Manuel PAIA

1. List of Acronyms and Abbreviations

1. 1.1 “CEO” means the Chief Executive Officer of STOICFX (PTY) LTD;
2. 1.2 “DIO” means the Deputy Information Officer of STOICFX (PTY) LTD;
3. 1.3 “IO” means the Information Officer of STOICFX (PTY) LTD;
4. 1.4 “Minister” means Minister of Justice and Correctional Services of the République d'Afrique du Sud;
5. 1.5 “PAIA” means the Promotion of Access to Information Act No. 2 of 2000 (as Amended);
6. 1.6 “POPIA” means the Protection of Personal Information Act No. 4 of 2013;
7. 1.7 “Regulator” means the Information Regulator; and
8. 1.8 “Republic” means the République d'Afrique du Sud.

2. Purpose of The PAIA Manual

1. 2.1 This PAIA Manual serves as a valuable resource for the public, offering crucial information regarding the records held by our organization. It provides the following key benefits:
   1. Transparency of Available Records: The Manual identifies the records that are automatically available to the public without the need to submit a formal request under the Promotion of Access to Information Act (“PAIA”). This enables individuals to quickly ascertain what information is readily available;
   2. Guidance on Requesting Access: The Manual offers comprehensive instructions on how to submit a request for access to records. This includes a detailed description of the subjects on which the body holds records, as well as the specific categories of records related to each subject;
   3. Legislative Compliance: The Manual details the records that are accessible in accordance with other applicable legislation, thereby ensuring transparency and compliance with regulatory requirements;
   4. Coordonnées: It includes all relevant contact details for the Information Officer and Deputy Information Officer, who are designated to assist the public in accessing the records they seek. This facilitates direct communication for any inquiries or assistance needed;
   5. Guide to Using PAIA: The Manual provides a description of the guide issued by the Regulator, which explains how to effectively utilize PAIA. It also outlines how individuals can obtain access to this guide;
   6. Personal Information Processing: The Manual clarifies whether the body processes personal information, detailing the purpose of such processing as well as a description of the categories of data subjects involved and the specific types of information processed;
   7. Categories of Data Subjects: It elaborates on the various categories of data subjects and the associated information or categories of information that the body holds;
   8. Information Recipients: The Manual specifies the recipients or categories of recipients to whom personal information may be disclosed, ensuring that individuals are informed about potential third-party access to their information;
   9. International Data Transfers: It addresses whether the body has plans to transfer or process personal information outside the République d'Afrique du Sud, along with details about the recipients or categories of recipients who may receive this information; and
   10. Security Measures: Finally, the Manual outlines the security measures in place to protect the confidentiality, integrity, and availability of personal information that is processed. This reassures individuals that appropriate safeguards are established to protect their data.
2. 2.2 By providing this comprehensive overview, the PAIA Manual enhances public awareness and understanding of their rights to access information, thereby promoting transparency and accountability within our organization.
3. 2.3 If you have any questions or require further assistance regarding the information contained in this manual, please do not hesitate to reach out. Your engagement is vital to fostering an open and informed relationship with our body.

3. Key Contact Details for Access to Information of STOICFX (PTY) LTD

1. 3.1 Chief Information Officer

   Name: Zachary Estes

   Tel: 0311002202 (VoIP)

   Email: [email protected]

2. 3.2 Deputy Information Officer

   Name: Michael Talento

   Tel: 7607050423

   Email: [email protected]

3. 3.3 Access to Information – General Contacts

   Email: [email protected]

4. National or Head Office

5. Guide on How to Use PAIA and How to Obtain Access to the Guide

1. 5.1 The Regulator has, in accordance with section 10(1) of the Promotion of Access to Information Act (“PAIA”), as amended, revised and made accessible the updated Guide on how to utilize PAIA (hereinafter referred to as the “Guide”). This Guide is presented in a clear and easily comprehensible format, tailored to meet the needs of individuals seeking to exercise their rights under both the PAIA and the Protection of Personal Information Act (“POPIA”).

   The revisions aim to ensure that all users, regardless of their familiarity with legal terminology, can readily understand the procedures and rights afforded to them. This proactive approach reflects the Regulator's'commitment to promoting transparency and empowering individuals to access information in a manner that is both efficient and user-friendly.

   If you require further details or assistance in navigating the Guide, please do not hesitate to contact us. We are here to support you in exercising your rights effectively.

