Form 1 - Objection to the Processing of Personal Information
05.09.2024 | PDF | 61.05 KB
鈥淐濒颈别苍迟鈥澨A natural or juristic person who receives services from 麻豆色情片.
鈥淒ata subject鈥澨The natural or juristic person to whom personal information relates
鈥凄滨翱鈥澨Deputy Information Officer;听听听听听听听
鈥泪翱鈥溙Information Officer;
鈥淢补苍耻补濒鈥澨means the manual, together with all the annexures thereto as amended and made available at the offices of 麻豆色情片 from time to time
鈥淢别诲颈肠濒颈苍颈肠鈥澨means 麻豆色情片 Pty Ltd (registration number -1969/009218/07)
鈥淧础滨础鈥澨Promotion of Access to Information Act No. 2 of 2000 (as Amended;
鈥淧翱笔滨础鈥澨Protection of Personal Information Act No.4 of 2013;
鈥淧谤辞肠别蝉蝉颈苍驳鈥澨means any operation or activity or any set of operations whether or not by automatic means concerning personal information, including 鈥
a)听听听听 The collection, receipt, recording organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use;
b)听听听听 Dissemination by means of transmission, distribution or making available in other form; or
c)听听听听 Merging, linking, as well as restriction, degradation, erasure or destruction of information.
鈥凌别驳耻濒补迟辞谤鈥听Information Regulator; and
鈥凌别辩耻别蝉迟别谤鈥澨means any person or entity (including any data subject) requesting access to a record that is under the control of 麻豆色情片.
鈥淭丑颈谤诲-辫补谤迟测鈥澨means any independent contractor, agent, consultant, sub-contractor or other representative of 麻豆色情片.
2.听听听听听听听听 PREAMBLE
Manual of the 麻豆色情片 Group of Companies (as per the individual companies and entities on the attached list, herein represented by 麻豆色情片 (Pty) Ltd) prepared in terms of section 51 of the Promotion of Access to Information Act, No 2 of 2000.
3.听听听听听听听听 ABOUT MEDICLINIC
麻豆色情片 is a diversified international private healthcare services group, established in South Africa in 1983, with divisions in Switzerland, Southern Africa (South Africa and Namibia) and the Middle East.
麻豆色情片 is focused on providing specialist-orientated, multi-disciplinary services across the continuum of care in such a way that the Group will be regarded as the most respected and trusted provider of healthcare services by clients, medical practitioners, funders and regulators of healthcare in each of its markets.
麻豆色情片 takes a sustainable, long-term approach to business, putting clients at the heart of its operations and consistently delivering high-quality healthcare services. In order to deliver on these priorities, the Group upholds the highest standards of clinical governance and ethical behaviour across its divisions; invests significant time and resources in recruiting and retaining skilled employees; makes considerable investment into its facilities and equipment; and respects the communities and environment in the areas in which it operates.
4.听 听听听听听听 PURPOSE OF PAIA MANUAL
听听 This PAIA Manual is useful for the public to-
4.1听听听听听听听 check the categories of records held by a body which are available without a person having to submit a formal PAIA request;
4.2听听听听听听听 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;
4.3听听听听听听听 know the description of the records of the body which are available in accordance with any other legislation;
4.4听听听听听听听 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;
4.5听听听听听听听 know the description of the guide on how to use PAIA, as updated by the Regulator and how to obtain access to it;
4.6听听听听听听听 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;
4.7听听听听听听听 know the description of the categories of data subjects and of the information or categories of information relating thereto;
4.8听听听听听听听 know the recipients or categories of recipients to whom the personal information may be supplied;
4.9听听听听听听听 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
4.10听听听听 know whether the body has appropriate security measures to ensure the confidentiality, integrity and availability of the personal information which is to be processed.
