PAIA manual

This manual is published in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 (“PAIA”), as amended by the Protection of Personal Information Act 4 of 2013 (“POPIA”).

It tells you what records Romens Clothing Company (Pty) Ltd holds, and how to request access to them. It also describes, as regulation 4(1)(e) of the PAIA Regulations requires, how we process personal information.

The manual is available free of charge on this page, and on request at any of our stores.

• Name: Romens Clothing Company (Pty) Ltd
• Registration number: [TO CONFIRM: company registration number]
• VAT number: [TO CONFIRM: VAT registration number]
• Registered / head office: [TO CONFIRM: registered office / head office address]
• Postal address: [TO CONFIRM: postal address]
• Website: www.romens.co.za

Trading addresses:

• Canal Walk — Shop 518, Upper Level, Canal Walk Shopping Centre, Century City, Cape Town, 7446 · 021 555 4993 · cw@romens.co.za
• Tygervalley — Shop 577, Tygervalley Shopping Centre, Willie Van Schoor Drive, Bellville Park, Cape Town, 7530 · 021 914 2122 · tv@romens.co.za
• Somerset Mall — Shop 64, Ground Floor, Somerset Mall, Somerset West, Cape Town, 7130 · 021 065 1763 · ssm@romens.co.za

Requests for access to records must be addressed to the Information Officer:

• Information Officer: [TO CONFIRM: full name of the Information Officer]
• Deputy Information Officer: [TO CONFIRM: full name(s) of any Deputy Information Officer]
• Email: [TO CONFIRM: Information Officer email, e.g. privacy@romens.co.za]
• Telephone: 021 555 4993
• Address: [TO CONFIRM: registered office / head office address]

The Information Officer is registered with the Information Regulator in terms of section 55 of POPIA.

The Information Regulator has compiled a guide, in terms of section 10 of PAIA, containing information a person needs in order to exercise their rights under the Act. The guide is available in each official language.

It may be obtained from the Information Regulator:

The Information Regulator (South Africa)
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
P.O. Box 31533, Braamfontein, Johannesburg, 2017
General enquiries: enquiries@inforegulator.org.za
POPIA complaints: POPIAComplaints@inforegulator.org.za
PAIA complaints: PAIAComplaints@inforegulator.org.za
Website: inforegulator.org.za

Romens has not published a notice under section 52(2) of PAIA listing categories of records that are automatically available without a request.

The following information is, however, freely available on our website or in our stores, and no PAIA request is needed for it:

• our store addresses, telephone numbers, email addresses and trading hours;
• our product ranges and the brands we carry;
• our Terms & Conditions, Privacy Policy, Cookie Policy and Exchanges & Returns policy;
• this manual.

Romens holds records in terms of, among others, the following legislation. Listing an Act here does not mean the records are automatically available to the public — access is still governed by PAIA.

• Companies Act 71 of 2008
• Consumer Protection Act 68 of 2008
• Protection of Personal Information Act 4 of 2013
• Income Tax Act 58 of 1962
• Value-Added Tax Act 89 of 1991
• Tax Administration Act 28 of 2011
• Basic Conditions of Employment Act 75 of 1997
• Labour Relations Act 66 of 1995
• Employment Equity Act 55 of 1998
• Skills Development Act 97 of 1998 and Skills Development Levies Act 9 of 1999
• Unemployment Insurance Act 63 of 2001 and Unemployment Insurance Contributions Act 4 of 2002
• Compensation for Occupational Injuries and Diseases Act 130 of 1993
• Occupational Health and Safety Act 85 of 1993
• Electronic Communications and Transactions Act 25 of 2002

To request access to a record held by Romens:

• Complete Form 02 (Request for Access to Record) prescribed under the PAIA Regulations, 2021. The form is available from the Information Regulator’s website, or from us on request.
• Send the completed form to the Information Officer at [TO CONFIRM: Information Officer email, e.g. privacy@romens.co.za], or deliver it to our registered address.
• Give enough detail to enable us to identify the record and to identify you. If you are acting on behalf of someone else, attach proof of your authority.
• State the form of access you want (a copy, an inspection, a transcription) and how you would like to be informed of our decision.
• State the right you are seeking to exercise or protect, and explain why the record is required for that purpose. Section 50 of PAIA only entitles you to a record held by a private body where it is required for the exercise or protection of a right. A request that does not explain this must be refused.
• Pay the prescribed request fee, where one applies.

We will respond within 30 days of receiving the request. That period may be extended by a further 30 days where the request is for a large number of records or requires a search of records held elsewhere; we will notify you in writing if that happens.

Two fees may apply under PAIA:

• a request fee, payable before we process the request; and
• an access fee, covering the cost of searching for, reproducing and preparing the record, payable before the record is released.

The amounts are those prescribed from time to time in the PAIA Regulations, published by the Minister of Justice, and are available from the Information Regulator’s website. We will give you a written estimate before we do the work, and we will not release a record until the access fee is paid.

A personal requester — someone requesting a record about themselves — does not pay a request fee.

PAIA obliges or permits us to refuse access in certain circumstances, including where the record contains:

• personal information about a third party, the disclosure of which would be unreasonable (section 63);
• commercial information of a third party — trade secrets, financial or commercial information that could harm them, or information supplied in confidence (section 64);
• information that would breach a duty of confidence owed to a third party (section 65);
• information that could endanger a person’s life or physical safety, or prejudice the security of property (section 66);
• records privileged from production in legal proceedings (section 67);
• our own trade secrets, or commercial or financial information the disclosure of which would harm our commercial or financial interests (section 68);
• research information of ours or of a third party (section 69).

We may also refuse a request where the record cannot be found or does not exist (section 55), or where the request is manifestly frivolous or vexatious.

Section 70 requires us to grant access despite these grounds where disclosure would reveal a substantial contravention of the law, or an imminent and serious public safety or environmental risk, and the public interest in disclosure clearly outweighs the harm.

We will notify you in writing of our decision, with reasons, and tell you of your right to take the matter further.

There is no internal appeal against a decision of a private body. If you are dissatisfied you may:

• lodge a complaint with the Information Regulator in terms of section 77A of PAIA, using Form 05, within 180 days of the decision; or
• apply to a court with jurisdiction in terms of section 78 of PAIA.

The Information Regulator’s details appear under “The PAIA Guide” above.

This section is included as regulation 4(1)(e) of the PAIA Regulations requires.

Purpose of processing

We process personal information to sell and exchange goods, to answer customer enquiries, to carry out alterations and special orders, to send marketing to those who have asked for it, to employ and pay staff, to keep the statutory records the law requires, and to protect people and property in our stores.

Categories of data subjects and their information

• Customers — name, contact details, purchase and exchange records, alteration measurements, enquiry correspondence, CCTV footage.
• Mailing list subscribers — name, email address, marketing preferences and engagement.
• Employees and job applicants — identity and contact details, banking details, employment history, qualifications, payroll and tax records.
• Suppliers and service providers — contact details of their representatives, banking and contractual records.

Recipients

Our operators (website host, email and marketing platform, IT support, accounting and payroll providers), our banks, our professional advisers, and regulators or courts where the law requires it.

Cross-border transfers

Some operators store information on servers outside South Africa. Those transfers are made in accordance with section 72 of POPIA.

Security measures

Access controls, encrypted website connections, secured premises, written operator agreements, staff training, and periodic review — as described in our Privacy Policy.

This manual is available:

• on this page, free of charge;
• at our head office and at each of our stores, on request;
• by email from the Information Officer.

We review the manual at least once a year and update it whenever our records, structure or contact details change. The “last updated” date at the top of this page shows when it last changed.