1. PREAMBLE

1.1. The Promotion of Access to Information Act, 2000 (“PAIA”) came into operation on 9 March 2001.  PAIA seeks, among other things, to give effect to the Constitutional right of access to any information held by the State or by any other person where such information is required for the exercise or protection of any right and gives natural and juristic persons the right of access to records held by either a private or public body, subject to certain limitations, in order to enable them to exercise or protect their rights.  Where a request is made in terms of PAIA to a private body, that private body must disclose the information if the requester is able to show that the record is required for the exercise or protection of any rights, and provided that no grounds of refusal contained in PAIA are applicable.  PAIA sets out the requisite procedural issues attached to information requests.  

1.2. Section 51 of PAIA obliges private bodies to compile a manual to enable a person to obtain access to information held by such private body and stipulates the minimum requirements that the manual has to comply with.

1.3. This Manual constitutes the Jobox PAIA manual (“Manual”).  This Manual is compiled in accordance with section 51 of PAIA as amended by the Protection of Personal Information Act, 2013 (“POPIA”), which gives effect to everyone’s Constitutional right to privacy. POPIA promotes the protection of personal information processed by public and private bodies, including certain conditions so as to establish minimum requirements for the processing of personal information.  POPIA amends certain provisions of PAIA, balancing the need for access to information against the need to ensure the protection of personal information by providing for the establishment of an Information Regulator to exercise certain powers and perform certain duties and functions in terms of POPIA and PAIA, providing for the issuing of codes of conduct and providing for the rights of persons regarding unsolicited electronic communications and automated decision making in order to regulate the flow of personal information and to provide for matters concerned therewith.

1.4. This Manual also includes information on the submission of objections to the processing of personal information and requests to delete or destroy personal information or records thereof in terms of POPIA.

VERSION	POLICY OWNER	DATE
1.0	[]	[]

2. ABOUT JOBOX

2.1. Jobox is an early talent discovery ecosystem built to connect employers, students and higher education institutions. 

2.2. Our ecosystem provides employers with access to vetted, diverse and affordable talent, students with work experience opportunities and higher education institutions with data-driven insights aimed at driving graduate employability forward. 

2.3. Our focus is to improve graduate employability by ensuring all students have the skills they need to enter, stay in, and thrive in the world of work. 

3. CONTACT DETAILS 

Name of Private Body:	Jobox Proprietary Limited
Designated Information Officer:	Sbusiso Buna
Email address of Information Officer:	bubu@joinjobox.com
Postal address:	155 West St, Sandown, Sandton, 2031
Street address:	155 West St, Sandown, Sandton, 2031
Phone number:	+27 71 672 5192

4. INFORMATION REGULATOR’S GUIDE 

An official 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 (“Guide”).  This Guide is made available by the Information Regulator (established in terms of POPIA).  Copies of the Guide are available from Information Regulator and the Information Officer free of charge.  Any request for public inspection of the Guide at the office of Jobox’s Information Officer (“Information Officer”) or a request for a copy of the Guide from the Information Officer must substantially correspond with Form 1 of Annexure A to Government Notice No. R.757 dated 27 August 2021 2021 promulgated under the PAIA Regulations.  Please refer to Annexure C.

5. OBJECTIVES OF THIS MANUAL

The objectives of this Manual are:

5.1. to provide a list of all records held by the legal entity;

5.2. to set out the requirements with regard to who may request information in terms of PAIA as well as the grounds on which a request may be denied;

5.3. to define the manner and form in which a request for information must be submitted; and

5.4. to comply with the additional requirements imposed by POPIA.

6. ENTRY POINT FOR REQUESTS

6.1. 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.

6.2. Information will therefore not be furnished unless a person provides sufficient particulars to enable Jobox 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’s 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.

6.3. The Information Officer has been delegated with the task of receiving and co-ordinating all requests for access to records in terms of PAIA, in order to ensure proper compliance with PAIA and POPIA.

6.4. The Information Officer will facilitate the liaison with the internal legal team on all of these requests.

6.5. All requests in terms of PAIA and this Manual must be addressed to the Information Officer using the details in paragraph 3 above.