5听听听听听听听 CONTACT DETAILS
Name of company | 麻豆色情片 (Pty) Ltd Registration number: 1969/009218/07 |
CEO听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听听 Postal Address听 Street Address Telephone number听 听 听 听 听 E-mail address听 听 听 听 听 听 听 听 听 | Mr. Greg van Wyk听听 P O Box 456, STELLENBOSCH, 7599 麻豆色情片 Corporate Office, 25 Du Toit Street,听Stellenbosch 听+27 21 809 6500 |
Information Officer听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听听 Postal Address听 Street Address Telephone number听 听 听 听 听 E-mail address听 听 听 听听 听 | Mr Clinton Lottering 听 P O Box 456, STELLENBOSCH, 7599听听 麻豆色情片 Corporate Office, 25 Du Toit Street, Stellenbosch +27 21 809 6725 |
Deputy Information Officer听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听听 Postal Address听 Street Address Telephone number听 听 听 听 听 E-mail address听 | Ms Varuschka Narotam听听 P O Box 456, STELLENBOSCH, 7599听听 麻豆色情片 Corporate Office, 25 Du Toit Street, Stellenbosch +27 21 809 6500 Varuschka.Narotam@麻豆色情片.com |
National or Head Office听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 Postal Address听 Street Address Telephone number听 听 听 听 听 E-mail address听 | P.O. BOX 456. Stellenbosch, 7599 听听听听听听听听听听听听听听听听听听听 麻豆色情片 Corporate Office, 25 Du Toit Street, Stellenbosch 021听809 6500 www.mediclinic.co.za |
6. 听听听听 INFORMATION REGULATORS GUIDE
An official PAIA Guide has been compiled which contains information to assist a person
wishing to exercise a right of access to information in terms of PAIA and POPIA. Copies of the PAIA Guides are available, in two official languages, English and Afrikaans for public inspection at our registered head office during normal business hours (08h30 鈥 16h30). The PAIA Guide is also available on the Regulator鈥檚 website听, in all eleven (11) official languages and copies thereof, including braille, are available at the Office of the Information Regulator, for inspection, during normal office hours. The Information Regulator can be reached at:
The Information Regulator Postal Address Telephone number E-mail address听 听 听 听 听 听 听 听 听 | 听 P O Box 31533, Braamfontein, Johannesburg,听2017 +27 (0) 101听023 5200 |
Information Officer Telephone number E-mail address听听 | Mr. Mosalanyane Mosala +27 (0) 10 023 5251 |
Deputy Information Officer听 Telephone number E-mail address听听 | Mr. Jaco Jansen听听 +27 (0) 10 023 5237 |
7.听听听听听听听听 ENTRY POINT FOR REQUESTS
听听听听听听听听听听听 PAIA provides that a person may only make a request for information, if the information is required for the exercise or protection of a legitimate right. Information will therefore not be furnished unless a person provides sufficient particulars to enable 麻豆色情片 to identify the right that the requester is seeking to protect as well as an explanation as to why the requested information is required for the exercise or protection of that right. The exercise of an individual鈥檚 rights is subject to justifiable limitations, including the reasonable protection of privacy, commercial confidentiality and effective, efficient and good governance. PAIA and the request procedure contained in this Manual may not be used for access to a record for criminal or civil proceedings, nor should information be requested after the commencement of such proceedings.
The IO has been delegated with the task of receiving and coordinating all requests for access to records in terms of PAIA, in order to ensure proper compliance with PAIA and POPIA.
The IO will facilitate the liaison with the internal legal team on all of these requests. All requests in terms of PAIA and this Manual must be addressed to the IO using the details in paragraph 3 above.
8.听听听听听 CATEGORIES OF RECORDS OF MEDICLINIC WHICH ARE AVAILABLE WITHOUT A PERSON HAVING TO REQUEST ACCESS
There is currently no description of categories of records which are automatically available in terms of section 52(2) of the Act.听 Information that is obtainable via the 麻豆色情片 website about 麻豆色情片 is automatically available and need not to be formally requested in terms of this Manual. The following categories of records are automatically available:
8.听听听听听 DESCRIPTION OF THE RECORDS OF MEDICLINIC WHICH ARE AVAILABLE IN ACCORDANCE WITH ANY OTHER LEGISLATION 听
听听听听听听听听 All records that are legally required to be kept by the company in terms of the following legislation are available:
Although 麻豆色情片 has used its best endeavours to supply the Requester with a complete list of applicable legislation, it is possible that the above list may be incomplete. Wherever it comes to 麻豆色情片鈥檚 attention that existing or new legislation allows a Requester access on a basis other than that set out in the Act, 麻豆色情片 shall promptly update the list. If a Requester believes that a right to access to a Record exists in terms of the legislation listed above, or any other legislation, the Requester is required to indicate what legislative right the request is based on, to allow the Information Officer the opportunity of considering the request in light thereof.
