POLICY

PROMOTION OF ACCESS TO INFORMATION

PAIA Policy

PURPOSE

The purpose of this policy is to make sure Truzo adheres to the Promotion of Access to Information (PAIA) Act, 2000. The PAIA Act gives effect to section 32 of the Constitution, which provides that everyone has the right to access information held by the State or any other person (or private body), when that information is required for the exercise or protection of any rights.

The purpose of PAIA is to:

foster a culture of transparency and accountability in public and private bodies by giving effect to the right of access to information, and to
actively promote a society in which the people of South Africa have effective access to information to enable them to more fully exercise and protect all of their rights.

Truzo recognises everyone’s right to access information and is committed to provide access to Truzo’s records where the proper procedural requirements as set out by PAIA and Protection of Personal Information (POPI) have been met. Truzo’s PAIA policy is compiled in accordance with section 51 of the Act and contains the following provisions:

Annexure A : Contact Details & Business Type

This section provides Truzo’s postal and street address, phone and the e-mail address.

Annexure B : Section 10 PAIA Guide

This section provides a description of the guide referred to in Section 10 of PAIA and how you may obtain access to it.

Annexure C : Statutory Records

This section provides a description of the various statutes in terms of which Truzo is required to maintain records.

Annexure D : Availability of Records

This section provides a list of records held by Truzo along with an indication of whether the record is freely available or only accessible by way of a formal request in terms of the provisions of PAIA. The section also provides a description of the category of data subject(s) to who the respective records relates along with an indication of the purpose for which the record is being kept. Records that are indicated as “Freely Available” can be accessed by contacting the Information Officer (see Annexure A), without having to follow any formal procedures. Records that are indicated as a “PAIA Request”, requires the requester to lodge a formal request as provided for in Annexure E.

Annexure E : Request Procedure

This section sets out the procedure required to obtain access to a record indicated as a “PAIA Request” in Annexure D.

Annexure F : Prescribed Fees

This section sets out the fees that are payable to Truzo prior to processing a request to obtain access to a record held by Truzo.

Annexure G : Processing of Personal Information

This section sets out the applicable aspects for the processing of personal information.

DUTIES OF THE INFORMATION OFFICER

The Information Officer of Truzo is responsible for:

Publishing and proper communication of the policy i.e. creating awareness of the request for information process;
The facilitation of any request for access to Truzo information;
Providing adequate notice and feedback to the requester;
Determining whether to grant a request for access to a complete/full record or only part of a record;
Ensuring that access to a record, where so granted, is provided timeously and in the correct format;
Reviewing the policy for accuracy and communicating any amendments.

Right of Access

The Information Officer may only provide access to any record held by Truzo to a requester if:

The record is required for the exercise or protection of any right, and
The requester complies with the procedural requirements relating to a request for access to that record, and
Access to that record is not refused in terms of any of the grounds for refusal listed below.

Grounds for Refusal

The Information Officer must assess whether there are any grounds for refusing a request for access. Where any grounds for refusal are found, a request for access will not be granted. Where there are no grounds for refusal, request for access will be granted.

However, despite finding any grounds for refusal, access to the record(s) will be provided where:

the disclosure of the record would reveal evidence of a substantial contravention of, or failure to comply with the law or imminent and serious public or environmental risk, and
the public interest in disclosing record, will clearly outweigh the harm contemplated in the provision in question.

If a request for access to a record has been refused, but parts of the record can be divorced from the original record without compromising any rights once the information is made available, this must be done.

The grounds for refusal, or absence thereof, are set out below:

A: Mandatory Protection of privacy of a Third Party who is a Natural Person

Grounds for Refusal:

· The disclosure would involve the unreasonable disclosure of personal information about a third party that is a natural person (including a deceased individual).

No Grounds for Refusal:

The record consists of information that concerns an individual who has already consented in writing to its disclosure to the requester concerned.
The record consists of information that is already publicly available.
The record consists of information that was given to Truzo by the individual to whom it relates and the individual was informed by or on behalf of Truzo, before it is given, that the information belongs to a class of information that would or might be made available to the public.
The record consists of information about an individual’s physical or mental health, or well-being, who is under the care of the requester and who is under the age of 18; or incapable of understanding the nature of the request, and if giving access would be in the individual’s best interest.
The record consists of information about an individual who is deceased and the requester is the individual’s next of kin or making written consent of the individual’s next of kin.
The record consists of information about an individual who is or was an official of Truzo and which relates to the position or functions of the individual, including, but not limited to the title, work address, work phone number, the classification, salary scale or remuneration and responsibilities of the position held or services performed by the individual and the name of the individual on a record prepared by the individual in the course of employment.

