Promotion of Access To Information Manual

ROTH EDUCATIONAL SERVICES (PTY) LTD

T/A

PARKLANDS COLLEGE

(1998/025221/07)

PROMOTION OF ACCESS TO 

INFORMATION ACT MANUAL

(PAIA MANUAL)

Prepared in terms of section 51 of the Promotion of Access

to Information Act 2 of 2000 (as amended)

Version 2.0 January 2022

Table of Contents

Preamble 3

1. List of Acronyms and Abbreviations 3

2. The Purpose of the Manual 4

3. Key Contact Details for Access to Information of Parklands College 5

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

5. Categories of Records that are available without having to formally request access 8

6. Records available in terms of any other legislation 8

7. Description of the subjects on which Parklands College holds records and the categories held on each subject 9

8. Processing of Personal Information 10

9. Availability of the Manual 13

10. Request procedure in terms of the Act 13

11. Updating of the Manual 13

ANNEXURE A (Form 2) 14

Preamble

Christopher Robin has succeeded in providing exceptional pre-primary education, since its inception in 1980. It was with pride that we took our vast experience into formal education in 1998, with the opening of Parklands College, offering private education to learners from 12 months through to Grade 12 and beyond.

This manual has been compiled in accordance with the requirements of the Promotion of Access to Information Act, No.2 of 2000 (“the Act”). Parklands College is a private body as defined in the Act, and this manual contains the information which applies to such a private body. 

The manual will be updated regularly in accordance with the requirements of the Act.

1. List of Acronyms and Abbreviations

In this manual, the following words bear the meaning set out below:

“Parklands College” Roth Educational Services (Proprietary) Limited;
“Client” A natural or juristic person who or which receives services from Parklands College;
“Employee” Any person who works for or provides services to or on behalf of Parklands College, and receives or is entitled to receive remuneration;
“Requestor” Any person or entity requesting access to a record that is under the control of Parklands College;
“CEO” Chief Executive Officer/Managing Director;
“DIO” Deputy Information Officer;
“IO” Information Officer;
“Minister” Minister of Justice and Correctional Services;
“PAIA” Promotion of Access to Information Act No. 2 of 2000 (as Amended);
“POPIA” Protection of Personal Information Act No.4 of 2013;
“Regulator” Information Regulator;
“Republic” Republic of South Africa; and
“The Manual” This manual which is published in accordance with section 51 of the Act and “this manual” shall have the same meaning.

2. The Purpose of the Manual

This PAIA Manual is useful for the public to – 

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

2.2 Have sufficient understanding of how to request access to a record of the body, by describing 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 the body will process personal information, the purpose of the processing of personal information and the description of the categories of data subjects and the information or categories of information relating thereto;

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

2.8 Know the recipients or categories of recipient’s 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 Parklands College

3.1 Information Officer  
     
  Name: Richard Knaggs
  Tel: (021) 5212700
  Email: privacy@parklands.co.za
     
3.2 Deputy Information Officer(s)  
     
  Financial Manager: Jane Clews
  Secondary Principal: Sylvia Steyn
  Preparatory Principal: Lee-ann Steynberg
  Pre-Primary Principal: Riette Peterse
  Head: Parklands College Further Education: C Lamb
     
3.3 Access to information general contact  
     
  Email: privacy@parklands.co.za
     
3.4 Head Office Parklands College
     
  Postal Address: P.O. Box 11546, Bloubergrant 7443
     
  Physical Address: 91 Raats Drive, Parklands, 7441
     
  Telephone: (021) 521 2710;
    (021) 521 2700;
    (021) 521 2800; and
    (021) 522 6700
     
  CEO / Managing Director HL Roth

 

 

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

The Information Regulator has updated the guide in order to assist accessing information held by a public or private body.  The guide is available in each of the official languages on the Information Regulator’s website: www.justice.gov.za/inforeg/docs/

5. Categories of Records that are available without having to formally request access

Certain records are available without needing to be requested in terms of the request procedures set out in the Act and detailed in Section 9 of this manual. This information may be inspected, collected, purchased or copied at the prescribed fee reproduction) at the offices of Parklands College. Certain information is also available on the Parklands College website http://www.parklands.co.za and electronically upon request. These records include:

General Public

  • Marketing brochures
  • Prospectus/yearbook
  • College fee structure
  • Parklands College public social media platforms e.g. FaceBook, Twitter, YouTube

Parklands College Community (Parents, learners, students and staff)

  • Parklands College staff and parents have secure access to their records through our online school administration systems, edadmin.parklands.co.za and the Edana Parent/Staff App.
  • Parklands College learners have access to College learning information through our internal learning delivery systems e.g. Google Classroom.

