PAIA & POPI POLICY (“The Policy”)

This is the Humewood Golf Club’s (“the Club”) policy in terms of the Protection of Personal Information Act, No. 4 of 2013 (“POPIA”) and the Promotion of Access to Information Act, No. 2 of 2000 ("PAIA") (“the Policy”)

This Policy applies to the business of the Club wherever it is conducted, it applies to its Members, paid staff, guests, volunteers and associates of the Club upon the premises of the Club and towards the Club’s general business, golf and Member management conduct.

A: PAIA Policy

• PAIA is an act that was passed to give effect to the constitutional right, held by everyone in South African, of access to information which is held by the State or by another person (including the Club) and which is required for the exercise or protection of any right. Where a request is made in terms of PAIA, the body to which the request is made is obliged to give access to the requested information, except where the Act expressly provides that the information may or must not be released. It is important to note that PAIA recognises certain limitations to the right of access to information, including, but not exclusively, limitations aimed at the reasonable protection of privacy, commercial confidentiality, and effective, efficient, and good governance and in a manner which balances that right with any other rights, including such rights contained in the Bill of Rights in the Constitution.

• One of the main requirements specified in PAIA is the compilation of an information manual that provides information on both the types and categories of records held by a private body. This Policy serves as the Club’s Information Manual. This Policy is compiled in accordance with Section 51 of PAIA and the Schedule to POPIA. It is intended to give a description of the records held by and on behalf of the Club, to outline the procedure to be followed and the fees payable when requesting access to any of these records in the exercise of the right of access to information, with a view of enabling requesters to obtain records which they are entitled to in a quick, easy, and accessible manner. This Policy is available for public inspection at the physical address of the Club, free of charge.

The Club only keeps the Personal Information of the Member as defined in the POPIA Policy below. Members shall at all reasonable times have access to such data and retrieve it in full via:

• Personal presentation of his/her RSA ID at the Club’s Pro Shop; or
• Via email to the Club Secretary, assuming that is the email held by the Club on record.

The Club shall within a reasonable time provide a Member with that Personal Information and shall charge no fee to provide it.

B: POPIA Policy

Note:

POPIA compliance is still in its infancy. The procedures and guidelines in this Policy are drafted using the best available guidance from the Information Regulator as of 1 July, 2021 and hence this Policy is Version 1.0. The Club notes that it will amend this document should practices and procedures change in due course (amendments as provided for and approved by GolfRSA).