B: Mandatory Protection of Commercial Information of a Third Party

Grounds for Refusal

The record consists of information that contains trade secrets of a third party.
The record consists of information that contains financial, commercial, scientific or technical information, other than trade secrets, of a third party, the disclosure of which would be likely to cause harm to the commercial or financial interests of that third party.
The record consists of information supplied in confidence by a third party, the disclosure of which could reasonably be expected to put that third party at a disadvantage in contractual or other negotiations or to prejudice that third party in commercial competition.

No Grounds for Refusal

The record consists of information about a third party who has consented in writing to its disclosure to the requester concerned.
The record consists of information about the results of any product or environmental testing or other investigation supplied by a third party or the results of any such testing or investigation carried out by or on behalf of a third party and its disclosure would reveal a serious public safety or environmental risk (the results of any product or environmental testing or other investigation do not include the results of preliminary testing or other investigation conducted for the purpose of developing methods of testing or other investigation).

C: Mandatory Protection of certain Confidential Information of a Third Party

Grounds for Refusal

The record consists of information the disclosure of which would constitute an action for breach of a duty of confidence owed to a third party in terms of an agreement.

D: Mandatory Protection of Safety of Individuals and Protection of Property

Grounds for Refusal

The record consists of information that if disclosed could reasonably be expected to endanger the life or physical safety of an individual.
The record consists of information that if disclosed would likely prejudice or impair the security of a building, a structure or system, a computer or communication system, a means of transport, any other property.
The record consists of information that if disclosed would likely prejudice or impair the security of methods, systems, plans or procedures for the protection of an individual in accordance with a witness protection scheme, the safety of the public, or any part of the public, or the security of property.

E: Mandatory Protection of Records privileged from Production in Legal Proceedings

Grounds for Refusal

The record consists of information privileged from production in legal proceedings unless the person entitled to the privilege has waived the privilege

F: Commercial Information of Truzo

Grounds for Refusal

The record consists of information that contains trade secrets of Truzo.
The record consists of information that contains financial, commercial, scientific or technical information, other than trade secrets, of Truzo, the disclosure of which would likely cause harm to the commercial or financial interests of Truzo.
The record consists of information, the disclosure of which, could reasonably be expected to put Truzo at a disadvantage in contractual or other negotiations or prejudice Truzo in commercial competition.
The record is a computer program as defined in section 1(1) of the Copyright Act (Act 98 of 1978), owned by Truzo, except insofar as it is required to give access to a record to which access is granted in terms of PAIA.

No Grounds for Refusal

The record consists of information about the results of any product or environmental testing or other investigation supplied by Truzo or the results of any such testing or investigation carried out by or on behalf of Truzo and its disclosure would reveal a serious public safety or environmental risk (the results of any product or environmental testing or other investigation do not include the results of preliminary testing or other investigation conducted for the purpose of developing methods of testing or other investigation).

G: Mandatory Protection of Research Information of a Third Party and Truzo

Grounds for Refusal

The record consists of information that contains information about research being or to be carried out by or on behalf of a third party, the disclosure of which would be likely to expose the third party, a person that is or will be carrying out the research on behalf of the third party, or the subject matter of the research to serious disadvantage.
The record consists of information that contains information about research being or to be carried out by or on behalf of Truzo, the disclosure of which would be likely to expose Truzo, a person that is or will be carrying out the research on behalf of Truzo, or the subject matter of the research to serious disadvantage.

NOTICE

Where a request for access has been received (Annexure E) the Information Officer will notify the requester of receipt and the prescribed fee (if any) that is payable prior to processing the request. Please refer to Annexure F for a full breakdown of fees payable. Personal requesters (data subject) will not be charged a request fee.

The notice must state:

The amount of the deposit payable (if any).
That the requester may lodge a complaint with the Information Regulator or an application with a court against the tender or payment of the request fee, or the tender or payment of a deposit, as the case may be.
The procedure (including the period) for lodging the complaint with the Information Regulator or the application.

