1. List Of Acronyms and Abbreviations

“CEO”	Chief Executive Officer
“DIO”	Deputy Information Officer
“IO”	Information Officer
“Minister”	Minister of Justice and Correctional Services
“POPIA”	Protection of Personal Information Act No.4 of 2013
“Regulator”	Information Regulator
“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 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

• 3.1.Chief Information Officer

Name:
Tel:
Email:
Fax number:	N/A

• 3.2.Deputy Information Officer

(NB: if more than one Deputy Information Officer is designated, please provide the details of every Deputy Information Officer of the body designated in terms of section 17 (1) of PAIA.

Name:	N/A
Tel:	N/A
Email:	N/A
Fax number:	N/A

• 3.3.Access to information general contacts Email:

Email:

compliance@properfx.com

• 3.4.National or Head Office

Postal Address	Office 1215 The Leonardo 75 Maude Street Sandton Gauteng, Johannesburg, 2196, South Africa.
Physical Address	Office 1215 The Leonardo 75 Maude Street Sandton Gauteng, Johannesburg, 2196, South Africa.
Telephone:
Email:	compliance@properfx.com
Website:	https://www.properfx.com/

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 upon request.
• 4.2.1. The previously mentioned Guide contains the description of-the objects of PAIA and POPIA;
• 4.2.2. the postal and street address, phone and fax number and, if available, electronic mail address of-
• 4.2.2.1. the Information Officer of every public body, and
• 4.2.2.2. every Deputy Information Officer of every public and private body designated in terms of section 17(1) of PAIA1 and section 56 of POPIA2;
• 4.2.3. the manner and form of a request for-
• 4.2.3.1. access to a record of a public body contemplated in section 11(3); and
• 4.2.3.2. access to a record of a private body contemplated in section 50(4);
• 4.2.4. the assistance available from the IO of a public body in terms of PAIA and POPIA
• 4.2.5. the assistance available from the Regulator in terms of PAIA and POPIA;
• 4.2.6. 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-
• 4.2.6.1. an internal appeal;
• 4.2.6.2. a complaint to the Regulator; and
• 4.2.6.3. 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;
• 4.2.7. 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;
• 4.2.8. 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;
• 4.2.9. the notices issued in terms of sections 22(9) and 54(10) regarding fees to be paid in relation to requests for access; and
• 4.2.10. the regulations made in terms of section 92(11).
• 4.3. 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.
• 4.4. The Guide can also be obtained-
• 4.4.1. upon request to the Information Officer;
• 4.4.2. from the website of the Regulator (https://www.justice.gov.za/inforeg/).
• 4.5. A copy of the Guide is also available in the following official language, for public inspection during normal office hours-
• 4.5.1. English

5. Categories of Records of Properfx (PTY) Ltd Which Are Available Without a Person Having to Request Access

NB: Please specify the categories of records held by the body which are available without a person having to request access by completing Form C, types of the records and how the records can be accessed. These are mostly records that may be available on the website and a person may download or request telephonically or by sending an email or a letter.

Category of Records	Type of Records	Available on Website	Available upon request
Company Information	Terms & Conditions	X	X
Company Information	FAIS Disclosure Document	X	X
Company Information	Risk Disclosure	X	X
Company Information	PAIA Manual	X	X
Company Information	Complaints Notice	X	X
Company Information	Conflict of Interest Policy	X	X

;

6. Description of the Records of ProperFX (PTY) Ltd Which are Available in Accordance with any other Legislation

NB: Please specify all the records which are created and available in accordance with any of the South African legislation. Below is an example of the table that can be used in describing the records and applicable legislation.

Category of Records	Applicable Legislation
Memorandum of Incorporation	Companies Act 71 of 2008
PAIA Manual	Promotion of Access to Information Act 2 of 2000
Terms & Conditions	Financial Advisory and Intermediary Services Act 37 of 2002
FAIS Disclosure Document	Financial Advisory and Intermediary Services Act 37 of 2002
Risk Disclosure	Financial Advisory and Intermediary Services Act 37 of 2002
Complaints Notice	Financial Advisory and Intermediary Services Act 37 of 2002
Conflict of Interest Policy	Financial Advisory and Intermediary Services Act 37 of 2002

7. Processing Of Personal Information

• 7.1. Purpose of Processing Personal Information
• 7.2.1. Identity Verification
• 7.2.2.Geographical location verification
• 7.3. 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	Postal and/or street address, Title and name, Contact numbers and/or e-mail address, Ethnic group, Employment history, Age, Gender, Marital status, Nationality, Language, Financial information, Identity or passport number
Service Providers	Names, registration number, VAT numbers, address, trade secrets and bank details
Employees	Employment history and references, Employee number, Banking and financial details, Details of payments to third parties (deductions from salary), Employment contracts, Employment equity plan, Medical aid records, Pension fund records, Remuneration/salary records, Performance appraisals, Disciplinary records, Leave records, Training records, Qualifications

• 7.4. 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
Names, Identity documents/number, transaction data and any other requested information	Financial Intelligence Centre
Identity documents/number and names, for criminal checks, any other requested information	South African Police Services
Qualifications, for qualification verifications, any other requested information	South African Qualifications Authority
Credit and payment history, for credit information, any other requested information	Credit Bureaus

• Any firm, organisation or person that the ProperFX uses to collect payments and recover debts or to provide a service on its behalf;
• Any firm, organisation or person that/who provides the ProperFX with products or services;
• Any person who the has reason to believe to be a data subject’s/consumer’s parent, carer or helper where he/she is unable to handle his/her own affairs because of mental incapacity or other similar issues;
• Any payment system the ProperFX uses;
• Regulatory and governmental authorities or ombudsmen, or other authorities, including tax authorities, where the ProperFX has a duty to information;
• Credit bureau;
• Third parties to whom payments are made on behalf of employees;
• Financial institutions from whom payments are received on behalf of data subjects;
• Any other operator not specified;
• Employees, contractors and temporary staff; and
• Agents
• General description of Information Security Measures to be implemented by the responsible party to ensure the confidentiality, integrity and availability of the information
• Data Encryption; Anti-virus and Anti-malware Solutions.

8. Availability of the Manual

• 8.1. A copy of the Manual is available on
• 8.1.1. www.properfx.com
• 8.1.2. head office of ProperFX (Pty) Ltd for public inspection during normal business hours;
• 8.1.3. to any person upon request and upon the payment of a reasonable prescribed fee; and
• 8.1.4. to the Information Regulator upon request.
• 8.2. 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.

9. Updating of the Manual

The Information Officer will update this manual regularly.

10. References

• 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 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.
• 4 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
• 9 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.