6. Records available in terms of any other legislation

Certain records held by Parklands College are available in terms of legislation other than the Act. The specific records, which are available in terms of such legislation, are set out therein and these records may in certain instances only be accessed by the persons specified in the relevant legislation. 

The legislation is as follows:

  • Basic Conditions of Employment Act, No. 75 of 1997;
  • Companies Act, No.71 of 2008;
  • Compensation for Occupational Injuries and Diseases Act, No. 130 of 1993;
  • Employment Equity Act, No. 55 of 1998;
  • Income Tax Act, No.58 of 1962;
  • Labour Relations Act, No.66 of 1995;
  • Medical Schemes Act, No.131 of 1998;
  • Occupational Health and Safety Act, No.85 of 1993;
  • Pensions Fund Act, Act No. 24 of 1956;
  • Skills Development Act, No.97 of 1998;
  • Skills Development Levies Act, No.9 of 1999;
  • Unemployment Insurance Act, No.63 of 2001;
  • Unemployment Insurance Contributions Act, No.4 of 2002;
  • Valued Added Tax Act, No.89 of 1991
  • South African Schools Act of 1996
  • Unemployment Insurance Act No.30 of 1966
  • Further Education and Training Colleges Act 16 of 2006
  • Higher Education Act 101 of 1997
  • Promotion of Access to Information Act No 2 of 2000;
  • Protection of Personal Information Act No 4 of 2013

7. Description of the subjects on which Parklands College holds records and the categories held on each subject

The following is a list of records and the categories into which these fall. 

Categories of Records Description of records
Administration
  • Shareholder records
  • Share Register
  • Minutes of meetings of directors
  • Records relating to the incorporation of Parklands College
  • Minutes of meetings of committees and sub-committees
  • Umalusi documentation and accreditation records
  • Further/Higher Education registration documentation
  • Education Department registration documentation
  • Social Services registration documentation
Management
  • Minutes of meetings of Executive Committee
  • Internal Correspondence
  • Resolutions of the directors of Parklands College
Finance
  • Accounting Records
  • Tax Records
  • Debtors Records
  • Creditors Records
  • Insurance Records, including cover for learners and staff
  • Auditors Records
  • Interim and Annual Financial Statements
  • Bank Statements and other banking records for business and trust accounts
  • Invoices issued in respect of debtors and billing information
  • Records regarding Parklands College financial commitments
Human Resource
  • Lists of employees
  • Statistics regarding employees
  • Employment Contracts
  • Conditions of Employment
  • Information relating to prospective employees
  • Personnel records including personal details, disciplinary records, performance and internal evaluation records
  • Employee tax information
  • Records of Unemployment Insurance Fund contributions
  • Records regarding group life assurance and disability income protection
  • Provident Fund records
  • Payroll records
  • Health and safety records
  • Employment Equity records
  • Injury on duty records
  • Workplace skills plans
  • Codes of Conduct
  • Disciplinary Code and Procedures
  • Grievance Procedures
  • Appeal Procedures
  • Remuneration Policy
  • Internal policies and procedures regarding dismissals, performance appraisal, recruitment, selection, advertising of positions, appointments, retirement, promotions, leave, extended sick leave, study leave, salaries, overtime, bonuses, medical aid, health and safety, adoption leave and benefits, loans, working permits, smoking, use of company resources, including, telephones, motor vehicles and computers, sexual harassment, HIV-AIDS;
  • Training schedules and material
  • Correspondence relating to personnel
Suppliers
  • Supplier lists and details of suppliers
  • Agreements with suppliers
Information Technology
  • Computer Software
  • Support and maintenance agreements
  • Records regarding computer systems and programmes
Parents
  • Parent information records
Learners
  • Learner information records
Property
  • Asset registers
  • Lease Agreements in respect of immovable property
  • Records regarding insurance in respect of movable property
  • Records regarding insurance in respect of immovable property
Miscellaneous
  • Internal correspondence
  • Firm publications
Educational Material
  • Lesson Content
  • Exams and Tests

8.  Processing of Personal Information

8.1 Purpose of Processing Personal Information

Personal information is processed in order to conduct and meet the minimum standards required for the function and activity of the day-to-day operations of Parklands College. This will be done lawfully and in a reasonable manner that does not infringe on the privacy of a data subject.

The processing of information is not used for any other purpose other than for the purpose for which it was specifically collected without the written permission and consent of the data subject.