Except to the extent that the provisions regarding third party notification may apply, the Information Officer to whom the request is made, must as soon as reasonably possible, but in any event within 30 days, after the request has been received in the prescribed format:

Decide in accordance with PAIA whether to grant the request, and
Notify the requester of the decision and, if the requester stated that he or she wishes to be informed of the decision in any other manner, inform him or her in that manner, if it is reasonably possible.

If the request for access is granted, the notice must state:

The access fee (if any) to be paid upon access;
The form in which access will be given; and
That the requester may lodge a complaint with the Information Regulator or an application with a court against the access fee to be paid or the form of access granted, and the procedure, including the period allowed, for lodging a complaint with the Information Regulator or the application.

If the request for access is refused, the notice must:

State adequate reasons for the refusal, including the relevant provision of PAIA that was relied on;
Exclude, from any such reasons, any reference to the content of the records’; and
State that the requester may lodge a complaint with the Information Regulator or an application with a court against the refusal of the request, and the procedure (including the period) for lodging a complaint with the Information Regulator or the application.

Truzo holds limited information about our clients. Anything out of the scope of these limitations cannot be considered. Should all reasonable steps have been taken to find a record requested, and there are reasonable grounds for believing that the record:

Is in Truzo’s possession, but cannot be found, or
Simply does not exist,

the CEO will, by way of affidavit or affirmation, notify the requester that it is not possible to provide access to that record. The affidavit or affirmation must provide full account of all steps taken to find the record in question or to determine whether the record exists, as the case may be, including all communication with every person who conducted the search on behalf of the CEO.

WHEN AND HOW DO WE COLLECT PERSONAL INFORMATION?

A copy of the PAIA Policy is available:

on truzo.com;
head office of Truzo for public inspection during normal business hours;
to any person upon request and upon the payment of a reasonable prescribed fee (see Annexure F); and
to the Information Regulator upon request.
a fee for a copy of the Policy, as contemplated in annexure B of the Regulations, shall be payable per each A4-size photocopy made.

DEFINITIONS

CEO	In relation to a private body means: in the case of a juristic person: the chief executive officer or equivalent officer of the juristic person or any person duly authorised by that officer; or the person who is acting as such or any person duly authorised by such acting person.
Data Subject	The person to whom personal information relates.
Information Officer	The person appointed to act on behalf of Truzo.
Information Regulator	The Regulator established in terms of Section 39 of POPI.
PAIA	The Promotion of Access to Information Act 2 of 2000
Person	A natural person or a juristic person
Personal Information	Information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, including, but not limited to: information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of the person; Information relating to the education or the medical, financial, criminal or employment history of the person; Any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier or other particular assignment to the person, the biometric information of the person; The personal opinions, views or preferences of the person; correspondence sent by the person that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence; The views or opinions of another individual about the person; and the name of the person if it appears with other personal information relating to the person or if the disclosure of the name itself would reveal information about the person.
Personal Requester	A requester seeking access to a record containing personal information about the requester.
POPI	The Promotion of Personal Information Act 4 of 2013.
Private body	a natural person who carries or has carried on any trade, business or profession, but only in such capacity a partnership which carries or has carried on any trade, business or profession; or any former or existing juristic person, but excludes a public body.
Processing	Any operation or activity or any set of operations, whether or not by automatic means, concerning personal information, including the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use, dissemination by means of transmission, distribution or making available in any other form, or merging, linking, as well as restriction, degradation, erasure or destruction of information.
Public body	any department of state or administration in the national or provincial sphere of government or any municipality in the local sphere of government; or in any other functionary or institution when: exercising a power or performing a duty in terms of the Constitution or a provincial constitution; or exercising a public power or performing a public function in terms of any legislation
Requester	In relation to a private body, means any person, including, but not limited to public body or an official thereof, making a request for access to a record of Truzo or a person acting on behalf of such person.
Request for access	A request for access to a record of Truzo in terms of section 50 of PAIA.
Record	Any recorded information regardless of the form or medium, in the possession or under the control of Truzo irrespective of whether or not it was created by Truzo.
Third Party	In relation to a request for access to a record held by Truzo, means any person other than the requester.