7. AUTOMATICALLY AVAILABLE INFORMATION

7.1. Information that is obtainable via the Jobox website about Jobox is automatically available and need not be formally requested in terms of this Manual.

7.2. The following categories of records are automatically available for inspection, purchase or photocopying:

• brochures;
• press releases;
• publication; and
• various other marketing and promotional material.

8. INFORMATION AVAILABLE IN TERMS OF POPIA

8.1. In terms of POPIA, personal information must be processed for a specified purpose.  The purpose for which data is processed by Jobox will depend on the nature of the data and the particular data subject.  This purpose is ordinarily disclosed, explicitly or implicitly, at the time the data is collected.  

8.2. Categories of personal information collected by Jobox

8.2.1. account details: username, password, profile picture; 

8.2.2. contact details: email address, phone number;

8.2.3. location details: physical address, billing address, time zone; 

8.2.4. identity details: full name, proof of identity (e.g. drivers licence, passport), proof of address (e.g. utility bill), a photograph of the user; 

8.2.5. financial information:  credit card details, wire transfer details, payment processor details (e.g. Skrill, PayPal), tax numbers; 

8.2.6. user generated content: user profiles, user reviews, user messages etc.; 

8.2.7. metadata: IP address, computer and connection information, referring web page, standard web log information, language settings, time zone, etc.; 

8.2.8. device information: device identifier, device type, device plugins, hardware capabilities, etc.; and

8.2.9. location: GPS position. 

8.3. The purpose of processing personal information

We may use your Personal Information for the following purposes:

8.3.1. to provide the service you have requested;

8.3.2. to provide technical or other support to you;

8.3.3. to answer enquiries about our services, or to respond to a complaint;

8.3.4. to promote our other programs, products or services which may be of interest to you (unless you have opted out from such communications);

8.3.5. to allow for debugging, testing and otherwise operate our platforms;

8.3.6. to conduct data analysis, research and otherwise build and improve our platforms;

8.3.7. to comply with legal and regulatory obligations;

8.3.8. if otherwise permitted or required by law; and

8.3.9. for other purposes with your consent, unless you withdraw your consent for these purposes.

8.4. A description of the categories of data subjects and of the information or categories of information relating thereto

8.4.1. users of our services; 

8.4.2. our employees; 

8.4.3. contractors of Jobox; and 

8.4.4. third party service providers with whom we do business. 

8.5. The recipients or categories of recipients to whom the personal information may be supplied

8.5.1. our third-party service providers, including:

• cloud hosting, storage, networking and related providers; 
• SMS providers; 
• payment and banking providers; 
• marketing and analytics providers; and
• security providers;

8.5.2. statutory oversight bodies, regulators or judicial commissions of enquiry making a request for personal information;

8.5.3. any court, administrative or judicial forum, arbitration, statutory commission, or ombudsman making a request for personal information or discovery in terms of the applicable rules; and 

8.5.4. South African Revenue Services, or another similar authority. 

8.6. Planned transborder flows of personal information

We may transfer your Personal Information to places outside of South Africa and store it there, where us and/or of affiliates and/or service providers might process it.  If that happens, your Personal Information will only be transferred to and stored in a country that has equivalent, or better, data protection legislation than South Africa or subject to appropriate measures requiring compliance with data protection requirements equivalent or better than those applicable in South Africa. 

8.7. A general description of information security measures to be implemented by Jobox

Jobox takes extensive information security measures to ensure the confidentiality, integrity and availability of personal information in our possession.  Jobox takes appropriate technical and organisational measures designed to ensure that personal data remains confidential and secure against unauthorised or unlawful processing and against accidental loss, destruction or damage.

The security of your Personal Information is important to Us.  While We strive to use commercially acceptable means to protect your Personal Information, We cannot guarantee its absolute security.  However, We do employ a number of safeguards intended to mitigate the risk of unauthorized access or disclosure of your information.  We will do our best to protect your Personal Information and We will use up to date technology that will help us to do this.  We will at all times comply with our obligation under Data Protection Laws.

