Nr. 24 of 1956

Income Tax Act, Nr. 58 of 1962 (Section 75)

Companies Act, Nr. 61 of 1973

Value Added Tax Act, Nr. 89 of 1991 (Section 65)

Occupational Health and Safety Act, Nr. 85 of 1993

Compensation for Occupational Injuries and Diseases Act, Nr. 130 of 1993 (Section 97)

Labour Relations Act, Nr. 66 of 1995

Basic Conditions of Employment Act, Nr. 75 of 1997 (Section 31)

Employment Equity Act, Nr. 55 of 1998 (Section 26)

Skills Development Act, Nr. 97 of 1998

Medical Schemes Act, Nr. 131 of 1998

Skills Development Levies Act, Nr. 9 of 1999

Unemployment Insurance Act, Nr. 63 of 2001

7. DESCRIPTION OF THE SUBJECTS ON WHICH THE BODY HOLDS RECORDS AND CATEGORIES OF RECORDS HELD ON EACH SUBJECT BY RCI SOUTH AFRICA

	Record Category
Business Development	Affiliation Agreements, Marketing Records, Rental Agreements
Compliance	Compliance Records, Contracts, Operational Records, Policies and Procedures
Finance	Annual Reports, Budgets, Financial Records, Strategic Plans
Human Resources	Compliance Records, Employee Records, Information (CV’s and recruitment checks), Policies and Procedures, Recruitment
Information Technology	Contracts, Licenses, Policies, Product Development, Projects, Reports
Marketing	Customer Referrals, Marketing Strategies, Member Database, Public Product Information, Sales Records
Operations	Member Records

8. PROCESSING OF PERSONAL INFORMATION

8.1 Purpose of Processing Personal Information

1. We may process personal information in connection with any of the following:

1.1. Our business transactions with you, including, but not limited to:

(i) Entering into or performing a contract with you.

(ii) Responding to your inquiries and fulfilling your requests.

(iii) Sending administrative information to you, for example, information regarding the services or an event you are attending.

(iv) Completing and fulfilling any purchases or requests for services.

1.2. For our legitimate business interests, including, but not limited to:

(i) Personalising your experience on the services by presenting products and offers tailored to you.

(ii) Allowing you to participate in sweepstakes, contests, and similar promotions, and administering such activities (each of which may have additional rules and could contain additional information about how we Process your Personal Information).

(iii) Facilitating social sharing functionalities of your social media account(s).

(iv) Carrying out data analysis, audits, fraud monitoring and prevention, internal quality assurance, developing new products, enhancing, improving or modifying our services, identifying usage trends, auditing use and functionality of our services, helping enforce compliance with our Terms of Use (found on our website), helping protect our services, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.

(v) Subject to your marketing preferences (which may include consent to marketing under applicable law), to send you newsletters or marketing communications we believe may interest you, for our own products and services, and on behalf of our related companies or selected third parties in accordance with applicable law.

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

Data Subject	Personal Information that is processed
Affiliate (Club and Resort)	Address Company Registration Numbers Name VAT Registration Numbers
Employee	Engagement Stage: Educational Qualifications Email Address Cell Phone Number Criminal, Qualification and Credit Checks Curriculum Vitae Identity Document Interview Questionnaires Rest of Employment: Bank Account Number Biometrics Cell Phone Number Contract of Employment Disciplinary Records Doctor's Notes Email Address Employee Code Employee Personnel File Leave Records Medical Aid Details Next Of Kin Contact Information Payslips Performance Records Residential Address Tax Number Termination Form
Service Provider / Supplier	Address Bank Details Email Address Identity Number Language Name Ownership Spouse Contact Numbers
Customer	Address Bank Detail Name
Member	Address Bank Details Email Address Identity / Passport Number Language Ownership Spouse Contact Numbers

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

Category of Personal Information	Recipients whom the Personal Information may be supplied to
Booking Information	Affiliates\Clubs
Payment Details	Bank or such other financial institution we work with
Member Personal Information	The affiliated resort / club
Employee Identity number and name	3rd party service provider assisting with recruitment checks for new hires

8.4 Planned transborder flows of personal information

International Transfers: We are an international company and we may, subject to applicable law, transfer your information, to our related companies or selected third parties outside the country where you are located and where information protection standards may differ (e.g. your information may be stored on servers located in other jurisdictions such as the United States of America and the United Kingdom)and your information will be transferred to your holiday destinations to facilitate your booking). We will utilize appropriate safeguards governing the transfer and usage of your Personal Information.