ANNEXURE A – CONTACT DETAILS & BUSINESS TYPE

A. Organisation Contact Details
Postal address:	Postnet suite 225, Private Bag X87, Bryanston, 2021
Street address:	2nd Floor, One-on Jameson Building, 1 Jameson Avenue, Melrose Estate, 2198
Phone number:	011 486-0692 / 0847
Email address:	info@truzo.com
B. CEO of Organisation
Full names & surname:		Vinodhan Naidu (Terence)
Email address:		info@truzo.com
Phone number:		011 486-0692 / 0847
C. Information Officer
Full names & surname		Andrei Migatchev
Email address:		info@truzo.com
Phone number:		011 486-0692 / 0847
D. Business Type
Truzo provides escrow services to the following sector(s):
Agriculture			×
Mining and Quarrying			×
Manufacturing			×
Electricity, Gas & Water			×
Construction			×
Retail & Motor Trade and Repair Services			×
Wholesale Trade, Commercial Agents & Allied Services			×
Catering, Accommodation & Other Trade			×
Community, Special & Personal Services			×
Finance & Business Services			×

ANNEXURE B – SECTION 10 PAIA GUIDE

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.

The Guide is available in each of the official languages and in braille. Please visit the website for further information on this: https://www.inforegulator.org.za/docs.html#docs

The aforesaid Guide contains the description of-

the objects of PAIA and POPIA;
the postal and street address, phone and fax number and, if available, electronic mail address of-
- The Information Officer of every public body, and
- every Information Officer of every public and private body designated in terms of section 17(1) of PAIA and section 56 of POPIA ;

the manner and form of a request for-
- access to a record of a public body contemplated in section 11; and
- access to a record of a private body contemplated in section 50;

the assistance available from the IO of a public body in terms of PAIA and POPIA;
the assistance available from the Regulator in terms of PAIA and POPIA;
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-
- an internal appeal;
- a complaint to the Regulator; and
- 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;

the provisions of sections 14 and 51 requiring a public body and private body, respectively, to compile a policy, and how to obtain access to a policy;
the provisions of sections 15 and 52 providing for the voluntary disclosure of categories of records by a public body and private body, respectively;
the notices issued in terms of sections 22 and 54 regarding fees to be paid in relation to requests for access; and
the regulations made in terms of section 92.

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.

The Guide can also be obtained-

upon request to the Information Officer;
from the website of the Regulator (https://www.justice.gov.za/inforeg/ ).

PAIA grants a requester access to records of a private body, if the record is required for the exercise or protection of any rights. Where a public body lodges a request, the public body must be acting in the public interest.

Requests in terms of PAIA shall be made in accordance with the prescribed procedures at the rates provided.

ANNEXURE C: STATUTORY RECORDS

Truzo maintains statutory records and information in terms of the following legislation:

Arbitration Act	×
Auditing Professions Act	×
Basic Conditions of Employment Act	×
Collective Investment Schemes Control Act	×
Companies Act	×
Compensation of Occupational Injuries & Diseases Act	×
Consumer Protection Act	×
Copyright Act	×
Electronic Communications and Transactions Act	×
Employment Equity Act	×
Financial Advisory & Intermediary Services Act	×
Financial Institutions (Protection of Funds) Act	×
Financial Intelligence Centre Act	×
Income Tax Act	×
Insolvency Act	×
Labour Relations Act	×
Long-term Insurance Act	×
Occupational Health and Safety Act	×
Prevention of Organised Crime Act	×
Prevention and Combatting of Corrupt Activities Act	×
Promotion of Equality and Prevention of Unfair Discrimination Act	×
Protection of Constitutional Democracy against Terrorist and related Activities Act	×
Skills Development Act	×
Trademarks Act	×
Unemployment Insurance Act	×
Value Added Tax Act	×

ANNEXURE D: AVAILABILITY OF RECORDS

Truzo maintains the following categories of records and related subject matter. The status of the record’s availability, the purpose for its processing and the relevant data subject category to who the record relates are set out below:

Category:	Record:	Availability:	Purpose:	Data Subject:
Public Affairs	Public Product Information	Freely Available	Convey Public Information	Truzo
	Public Corporate Records	Freely Available	Convey Public Information	Truzo
	Media Releases	Freely Available	Convey Public Information	Truzo
	Published Newsletters	Freely Available	Convey Public Information	Truzo
	Magazine Articles	Freely Available	Convey Public Information	Truzo
Regulatory & Administrative	Permits, Licenses or Authorities	Freely Available	Statutory Requirement	Truzo
	Conflict of Interest Management Policy	Freely Available	Statutory Requirement	Truzo
	Complaints Policy	Freely Available	Statutory Requirement	Truzo
	FICA Internal Rules	PAIA Request	Statutory Requirement	Truzo
	Health & Safety Plan	PAIA Request	Statutory Requirement	Truzo
	Memorandum of Incorporation	PAIA Request	Statutory Requirement	Truzo
	Minutes of Board or Directors Meetings	PAIA Request	Statutory Requirement	Truzo
	Register of Board of Directors	PAIA Request	Statutory Requirement	Truzo
	Internal correspondence (e-mails/memos)	PAIA Request	Internal Communications	Employees
	Insurance Policies held by organisation	PAIA Request	Risk Management	Truzo
Human Resources	Employment Applications	PAIA Request	Internal Referencing	Employees
	Employment Contracts	PAIA Request	Contractual Agreement	Employees
	Personal Information of Employees	PAIA Request	Internal Referencing	Employees
	Disciplinary Records	PAIA Request	Statutory Requirement	Employees
	Performance Management Records	PAIA Request	Internal Referencing	Employees
	Salary Records	PAIA Request	Internal Referencing	Employees
	Employee Benefit Records	PAIA Request	Internal Referencing	Employees
	PAYE Records	PAIA Request	Statutory Requirement	Employees
	Disciplinary Code	PAIA Request	Statutory Requirement	Truzo
	Leave Records	PAIA Request	Internal Referencing	Employees
	Training Records	PAIA Request	Internal Referencing	Employees
	Training Manual	PAIA Request	Internal Referencing	Truzo
Financial	Financial Statements	PAIA Request	Internal Referencing	Truzo
	Financial and Tax Records	PAIA Request	Statutory Requirement	Truzo
	Asset Register	PAIA Request	Internal Referencing	Truzo
	Management Accounts and Reports	PAIA Request	Internal Referencing	Truzo
	Vouchers, Cash Books and Ledgers	PAIA Request	Internal Referencing	Truzo
	Banking Records and Statements	PAIA Request	Internal Referencing	Truzo
	Electronic Banking Records	PAIA Request	Internal Referencing	Truzo
Marketing	Market Information	PAIA Request	Internal Referencing	Truzo
	Product Brochures	PAIA Request	Internal Referencing	Truzo
	Advertisements	PAIA Request	Internal Referencing	Truzo
	Field Records	PAIA Request	Internal Referencing	Truzo
	Performance Records	PAIA Request	Internal Referencing	Truzo
	Product / Service Sales Records	PAIA Request	Internal Referencing	Truzo
	Marketing Strategies	PAIA Request	Internal Referencing	Truzo
Client Customer	Customer / Client Database	PAIA Request	Internal Referencing	Customers
	Customer / Client agreements	PAIA Request	Internal Referencing	Customers
	Customer / Client Files	PAIA Request	Internal Referencing	Customers
	Customer / Client Instructions	PAIA Request	Internal Communications	Customers
	Customer / Client Correspondence	PAIA Request	External Communications	Customers
Third Party	Rental agreements	PAIA Request	Contractual Agreement	Third Party
	Integration agreements	PAIA Request	Contractual Agreement	Third Party
	Non-disclosure agreements	PAIA Request	Risk Management	Third Party
	Letters of Intent	PAIA Request	Contractual Agreement	Third Party
	Supplier Contracts	PAIA Request	Contractual Agreement	Third Party

ANNEXURE E: REQUEST PROCEDURE

To facilitate the processing of your request, kindly complete and submit the form below to the e-mail address of the Information Officer indicated in Annexure A.

The Information Officer will notify the requester that a request for access has been received and that the prescribed fee (if any) is payable prior to processing the request. Please refer to Annexure F for a full breakdown of fees payable. Personal requesters will not be charged a request fee.

Once the request has been processed, the Information Officer will inform you of the outcome of your request and any additional fees that may fall due.