Parent/guardian, learner and student information is processed for the purposes of, not limited to:

  • Compliance with legislative and administrative requirements
  • Ensuring admission criteria is met
  • Biometrics for access control and internal procurement
  • Recording learner/student assessment and examination results
  • To aid learner support (internally and externally, i.e physiotherapy, assessment, medical, etc.)
  • To maintain parent/guardian contact details for learner progress updates, emergencies, notifications regarding school activities, sharing newsletters, etc.
  • Storing/saving College milestones and achievements, including videos and photographs, etc., for historical College collection, annual yearbook publications, social media platforms and website upgrades 
  • Recording and updating education department educational management systems
  • Applications for external scholarships 
  • Applications relating to special learner support and concessions
  • Completing educational statistics and surveys (unique identifiers are removed and information is aggregated)
  • Applications for education related accreditations and certifications
  • Applications for and enrolment in school related Olympiads and Competitions

Employee information is processed for the purposes of, not limited to:

  • Job application selection process and suitability of the candidate
  • Administration of staff records and human resource records
  • Biometrics for access control
  • Administration of payroll records
  • Provident Fund Membership
  • Medical Aid Membership
  • Personal and Company Insurance
  • Staff appraisals
  • Disciplinary procedures
  • Recording and updating education department educational management systems
  • Completing educational statistics and surveys (unique identifiers are removed and information is aggregated)
  • Applications for education related accreditations and certifications
  • Applications for and enrolment in school related Olympiads and Competitions

Parent/guardian consent is required for all information pertaining to a learner.  Any identifiable information regarding a person under the age of 18 years is considered Special Personal Information.

Other data subject information is processed for the purposes of, not limited to, performing business activities such as buying, services or installation bookings, deliveries, payments and marketing.

8.2 Description of the personal information of Data Subjects 

The personal information is collected in order to conduct and meet the minimum standards required for the function and activity of the day-to-day operation of the College and is specific for the purpose for which it is collected. Only the personal information that is adequate, necessary, relevant and not excessive will be collected in terms of the provisions of POPIA. 

Data Subject Category Personal Information (and special personal information) that may be processed
Staff, students, learners and parents/guardians Names, ID’s, gender, nationality, addresses, telephone numbersParent/Guardian details including addresses, contact numbers, email addressesEducation and employment dataBiometricsRaceMedical information including Medical Aid MembershipBehavioural informationSpecial Needs EducationMarital status Police Clearance (educators)Video and photographic images, including CCTV footage and live streaming of events
Creditors, service providers Names, addresses, ID numbersCompany registration numbers, VAT numbersBank details 

8.3 The recipients to whom the personal information may be supplied

The College shall ensure that all agreements in place with suppliers and other third parties in terms of which they are required to collect and use personal information shall adhere to the terms of the Privacy Policy (POPIA) and that there will be a mutual understanding regarding the protection of such personal information.  

  1. Sage Payroll & HRM:  staff information uploaded to this system is deemed confidential and only authorised staff have access.  This system supports payroll requirements for salaries, SARS, Department of Labour and Department of Home Affairs.
  2. EdAdmin database:  Staff, student, learner and parent/guardian personal information is recorded on the system
  3. WCED Electronic Management Information System (CEMIS)
  4. Digicape and our Insurance company for device repairs and maintenance.
  5. Medical Aid and Provident fund management.
  6. Professional / Skills Development courses that are signed up for
  7. Relevant Educational Institutions
  8. General description of Information Security Measures to be implemented by the responsible party to ensure the confidentiality, integrity and availability of the information

The College strives to safeguard personal information in its possession through policies and procedures and technical measures that have been put in place.  It remains the objective of the College to identify all reasonably foreseeable internal and external risks and to continuously verify the effectiveness of those measures against new risks that may arise.

The processing, access, protocols, password protection and security measures are updated as and whenever necessary and furthermore form part of the college annual review process.

The accuracy of the personal information recorded on our system is important and we regularly update and/or verify personal information.

9. Availability of the Manual

A copy of the Manual is available on the Parklands College website at www.parklands.co.za;

or at Parklands College, 91 Raats Drive, Table View, for public inspection during normal business hours.

10. Request procedure in terms of the Act

10.1 A request for access to records held by Parklands College in terms of the Act must be made on the form contained in the Regulations Regarding the Promotion of Access to Information (Form 2). A copy of the form is attached as Annexure A to this manual. The request must be made to Parklands College at the address or email addresses, specified in item 3 above.
   
10.2 Fees Payable
  The fee structure in respect of fees payable when making a request for access to information held by a Public or Private Body can be accessed on the Regulator’s website. 

11. Updating of the Manual

The Information Officer at Parklands College will update this manual as and when required.

12. Downloads

12.1 ANNEXURE A (Form 2)