9. INFORMATION AVAILABLE IN TERMS OF OTHER LEGISLATION

Information is available in terms of certain provisions of the following legislation to the persons or entities specified in such legislation: 

• Arbitration Act 42 of 1965

• Basic Conditions of Employment Act 75 of 1997

• Broad Based Black Economic Empowerment Act 53 of 2003

• Companies Act 71 of 2008

• Compensation for Occupational Injuries and Health Diseases Act 130 of 1993

• Constitution of South Africa Act 108 of 1996

• Electronic Communications and Transactions Act 25 of 2002

• Employment Equity Act 55 of 1998

• Income Tax Act 58 of 1962

• Insolvency Act No. 24 of 1936 

• Labour Relations Act 66 of 1995

• Occupational Health & Safety Act 85 of 1993

• Pension Funds Act 24 of 1956

• Prevention and Combatting of Corrupt Activities Act 12 of 2004

• Prevention of Organised Crime Act 14 of 1998

• Protected Disclosure Act 26 of 2000

• Promotion of Access of Information Act 2 of 2000

• Promotion of Equality and Prevention of Unfair Discrimination Act 4 of 2000

• Protection of Personal Information Act 4 of 2013

• Skills Development Act 97 of 1998

• Skills Development Levies Act 9 of 1999

• Tax Administration Act 28 of 2011

• Unemployment Contributions Act 4 of 2002

• Unemployment Insurance Act 63 of 2001

• Value Added Tax Act 89 of 1991

 

10. CATEGORIES OF RECORDS AVAILABLE UPON REQUEST

10.1. Jobox maintains records on the categories and subject matters listed below.  Please note that recording a category or subject matter in this Manual does not imply that a request for access to such records would be honoured.  All requests for access will be evaluated on a case by case basis in accordance with the provisions of PAIA.  

10.2. Please note further that many of the records held by Jobox are those of third parties, such as clients and employees, and Jobox takes the protection of third party confidential information very seriously. In particular, where Jobox acts as professional advisors to clients, many of the records held are confidential and others are the property of the client and not of Jobox.  For further information on the grounds of refusal of access to a record please see paragraph 11.5 below.  Requests for access to these records will be considered very carefully.  Please ensure that requests for such records are carefully motivated.

Category of records	Records
Internal records The records listed pertain to Jobx’s own affairs	memoranda and articles of association; financial records; operational records; intellectual property; marketing records; internal correspondence; service records; statutory records; internal policies and procedures; and minutes of meetings
Personnel records For the purposes of this section, “personnel” means any person who works for or provides services to or on behalf of Jobox and receives or is entitled to receive any remuneration and any other person who assists in carrying out or conducting the business of Jobox.  This includes partners, directors, all permanent, temporary and part-time staff as well as consultants and contract workers.	any personal records provided to us by our personnel; any records a third party has provided to us about any of their personnel; conditions of employment and other personnel-related contractual and quasi legal records; employment policies and procedures; internal evaluation and disciplinary records; and other internal records and correspondence.
Investee/Portfolio company-related records	documents processed during the assessment and review of prospective investment opportunities; and  contracts with investees/portfolio companies and between such entities and other persons.
Other third party records Records are kept in respect of other parties, including without limitation joint ventures and consortia to which Jobox is a party, contractors and sub-contractors, suppliers, service providers, and providers of information regarding general market conditions.  In addition, such other parties may possess records which can be said to belong to Jobox.	personnel, client, or Jobox records which are held by another party as opposed to being held by Jobox; and records held by Jobox pertaining to other parties, including financial records, correspondence, contractual records, records provided by the other party, and records third parties have provided about the contractors or suppliers.
Other records	information relating to Jobox; and research information belonging to Jobox or carried out on behalf of a third party.

11. REMEDIES AVAILABLE TO A REQUESTER ON REFUSAL OF ACCESS

11.1. Completion of the prescribed form

11.1.1. Any request for access to a record in terms of PAIA must substantially correspond with Form 2 of Annexure A to Government Notice No. R.757 dated 27 August 2021 promulgated under the PAIA Regulations and should be specific in terms of the record requested.  Please refer to Annexure A.