Please be advised that PAIA provides a number of grounds on which a request for access to information must be refused. These grounds mainly comprise instances where:

the privacy and interests of other individuals are protected;
where such records are already otherwise publicly available;
instances where public interest are not served;
the mandatory protection of commercial information of a third party; and
the mandatory protection of certain confidential information of a third party.

When completing the form below please:

indicate the identity of the person seeking access to the information;
provide sufficient particulars to enable the deputy information officer to identify the information requested;
specify the format in which the information is required;
indicate the contact details of the person requiring the information;
indicate the right to be exercised and/or to be protected, and specify the reasons why the information required will enable the person to protect and/or exercise the right;
where the person requesting the information wishes to be informed of the decision of the request in a particular manner, state the manner and particulars to be so informed; and
if the request for information is made on behalf of another person, submit proof that the person submitting the request, has obtained the necessary authorisation to do so.

REQUEST FORM

A. Particulars of Private Body
CEO:



B. Particulars of person requesting access to the record
(i) The particulars of the person who requests access to the record must be recorded below.
(ii) Furnish an address and/or fax number in the Republic to which information must be sent.
(iii) Proof of the capacity in which the request is made, if applicable, must be attached.
Full names & surname:
Identity number:
Postal address:
Fax number:
Telephone number:
Email address:
Capacity:
C. Particulars of person on whose behalf request is made
This section must be completed ONLY if a request for information is made on behalf of another person
Full names & surname:
Identity number:
D. Particulars of Record
(i) Provide full particulars of the record to which access is requested, including the reference number if that is known to you.
(ii) If the provided space is inadequate, please continue on a separate page and attach to this form. Please sign any additional pages.
Description of record:



Reference number:
Any further particulars:

E. Fees
(i) A request for access to a record, other than a record containing personal information about yourself, will be processed only after a request fee has been paid.
(ii) You will be notified of the amount required to be paid as the request fee.
(iii) The fee payable for access to a record depends on the form in which access is required and the reasonable time required to search for and prepare a record.
(iv) If you qualify for exemption of the payment of any fee, please state the reason.
Reason for exemption:


F. Form of access to record Financial Statements
If you are prevented by a disability to read, view or listen to the record in the form of access provided hereunder, please state your disability and indicate in which form the record is required.
Disability:


Form in which required:

Mark the appropriate box with an “X”
(i) Your indication as to the required form of access depends on the form in which the record is available.
(ii) Access in the form requested may be refused in certain circumstances. In such a case you will be informed of access will be granted in another form.
(iii) The fee payable for access to the record, if any, will be determined partly by the form in which access is requested.
1) If the record is in written or printed form:
copy of record
inspection of record
2) If record consists of visual images:
view the images
copy of the images
transcription of the images
3) If the record consists of recorded words or information which can be reproduced in sound:
listen to the soundtrack
transcription of the soundtrack
4) If the record is held on computer or in an electronic or machine-readable form:
printed copy of record

Please indicate the preferred method of delivery
By hand
Email
Post
Fax
G. Particulars of right to be exercised or protected
If the provided space is inadequate, please continue on a separate sheet and attach it to this form. The requester must sign all additional sheets.
Indicate which right is to be exercised or protected:




Explain why the record requested is required for the exercise or protection of the aforementioned right:




H. Notice of decision regarding the request for access
You will be notified in writing whether your request has been approved / denied. If you wish to be informed thereof in another manner, please specify the manner and provide the necessary particulars to enable compliance with your request.
How would you prefer to be informed of the decision regarding your request for access to the record?


I. Signature page
Signed at:
Date:
Signature of Requester / Person on whose behalf request is made:

ANNEXURE F: PRESCRIBED FEES

The following applies to requests (other than personal requests):

A requester is required to pay a preliminary request fee before a request will be processed.
If the preparation of the record requested requires more than the prescribed hours (six), an additional deposit shall be paid (of not more than one third of the access fee which would be payable if the request was granted).
A requestor may lodge an application with a court against the render / payment of the request fee and/or deposit.

Records may be withheld until the fees have been paid.

