Information required under section 51 (1)(e) of the Act

Personnel records
Personnel refers to any person who works for or provides services to or on behalf of KPAL and receives or is entitled to receive any remuneration and any other person who assists in carrying out or conducting the business of KPAL. This includes, without limitation, directors, executives, non-executives, all permanent, temporary and part-time staff as well as contract workers.

Personnel records include the following:
• Any personal records provided to KPAL by their personnel;
• Any records that a third party has provided to KPAL about any of their personnel;
• Conditions of employment and other personnel-related contractual and quasi-legal records;
• Internal evaluation records; and
• Other internal records and correspondence.
Customer-related records A customer includes any natural or juristic entity that receives services from KPAL. Customer-related
information includes the following:
• Any records a customer has provided to a third party acting for or on behalf of KPAL;
• Any records a third party has provided to KPAL; and
• Records generated by or within KPAL pertaining to the customer, including transactional records.
Records pertaining to KPAL

The following are considered to include but not be limited to records that pertain to KPAL’s own affairs:

• Financial records;
• Operational records;
• Databases;
• Marketing records;
• Internal correspondence;
• Statutory records;
• Internal policies and procedures;
• Treasury-related records;
• Securities and equities; and
• Records held by officials of KPAL;
• Software and licensing agreements.

Other Parties
KPAL may possess records pertaining to other parties, including without limitation contractors, suppliers, subsidiary and associated companies, joint venture companies and service providers. Alternatively, such other parties may possess records that can be said to belong to KPAL.

The following records fall under this category:
• Personnel, customer or KPAL’s records which are held by another party as opposed to being held by
KPAL; and
• Records held by KPAL pertaining to other parties, including without limitation financial records, correspondence, contractual records, records provided by the other party, and records third parties have provided about the contractors / suppliers.

REQUESTS
Categories of Requestors
The capacity under which a Requestor makes a request for records defines the category in which the Requestor will fall into. There are four categories of Requestors:
• A Data Subject who makes requests about themselves;
• A Representative who makes a request on behalf of the Data Subject(s);
• A Third Party who requests information about a Data Subject; or
• A Public Body who requests information in the public interest.

POPIA
POPIA provides that a data subject may, upon proof of identity, request Kansai Plascon 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 provides that a data subject may object, at any time, to the processing of personal information by Kansai Plascon, on reasonable grounds relating to his/her particular situation, unless legislation provides for such processing.

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

If a data subject that wishes to:

• object to the processing of their personal information must complete the form attached hereto as Appendix C and;
• request a correction or deletion of personal information or the destruction or deletion of a record of personal information must complete the form attached hereto as Appendix D and submit it to the Information Officer. The purpose of this section is to provide directive and guidance on the process to follow when requesting information from Kansai Plascon.
• The Requestor should contact Kansai Plascon’s Information Officer to obtain guidance on the process to follow when sending documentation containing personal information. This includes application forms and proof of identification documents.
• The prescribed form must be used and completed to make the request for access to a record. The form can be downloaded from the Department of Justice website (refer to Appendix B).
• Proof of identification of the Requestor (and related third parties acting on behalf of the Requestor) must be provided on submitting the request form.
• The requester must specify the right that they are seeking to protect or that they wish to exercise and provide an explanation as to why the requested records are required for the protection or exercise of that right.
• If the request is made on behalf of another person, then proof is required of the capacity in which the requester is making the request.
• Proof of identity must be provided in the form of a certified copy of the Requestor’s and/or delegate’s identity document or passport via secure methods provided by the Information Officer in the initial
correspondence.
• An initial response to a request will take approximately 30 days. The Information Officer may extend the period by an additional 30 days depending on the complexity of the request requirements.
• Please note that an application for access to information can be refused in the event that the application does not comply with the requirements of PAIA.
• The successful completion and submission of the access request does not automatically allow the Requestor access to the requested records.
• If access to a record/information is granted, the Requestor will be notified, and the notification will include the following:
– An indication of the access fee that should be paid upon gaining access (if any).
– An indication of the form in which the access will be granted.
• If access to a record/information is denied, the Requestor will be notified, and will include the following:
– Adequate reasons for the refusal.
– Process to appeal the refusal.
• Should the requester not be satisfied with the decision of the Information Officer, the Requester may apply to court for relief. In terms of PAIA, the said application must be made within 180 days after the decision has been made by the Information Officer.

Request Fees
Prescribed fees were published by the Minister of Justice and Constitutional Development in the Government
Gazette No. 23119, General Notice No. 187 of 15 February 2002.

Information available in terms of POPIA
Kansai Plascon may collect 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.

The purpose of processing personal information
In terms of POPIA, data must be processed for a specified purpose. The purpose for which data is processed by Kansai Plascon 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. In general, personal information is processed for purposes of on-boarding clients and suppliers, service or product delivery, records management, security, employment and related matters. Please refer to the Kansai Plascon Privacy Policy for further details.
https://plascon.co.za/privacy-policy

Categories of data subjects
Kansai Plascon holds information and records on the following categories of data subjects:
• customers of Kansai Plascon;
• employees / personnel of Kansai Plascon;
• Independent contractors of Kansai Plascon;
• suppliers of Kansai Plascon; and
• any third party with whom Kansai Plascon conducts business.
Categories of recipients to whom personal information may be supplied
Depending on the nature of the personal information, Kansai Plascon may supply information or records to the following categories of recipients:
• statutory oversight bodies, regulators or judicial commissions of enquiry making a request for data;
• any court, administrative or judicial forum, arbitration, statutory commission, or ombudsman making a request for data or discovery in terms of the applicable rules;
• South African Revenue Services, or another similar authority;
• anyone making a successful application for access in terms of PAIA or POPIA; and
• subject to the provisions of POPIA and other relevant legislation, Kansai Plascon may share information about a client’s creditworthiness with any credit bureau or credit providers industry association or other association for an industry in which Kansai Plascon operates.

Transborder flows of personal information
Kansai Plascon may need to transfer a data subject’s information to service providers in countries outside South Africa, these countries may not have data-protection laws which are similar to those of South Africa. Where this is done, Kansai Plascon do so in accordance with applicable laws.

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