9.听听听听听 DESCRIPTION OF THE SUBJECTS ON WHICH THE BODY HOLDS RECORDS AND CATEGORIES OF RECORDS HELD ON EACH SUBJECT BY MEDICLINIC
Subjects on which the body holds records听 听 听 听 听听 | 听 Categories of records |
Company secretarial records | Minutes of meetings, company registration certificates, share registers and other statutory registers. 听听 |
Finance | Reports and returns, banking details and back account records, financial statements and budgets. |
Funder Relations and Contracting | Healthcare provider database, Care Expert agreements, patient accounts, funder cost per event reports, product development reports, clinical performance reports. |
Hospital related records | Patient admission documentation, patient records information, patient billing information, minutes of meetings of all constituted committees.听 |
Human Resources | List of employees, employment contracts, employee records of each employee of 麻豆色情片, Employment Equity Plans, Retirement fund records, medical aid records, employee tax information, employee training records, payroll records, internal policies and procedures. |
Information Technology | Records regarding computer systems, programmes and databases held by 麻豆色情片. |
Legal Services | Monthly circumstance list, reports of patient and adverse event information, summons register, hospital event reports and improvement investigations, hospital and clinical records, legal system, insurance claim lists, insurance reporting, legally privileged documentation, file registers and vendor forms. |
Marketing | List of models for photoshoots, details of 麻豆色情片 Baby members, details of 麻豆色情片 Prime members, Sponsor database, newsletters and magazines, medial list, supplier and service providers, internal and external guest lists, doctors contact details database, medical entrants database and stakeholder relationship management database. |
Nursing Services | WCA forms, Bed register or lists, vaccination registers, file request registers, pharmacy order, theatre management system, theatre lists, telephone lists for doctors, laboratory results, serious adverse events, schedule 5 & 6 medication registers, research and trial registers, reporting of notifiable medical condition register, patient stickers, and staff allocation books.听 |
Property | Title deeds, lease agreements, hire agreements / rental agreements. |
Operations | Policies, procedures, guidelines, reports and supporting documentation. |
Training and Development | Work place skills plans and annual training reports, student / learner records, learnership applications and placement information, apprenticeship documentation, information shared with the HWSETA, third party agreements, learner contracts and academic transcripts. |
10.听听听听听听 PROCESSING OF PERSONAL INFORMATION
10.1听听听听 PRPOSE OF MEDICLINIC PROCESSING OF PERSONAL INFORMATION 听听听听听听
10.1.1听听 麻豆色情片 will only process data subject鈥檚 personal information for a specific, lawful and clear purpose and will ensure that it notifies the data subject, unless we consider that we need to use it for another reason and that reasons is compatible with the original purpose for which the information was collected.
10.1.2听听 It will ensure there is a legal basis for the processing of any personal information.
10.1.3听听 麻豆色情片 will retain personal information only for no longer that is necessary or permitted by applicable law. Once information is no longer required in accordance with our retention policies, it will be securely destroyed.听 In some circumstances, we may anonymize personal information so that it can longer be associated with data subjects, in which case may use such information without further notice.听
10.1.4听听 麻豆色情片 may share your personal information with third parties and other appropriate persons within the Group. We require all such persons to respect the security of data subjects鈥 personal information and to treat it in accordance with the applicable laws.
10.2听听听听听 DESCRIPTION OF THE CATEGORIES OF DATA SUBJECT AND OF THE INFORMATION CATEGORIES OF INFORMATION RELALTING THERETO:
Categories of Data Subjects | Personal Information that may be processed |
Patients | Name, gender, home address and telephone number, date of birth, biometric information, emergency contact details Copy of passport and national identification document Medical scheme, insurance and other benefits information Employer details and contact information Date of admission, tracking of bed status and theatre usage and date of discharge Height, weight and other detailed health information such as allergies, preferences and special need requirements as well as diagnoses and treatment Physical and mental healthcare records (including results and opinions from third party providers, such as X-rays, scans and blood tests; referrals and second opinions, such as written statements, medical photographs and diagrams and surgical videos), banking details, video footage, and referring doctors details such as name, surname, email address, telephone number. |
麻豆色情片 and Allied Health Professionals听 听 | Name, Surname, Government Issued Identification, HPCSA Registration Number, Practice Number, practice contact details, specialty, qualifications, fields of interest, cell phone number, personal email address, race, gender, account numbers, CPE reports, Indemnity insurance, and patient experience survey results. |