11.1.2. A request for access to information which does not comply with the formalities as prescribed by PAIA will be returned to you.

11.1.3. POPIA provides that a data subject may, upon proof of identity, request Jobox 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. 

11.1.4. POPIA also provides that where the data subject is required to pay a fee for services provided to them, Jobox 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. 

11.1.5. Grounds for refusal of the data subject’s request are set out in PAIA and are discussed below.

11.1.6. POPIA provides that a data subject may object, at any time, to the processing of personal information by Jobox, on reasonable grounds relating to their particular situation, unless legislation provides for such processing.  The data subject must complete the prescribed form attached hereto as Annexure E and submit it to the Information Officer at the postal or physical address, facsimile number or electronic mail address set out above. 

11.1.7. A data subject may also request Jobox 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 Jobox is no longer authorised to retain records in terms of POPIA’s retention and restriction of records provisions. 

11.1.8. 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 Information Officer at the postal or physical address, facsimile number or electronic mail address set out above on the form attached hereto as Annexure F.

11.2. Proof of identity

Proof of identity is required to authenticate your identity and the request.  You will, in addition to this prescribed form, 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. Payment of the prescribed fees

11.3.1. There are two categories of fees which are payable:

11.3.1.1. The request fee: R140.00.

11.3.1.1. The access fee: This is calculated by taking into account reproduction costs, search and preparation costs, as well as postal costs.  These fees are set out in Annexure B.

11.3.2. Section 54 of PAIA entitles Jobox to levy a charge or to request a fee to enable it to recover the cost of processing a request and providing access to records.  The fees that may be charged are set out in Annexure B of Government Notice No. R.757 dated 27 August 2021 2021 promulgated under the PAIA Regulations.  Please refer to Annexure D.

11.3.3. Where a decision to grant a request has been taken, the record will not be disclosed until the necessary fees have been paid in full.

11.4. Timelines for consideration of a request for access

11.4.1. Requests 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.  

11.4.2. The Information Officer will inform the requester of the decision, and the fees payable (if applicable) on a form that corresponds substantially with Form 3 of Annexure A to Government Notice No. R.757 dated 27 August 2021 promulgated under the PAIA Regulations.

11.4.3. Should an extension be required, you will be notified, together with reasons explaining why the extension is necessary.

11.5. Grounds for refusal of access and protection of information

11.5.1. There are various grounds upon which a request for access to a record may be refused.  These grounds include:

11.5.1.1. the protection of personal information of a third person (who is a natural person) from unreasonable disclosure;

11.5.1.2. 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);

11.5.1.3. if disclosure would result in the breach of a duty of confidence owed to a third party;

11.5.1.4. if disclosure would jeopardise the safety of an individual or prejudice or impair certain property rights of a third person;

11.5.1.5. if the record was produced during legal proceedings, unless that legal privilege has been waived;

11.5.1.6. if the record contains trade secrets, financial or sensitive information or any information that would put Jobox (at a disadvantage in negotiations or prejudice it in commercial competition); and/or

11.5.1.7. if the record contains information about research being carried out or about to be carried out on behalf of a third party or by Jobox.

11.5.2. 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.

11.5.3. 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. AVAILABILITY OF THIS MANUAL

Copies of this Manual are available for inspection, free of charge, at the offices of Jobox and at ……….(insert url of manual)

Annexure A- FORM 2: REQUEST FOR ACCESS TO RECORD

 

REQUEST FOR ACCESS TO RECORD
[Regulation 7]

Note:

1. Proof of identity must be attached by the requester.
2. If requests made on behalf of another person, proof of such authorisation, must be attached to this form.

TO:

Name of Private Body:	Jobox Proprietary Limited
Designated Information Officer:	Sbusiso Buna
Email address of Information Officer:	bubu@joinjobox.com
Postal address:	155 West St, Sandown, Sandton, 2031
Street address:	155 West St, Sandown, Sandton, 2031
Phone number:	+27 71 672 5192

Mark with an “X”

Request is made in my own name Request is made on behalf of another person.