2. 5.2 The aforementioned Guide includes a comprehensive description of the following key elements –
   1. Objectives of PAIA and POPIA: A clear articulation of the aims and purposes of both the Promotion of Access to Information Act (“PAIA”) and the Protection of Personal Information Act (“POPIA”);
   2. Coordonnées: The Guide provides the postal and street addresses, telephone and fax numbers, and, where available, the electronic mail addresses of:
      1. the Information Officer of every public body, and
      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;

         ¹ 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.

         ² 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. Request Procedures: Detailed instructions on the manner and form required to request:
      1. access to a record of a public body as outlined in section 11; and
      2. access to a record of a private body as specified in section 50;

         ³ Section 50(1) of PAIA – A requester must be given access to any record of a private body if –

         1. that record is required for the exercise or protection of any rights;
         2. that person complies with the procedural requirements in PAIA relating to a request for access to that record; and
         3. access to that record is not refused in terms of any ground for refusal contemplated in Chapter 4 of this Part.
   4. Assistance from Information Officers: Information regarding the assistance available from the Information Officer of a public body in relation to both PAIA and POPIA;
   5. Support from the Regulator: Guidance on the assistance available from the Regulator under both PAIA and POPIA;
   6. Legal Remedies: A comprehensive overview of the legal remedies available for addressing any act or failure to act concerning rights or duties conferred by PAIA and POPIA. This includes instructions on how to lodge the following:
      1. an internal appeal;
      2. a complaint to the Regulator; and
      3. an application to a court;
   7. Regulatory Provisions: The regulations established under section 92.
3. 5.3 Members of the public are welcome to inspect or request copies of the Guide at the offices of public and private bodies, as well as at the office of the Regulator, during normal working hours.
4. 5.4 The Guide can also be obtained –
   1. upon request to the Information Officer;
   2. from the website of the Regulator https://www.justice.gov.za/inforeg/
5. 5.5 Additionally, a copy of the Guide is available for public inspection in two official languages – English and Afrikaans – during normal office hours, ensuring accessibility for a diverse range of individuals.

6. Categories of Records of STOICFX (PTY) LTD Which Are Available Without a Person Having to Request Access

7. Description of the Legislation Applicable to STOICFX (PTY) LTD

8. Description of the Subjects on Which the Body Holds Records and Categories of Records Held on Each Subject by STOICFX (PTY) LTD

9. Processing of Personal Information

1. 9.1 Purpose of Processing Personal Information

   The primary purpose of processing personal information is to comply with regulatory requirements and uphold the integrity of financial transactions. This involves verifying client identities, assessing eligibility and suitability, and actively monitoring for potential fraud. Additionally, processing personal information is essential for managing and mitigating risks related to financial transactions, ensuring adherence to anti-money laundering (AML) and know your customer (KYC) regulations. Ultimately, this process reinforces the security and trustworthiness of the financial services provided, fostering a safer environment for all stakeholders.

2. 9.2 Description of the Categories of Data Subjects and of the Information or Categories of Information relating thereto:

   Categories of Data Subjects	Personal Information That May Be Processed
   Customers / Clients	name, address, registration numbers or identity numbers, employment status and bank details
   Service Providers	names, registration number, VAT numbers, address, trade secrets and bank details
   Employees	address, qualifications, gender and race

3. 9.3 The recipients or categories of recipients to whom the personal information may be supplied:

   Category of Personal Information	Recipients or Categories of Recipients to Whom the Personal Information May Be Supplied
   Identity number and names, for criminal checks	South African Police Services
   Qualifications, for qualification verifications	South African Qualifications Authority
   Credit and payment history, for credit information	Credit Bureaus

4. 9.4 General Description of Information Security Measures to be Implemented by the Responsible Party to Ensure the Confidentiality, Integrity, and Availability of the Information
   1. Data Encryption;
   2. Anti-virus; and
   3. Anti-malware Solutions.

10. Availability of the Manual

A copy of the Manual is available in the following locations:

1. On stoicfx.com;
2. At the head office of STOICFX (PTY) LTD for public inspection during normal business hours;
3. To any person upon request and upon the payment of a reasonable prescribed fee; and
4. To the Information Regulator upon request.

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.

11. Updating and Modifications of the Manual

The Compliance Department of STOICFX (PTY) LTD is responsible for updating and amending this Manual as required. This Manual will be reviewed annually and updated to reflect any changes in legislation, organizational structure, or records management practices.