No.	Description	Fee
1.	The request fee payable by every requester	R140.00
2.	Photocopy/printed black & white copy of A4-size page	R2.00
3.	Printed copy of an A4 size page	R2.00
4.	For a copy in a computer-readable form on:
	i. Flash drive (to be provided by requester)	R40.00
	ii. Compact disc:
	– If provided by requestor	R40.00
	– If provided to the requestor	R60.00
5.	For a transcription of visual images per A4-size page	Service to be outsourced. Will depend on quotation from Service provider.
6.	Copy of visual images
7.	Transcription of an audio record, per A4-size page	R24.00
8.	Copy of an audio record on:
	i. Flash drive (to be provided by requester)	R40.00
	ii. Compact disc:
	– If provided by requestor	R40.00
	– If provided to the requestor	R60.00
9.	To search for and prepare the record for disclosure for each hour or part of an hour, excluding the first hour, reasonably required for such search and preparation. To not exceed a total cost of	R145.00 R435.00
10.	Deposit: If search exceeds 6 hours	One third of amount per request ito items 2-8.
11.	Postage, e-mail or any other electronic transfer	Actual expense, if any.

ANNEXURE G: PROCESSING OF PERSONAL INFORMATION

Purpose of Processing Personal Information

A good service provider, typically registered with the financial authority in the region within which they operate, conducts a full and comprehensive compliance check (Know Your Client – KYC, anti-money laundering, sanctions list and more) on a client before setting up an escrow account for that client. This is standard practice and ensures the integrity of the service provider’s client base. Parties involved in an escrow account are the buyer, the seller, the agent (if there is one) and the service provider. All parties to the transaction are verified for this purpose to ensure that they are known to Truzo.

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, bank details, Company CIPC information, and if necessary, Source of Wealth and/or Source of Funds
Service Providers	names, registration number, vat numbers, address, trade secrets and bank details
Employees	address, qualifications, gender and race

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, banking details and sanction screening	Verification through 3^rd party bureau
Identity number and names, for criminal checks	South African Police Services
Qualifications, for qualification verifications	South African Qualifications Authority

Planned transborder flows of personal information

Data privacy is a human right. That is why Truzo is committed to the privacy and confidentiality of information provided to us in compliance with all relevant legislation, including the Protection of Personal Information Act, 2013 (“POPI”) and General Data Protection Regulation (GDPR) (EU) 2016/679. We will never sell or use your information for anything other than communications about the Truzo platform and to perform verifications checks for compliance.

Client information is stored in the cloud outside the Republic of South Africa, in Ireland. As per point 3 above, the category of personal information stored includes, identity numbers, names, banking details, sanction screening and qualification checks in respect of employees.

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

All our systems are hosted by Amazon Web Services (AWS) and all information handled by us is encrypted using the latest technologies, protected by and processed in accordance with PCI Security Standards Council (PCI DSS) and ISO27001 standards. This means that client information cannot be traced, intercepted or used by unauthorised third parties.

All infrastructure devices that are used to provide this service are properly maintained, patched and assessed for any vulnerability or outdated components. Truzo uses appropriate physical and software measure, including but not limited to firewalls, anti-malware and intrusion detection and prevention software, to ensure continued and uninterrupted service.

ANNEXURE H: INFORMATION OFFICER APPOINTMENT

In terms of the Protection of Personal Information Act the head of a private body is the designated Information Officer for that private body. However, by way of resolution, the CEO of Truzo has appointed an Information Officer.

The Information Officer will facilitate any requests to access records held by Truzo. This delegation does not prohibit the person who made the delegation from exercising power concerned or performing the duty concerned himself. The delegation may at any time be withdrawn or amended in writing by the person who made the delegation.

The Information Officer need not have any specific qualifications but must have a thorough knowledge of Truzo’s functional departments and business processes. The Information Officer has the authority to approach all staff members of Truzo and to request all records held by Truzo. Where a manager is of the opinion that access to a record should not be granted to the Information Officer, reasons for this decision shall be given to the CEO who will make a final decision on the matter.

The Information Officer is responsible for:

Publishing and proper communication of the policy i.e. creating policy awareness;
The facilitation of any request for access;
Providing adequate notice and feedback to the requester;
Determining whether to grant a request for access to a complete/full record or only part of a record;
Ensuring that access to a record, where so granted, is provided timeously and in the correct format; and
Reviewing the policy for accuracy and communicating any amendments.