PERSONAL INFORMATION

Full names:
Identity number:
Capacity in which request is made (when made on behalf of another person):
Postal Address:
Street Address:
E-mail Address
Contact numbers:  Tel. (B): Cellular: Facsimile
Full names of person on whose behalf request is made (if applicable):
Identity number:
Postal Address:
Street Address:
E-mail Address:
Contact numbers: Tel. (B): Cellular: Facsimile
PARTICULARS OF RECORD REQUESTED Provide full particulars of the record to which access is requested, including the reference number if that is known to you, to enable the record to be located. (If the provided space is inadequate, please continue on a separate page and attach it to this form. All additional pages must be signed.)
Description of record or relevant part of the record:
Reference number, if available:
Any further particulars of record:

 

TYPE OF RECORD (Mark the applicable box with an “X”)
Record is in written or printed form
Record comprises virtual images (this includes photographs, slides, video recordings, computer-generated images, sketches, etc)
Record consists of recorded words or information which can be reproduced in sound
Record is held on a computer or in an electronic, or machine-readable form
FORM OF ACCESS (Mark the applicable box with an “X”)
Printed copy of record (including copies of any virtual images, transcriptions and information held on computer or in an electronic or machine-readable form)
Written or printed transcription or virtual images (this includes photographs, slides, video recordings, computer-generated images, sketches, etc)
Transcription of soundtrack (written or printed document)
Copy of record on flash drive (including virtual images and soundtracks)
Copy of record on compact disc drive (including virtual images and soundtracks)
Copy of record saved on cloud storage server

 

MANNER OF ACCESS (Mark the applicable box with an “X”)
Personal inspection of record at registered address of public/private body (including listening to recorded words, information which can be reproduced in sound, or information held on computer or in an electronic or machine-readable form)
Postal services to postal address
Postal services to street address
Courier service to street address
Facsimile of information in written or printed format (including transcriptions)
E-mail of information (including soundtracks if possible)
Cloud share/file transfer
Preferred language: (Note that if the record is not available in the language you prefer, access may be granted in the language in which the record is available)

 

PARTICULARS OF RIGHT TO BE EXERCISED OR PROTECTED If the provided space is inadequate, please continue on a separate page and attach it to this Form. The requester must sign all the additional pages.
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:

 

FEES
A request fee must be paid before the request will be considered. You will be notified of the amount of the access fee to be paid. 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. If you qualify for exemption of the payment of any fee, please state the reason for exemption.
Reason:

You will be notified in writing whether your request has been approved or denied and if approved the costs relating to your request, if any. Please indicate your preferred manner of correspondence:

Postal address	Facsimile	Electronic communication (Please specify)

 

Signed at ____________________ on this _________________ day of _____________________ 20_______

 

________________________________________
Signature of requester / person on whose behalf request is made
……………………………………………………………………………………………………………………

FOR OFFICIAL USE

Reference number:
Request received by: (state rank, name and surname of information officer)
Date received:
Access fees:
Deposit (if any):

 

_______________________________________________

Signature of Information Officer

Annexure B – FEES IN RESPECT OF PRIVATE BODIES

FEES IN RESPECT OF PRIVATE BODIES

Item	Description	Amount
	The request fee payable by every requester	R140.00
	Photocopy of A4-size page	R2.00 per page or part thereof.
	Printed copy of A4-size page	R2.00 per page or part thereof.
	For a copy in a computer-readable form on: Flash drive (to be provided by requestor) Compact disc If provided by requestor If provided to the requestor	R40.00 R40.00 R60.00
	For a transcription of visual images per A4-size page	Service to be outsourced. Will depend on quotation from Service provider.
	Copy of visual images	Service to be outsourced. Will depend on quotation from Service provider.
	Transcription of an audio record, per A4-size page	R24.00
	Copy of an audio record on: Flash drive (to be provided by requestor) Compact disc If provided by requestor If provided to the requestor	R40.00R40.00 R60.00
	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
	Deposit: If search exceeds 6 hours	One third of amount per request calculated in terms of items 2 to 8.
	Postage, e-mail or any other electronic transfer	Actual expense, if any.