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:

Wanderers Office Park, BDO Building, 52 Corlett Drive, Illovo, 2196

Telephone: (011) 258-1000
Email: compliance@rci.com
Website:  RCI.co.za

(Kindly note: This address is for administrative purposes only. Walk-in services are no longer available.)

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

Copyright Act, Nr. 98 of 1978

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

 

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

 ___________________________________________________



Section 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. 

Section 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. 

Section 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.

7 Section 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

Section 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.

10 Section 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.”