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

We implement various security safeguards, such as (a) encryption on certain personal information, (b) firewalls, (c) intrusion detection system on our network, (d) antivirus software, and (e) vulnerability scans. We also make use of segregation of duties so that personnel only accesses certain areas of information required for their work.

9. AVAILABILITY OF THE MANUAL

9.1 A copy of the Manual is available-

9.1.1 on RCI.co.za and m.RCI.co.za, if any;

9.1.2 head office of RCI South Africa for public inspection during normal business hours;

9.1.3 to any person upon request and upon the payment of a reasonable prescribed fee; and

9.1.4 to the Information Regulator upon request.

9.2 A fee for a copy of the Manual, as contemplated in annexure B of the Regulations, shall be payable per each A4-size photocopy made.

10. UPDATING OF THE MANUAL

The head of RCI South Africa will on a regular basis update this manual.

Issued by

Alyson Benjamin

Director, RCI South Africa

~~___________________________________________________~~

¹Section 17(1) of PAIA- For the purposes of PAIA, each public body must, subject to legislation governing the employment of personnel of the public body concerned, designate such number of persons as deputy information officers as are necessary to render the public body as accessible as reasonably possible for requesters of its records.

²Section 56(a) of POPIA- Each public and private body must make provision, in the manner prescribed in section 17 of the Promotion of Access to Information Act, with the necessary changes, for the designation of such a number of persons, if any, as deputy information officers as is necessary to perform the duties and responsibilities as set out in section 55(1) of POPIA.

³ Section 11(1) of PAIA- A requester must be given access to a record of a public body if that requester complies with all the procedural requirements in PAIA relating to a request for access to that record; and access to that record is not refused in terms of any ground for refusal contemplated in Chapter 4 of this Part.

⁴Section 50(1) of PAIA- A requester must be given access to any record of a private body if-

a) that record is required for the exercise or protection of any rights;

b) that person complies with the procedural requirements in PAIA relating to a request for access to that record; and

c) access to that record is not refused in terms of any ground for refusal contemplated in Chapter 4 of this Part.

⁵ Section 14(1) of PAIA- The information officer of a public body must, in at least three official languages, make available a manual containing information listed in paragraph 4 above.

⁶ Section 51(1) of PAIA- The head of a private body must make available a manual containing the description of the information listed in paragraph 4 above.

⁷Section 15(1) of PAIA- The information officer of a public body, must make available in the prescribed manner a description of the categories of records of the public body that are automatically available without a person having to request access

⁸ Section 52(1) of PAIA- The head of a private body may, on a voluntary basis, make available in the prescribed manner a description of the categories of records of the private body that are automatically available without a person having to request access

⁹Section 22(1) of PAIA- The information officer of a public body to whom a request for access is made, must by notice require the requester to pay the prescribed request fee (if any), before further processing the request.

¹⁰Section 54(1) of PAIA- The head of a private body to whom a request for access is made must by notice require the requester to pay the prescribed request fee (if any), before further processing the request.

¹¹ Section 92(1) of PAIA provides that –“The Minister may, by notice in the Gazette, make regulations regarding-

(a) any matter which is required or permitted by this Act to be prescribed;

(b) any matter relating to the fees contemplated in sections 22 and 54;

(c) any notice required by this Act;

(d) uniform criteria to be applied by the information officer of a public body when deciding which categories of records are to be made available in terms of section 15; and

(e) any administrative or procedural matter necessary to give effect to the provisions of this Act.”