Employees | Name, gender, telephone number, date of birth, photograph, biometric information, marital status, emergency contact details, ethnicity, residency and work permit status, nationality and passport information (including copies thereof), professional certifications and registrations, confirmation of qualifications, disability status and details where applicable and special needs, salary expectations, Covid-19 vaccination status may be monitored. Where permitted by law proportionate in view of the function to be carried out by an employee or prospective employee, the results of credit and criminal backgrounds and driving history. Tax number, social security number (country specific), banking details, sick pay, pensions, insurance and other benefit information, information about any spouse, minor children, or other eligible dependents and beneficiaries. Date of appointment, dates of promotion, work history, technical skills and educational background. Date of learning activities, duration, scores and learning completions. Height, weight and clothing sizes where required i.e for uniforms. Date of resignation or termination, reason for resignation or termination, information relating to administering termination of employment Records of work absences, vacation entitlement and requests, salary history, performance appraisals, letters of appreciation and commendation, disciplinary and grievance procedures and psychometric assessment records. Where permitted by law and proportionate in view of the function to be carried out by an employee or prospective employee, the results of credit and criminal background checks, the results of drug and alcohol testing (country specific), screening, health certifications, drivers licence number, vehicle registration and driving history.听 Information required to comply with laws, the requests and directions of law enforcement authorities or court orders, Tax number social security number, audit requirements (country specific). |
* All the details regarding the processing activities per data subject category listed above can be obtained from the company鈥檚 website, the employee privacy notice is available to employees on the Connect employees system.听 听
10.3听听听听听 THE RECIPIENTS OR CATEGORIES OF RECIPIENTS TO WHOM THE PERSONAL INFORMATION MAY BE SUPPLIED
We use different methods to collect personal information from and about you, including through:
路听听听听听听 The 麻豆色情片 Group is an international healthcare services group, with the Company鈥檚 registered office in the United Kingdom and its management offices based in South Africa. The 麻豆色情片 Group has operating divisions, all of which are based outside the EU, in Switzerland (Hirslanden), South Africa and Namibia (麻豆色情片) and the United Arab Emirates (麻豆色情片 Middle East). As such our information systems or those of service providers may be in different countries. This may result in the transfer of your personal information might end up in one of those information systems to another country, and that country may have a different level of data protection regulation than yours. By giving us personal information, you consent to this kind of transfer of your personal information. No matter what country your personal information is in, you can expect a similar degree of protection in respect of your personal information which will be processed in accordance with our privacy and data protection policy and applicable laws.
路听听听听听听 As explain above, we outsource the processing of certain functions and/or information to third parties. When we do outsource the processing of your personal information to third parties or provide your personal information to third-party service providers, we oblige those third parties to protect your personal information with appropriate security measures in accordance with our standards and applicable law.听听
10.3.3听听 Business transfers
路听听听听听听 Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this privacy notice.
路听听听听听听 We reserve the right to disclose any personal information we have concerning you if we are compelled to do so by a court of law, requested to do so by a governmental entity, or if we determine it is necessary or desirable to comply with the law or to protect or defend our rights or property in accordance with applicable laws. We also reserve the right to retain personal information collected and to process such personal information to comply with accounting, tax rules, regulations and any specific record retention laws.
路听听听听听听 We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
10.4听听听听 TRANS BORDER FLOW OF PERSONAL INFORMATION听
10.5听 Data Security Measures 听 |
麻豆色情片 and our service providers takes appropriate technical and organisational measures designed to ensure that personal information remains confidential and secure against unauthorised or unlawful processing against accidental loss, destruction or damage. Technical and organisational measures include:
路听听听听听听 Encryption of data in transit and at rest;
路听听听听听听 Identity and access management;
路听听听听听听 Infrastructure and operations security;
路听听听听听听 Vulnerability management;听
路听听听听听听 Business continuity planning;
路听听听听听听 Disaster recovery planning; and
路听听听听听听 Security awareness.
Further details of these measures are available upon request. We have put in place procedures to deal with any suspected data security breaches, and will notify data subjects and the Regulator of a suspected breach where we are legally required to do so.
11 听听听听听听 REQUEST PROCEDURE
11.1 听听听听 Completion of prescribed forms
Any request for access to a record in terms of PAIA must correspond with the PAIA Form 2: Request for Access to Record and should be specific in terms of the record requested. (听hereto.). A request for access to information which does not comply with the formalities as prescribed by PAIA will be returned to you. POPIA provides that a data subject may, upon proof of identity, request 麻豆色情片 to confirm, free of charge, all the information it holds about the data subject and may request access to such information, including information about the identity of third parties who have or have had access to such information.
POPIA also provides that where the data subject is required to pay a fee for services provided to him/her, 麻豆色情片 must provide the data subject with a written estimate of the payable amount before providing the service and may require that the data subject pays a deposit for all or part of the fee.
Grounds for refusal of the data subject鈥檚 request are set out in PAIA and are discussed below. POPIA provides that a data subject may object, at any time, to the processing of personal information by 麻豆色情片, on reasonable grounds relating to his/her particular situation, unless legislation provides for such processing. The data subject must complete the prescribed form attached hereto as听 and submit it to the IO at the postal or physical address or electronic mail address set out above.
A data subject may also request 麻豆色情片 to correct or delete personal information about the data subject in its possession or under its control that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully; or destroy or delete a record of personal information about the data subject that 麻豆色情片 is no longer authorised to retain records in terms of POPIA鈥檚 retention and restriction of records provisions.
A data subject that wishes to request a correction or deletion of personal information or the destruction or deletion of a record of personal information must submit a request to the IO at the postal or physical address or electronic mail address set out above on the form attached hereto as听.
11.2 听听听听 Proof of Identity
Proof of identity is required to authenticate your identity and the request. You will, in addition to this prescribed听, be required to submit acceptable proof of identity such as a certified copy of your identity document or other legal forms of identity.
11.3 听听听听 Payment of the prescribed fees
听 | 听听听听 There are two categories of fees which are payable: |
听 |
|
听 | Section 54 of PAIA entitles 麻豆色情片 to levy a charge or to request a fee to enable it to recover the cost of听processing a request and providing access to records. The fees that may be charged are set out in the PAIA听Regulations. Where a decision to grant a request has been taken, the record will not be disclosed until thenecessary fees have been paid in full. 听 |
11.4 听听听听 Timelines for consideration of a request for access
Request will be processed within 30 (thirty) days, unless the request contains considerations that are of such a nature that an extension of the time limit is needed. The Information Officer will inform the requester of the decision, and the fees payable (if applicable) on a form corresponding with PAIA Form 3: Outcome of Request and of Fees Payable promulgated under PAIA Regulations (Link to form to be included).
Should an extension be required, you will be notified, together with reasons explaining why the extension is necessary.
11.5 听听听听 Grounds for refusal of access and protection of information:
There are various grounds upon which a request for access to a record may be refused. These grounds include: |
路听听听听听听 the protection of personal information of a third person (who is a natural person) from unreasonable disclosure; 路听听听听听听 the protection of commercial information of a third party (for example: trade secrets; financial, commercial, scientific or technical information that may harm the commercial or financial interests of a third party); 路听听听听听听 if disclosure would result in the breach of a duty of confidence owed to a third party; 路听听听听听听 if disclosure would jeopardise the safety of an individual or prejudice or impair certain property rights of a third person; 路听听听听听听 if the record was produced during legal proceedings, unless that legal privilege has been waived; 路听听听听听听 if the record contains trade secrets, financial or sensitive information or any information that would put 麻豆色情片 (at a disadvantage in negotiations or prejudice it in commercial competition); and/or 路听听听听听听 if the record contains information about research being carried out or about to be carried out on behalf of a third party or by 麻豆色情片. |
Section 70 of PAIA contains an overriding provision. Disclosure of a record is compulsory if it would reveal (i) a substantial contravention of, or failure to comply with the law; or (ii) there is an imminent and serious public safety or environmental risk; and (iii) the public interest in the disclosure of the record in question clearly outweighs the harm contemplated by its disclosure. If the request for access to information affects a third party, then such third party must first be informed within 21 (twenty one) days of receipt of the request. The third party would then have a further 21 (twenty-one) days to make representations and/or submissions regarding the granting of access to the record. |
12.听听听听听听 REMEDIES AVAILABLE TO A REQUESTER ON REFUSAL OF ACCESS
If the IO decides to grant you access to the particular record, such access must be granted with thirty (30) days of being informed of the decision. There is no internal appeal procedure that may be followed after a request to access to information has been refused. The decision made by the IO is final. In the event that you are not satisfied with the outcome of the request, you are entitled to lodge an internal appeal, a compliant to the Regulator by using , or apply to a court of competent jurisdiction.听听
13.听听听听听听 AVAILABILITY OF THIS MANUAL
Copies of this manual are available from the IO for inspection, free of charge at the offices of 麻豆色情片 at 25 Du Toit Street, Stellenbosch, 7600.
听
* Please note this list is not exhaustive and may be updated from time to time as required.
13. UPDATING OF THE MANUAL
The Information Officer of 麻豆色情片 will on a regular basis update this manual as required.
Issued by 听
Clinton Lottering
Information Officer