CONTOUR LOGISTICS (PTY) LTD

1. DEFINITIONS

Unless the context clearly indicates otherwise, the following terms shall have the meanings assigned to them hereunder, namely;

Client means a natural or juristic person who receives services and/or products from the organisation.

data subject/s ("you" or "your") includes all living individuals, and juristic persons about whom the organisation holds personal information.

Information Officer means the person acting on behalf of the organisation and discharging the duties and responsibilities under the Protection of Personal Information Act, 2013.

Manual means this manual published in compliance with Section 51 of the Protection of Personal Information Act, 2013, with all appendices thereto as amended.

PAIA means the Promotion of Access to Information Act, 2000, including any regulations.

personal information means information relating to an identifiable, living, natural person, and where it is applicable and identifiable, existing juristic person, including, but not limited to -

1. 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;
2. information relating to the education or the medical, financial, criminal or employment history of the person;
3. any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier, or other particular assignments to the person;
4. the biometric information of the person;
5. the personal opinions, views, or preferences of the person;
6. 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;
7. the views or opinions of another individual about the person; and
8. 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.

"POPIA" means the Protection of Personal Information Act, 2013, including any regulations.

"processing" means any operation or activity or any set of operations, whether or not by automatic means, concerning personal information, including -

1. the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation, or use;
2. dissemination through transmission, distribution or making available in any other form; or merging, linking, as well as restriction, degradation, erasure, or destruction of information.

"record" means any recorded information regardless of form or medium, including any of the following:

1. writing on any material;
2. information produced, recorded, or stored by means of any tape-recorder, computer equipment, whether hardware or software or both, or other device, and any material subsequently derived from information so produced, recorded, or stored;
3. label, marking or other writing that identifies or describes anything of which it forms part, or to which it is attached by any means;
4. book, map, plan, graph, or drawing;
5. photograph, film, negative, tape or other device in which one or more visual images are embodied so as to be capable, with or without the aid of some other equipment, of being reproduced;

in the possession or under the control of a responsible party, whether or not it was created by a responsible party and regardless of when it came into existence.

"Requester" means any person or entity (including any Data Subject) and any person acting on behalf of that person, requesting access to a record that is under the control of the organisation.

"responsible party" means a public or private body or any other person that, alone or in conjunction with others, determines the purpose and means for processing personal information. For this Manual, the responsible party will be the organisation.

"SAHRC" means the South African Human Rights Commission.

"special personal information" includes personal information concerning the religious or philosophical beliefs, race or ethnic origin, trade union membership, political persuasion, health or sex life or biometric information of an information subject, or the criminal behaviour of an information subject.

"the organisation" refers to Contour Logistics (Pty) Ltd and all wholly-owned subsidiaries directly or indirectly controlled by it.

Unless a contrary intention clearly appears, words signifying:

1. The singular includes the plural and vice versa;
2. Any one gender includes the other genders and vice versa;
3. Natural persons include juristic persons.

2. PURPOSE OF THIS MANUAL

Section 51 of PAIA obliges private bodies to compile a manual to enable a person to obtain access to information held by such a private body.

This Manual has been prepared under Section 51 of the Promotion of Access to Information Act, 2000 ("PAIA") and aims to facilitate a request for access to a record held by the organisation required for the exercise or protection of any rights.

3. ABOUT THE ORGANISATION

Contour Logistics (Pty) LTD ("we" or "us" or "our" or "the organisation") is a Freight Forwarding and Logistics Service Provider incorporated under the company laws of South Africa that operates in the Transport/ Logistics industry.

This Manual applies to the organisation and all wholly-owned subsidiaries directly or indirectly controlled by it, of which there are none. The following are directors of the organisation:

Directors	Ms. M Rademan (Managing)
	Mr. JJ de Koker (Finance)
	Ms. N Cilliers
	Mr. PH du Plessis
	Mr. WJA Smith
	Mr. N Veldsman

The contact details of the organisation as required under section 51(1)(a) of PAIA are as follows:

Name of Organisation:	Contour Logistics (Pty) Ltd
Physical and Postal Address:	Head Office – Cape Town Physical: Bonitas Office Park B, 2nd Floor, Suite 0202, Carl Cronje Drive, South Gate, Tyger Waterfront, 7530 Postal: P.O Box 6092, Welgemoed, 7538
Head of body:	Name: Mariaan Rademan Email: mariaan@contourlogistics.co.za
Information Officer:	Name: Jacques de Koker Email: jacques@contourlogistics.co.za Contact number: 021 918 4900
Deputy Information Officers:	Name: Christine Jonker Email: christine_jonker@contourlogistics.co.za Name: Abigail Overmeyer Email: abigail@contourlogistics.co.za

4. SAHRC GUIDE

The SAHRC has compiled a guide, as required by Section 10 of the Act, containing such information as may reasonably be required by a person who wishes to exercise any right contemplated in this Act. The guide is available from the SAHRC or at their website at http://www.sahrc.org.za/.

The contact details of the SAHRC are:

Address:
The South African Human Rights Commission
Braampark Forum 3
33 Hoofd Street
Braamfontein, Johannesburg

Telephone:
+27 11 877 3600

Website:
www.sahrc.org.za

5. RECORDS AVAILABLE WITHOUT REQUEST

As required by Section 51(1)(c) of PAIA, the following records are automatically available without a person having to request access to them.

The website of the organisation, which can be located here: www.contourlogistics.co.za and is accessible to anyone who has access to the Internet. The website of the organisation hosts the following categories of information:

• Brands
• Company info, including contact information.
• Corporate Info
• Corporate Profile
• Service offerings
• News and marketing information
• Corporate communications
• Other literature intended for public viewing.
• Terms and conditions
• Privacy Policy & PAIA Manual
• Career Communication Channel
• Management Team Member names and contact details
• B-informed platform (Coldcha log in portal)
• Website developer name

6. RECORDS AVAILABLE UNDER LEGISLATION

As required by Section 51(1)(d) of PAIA, the records are kept in accordance with the following current South African legislation, to the extent that the relevant Act is applicable, therefore making the disclosure and possibly retention of such records compulsory:

• Agricultural Product Standards Act, 1990
• Basic Conditions of Employment Act, 1997
• Broad-Based Black Economic Empowerment Act, 2003
• Businesses Act, 1991
• Companies Act, 2008
• Compensation for Occupational Injuries and Diseases Act, 1993
• Competition Act, 1998
• Constitution of the Republic of South Africa, 1996
• Consumer Protection Act, 2008
• Copyright Act, 1978
• Customs and Excise Act, 1964
• Cybercrimes Act, No 19 of 2020
• Electronic Communications Act, 2005
• Electronic Communications and Transactions Act, 2002
• Employment Equity Act, 1998
• Financial Intelligence Centre Act, 2001
• Financial Advisory and Intermediary Services Act, No 37 of 2002
• Financial Markets Act, 2012
• Harmful Business Practices Act, 1999
• Income Tax Act, 1962
• Insolvency Act, 1936
• Intellectual Property Laws Amendment Act, 1997
• Labour Relations Act, 1995
• Long Term Insurance Act, 1998
• Medical Schemes Act, 1998
• National Credit Act, 2008
• National Environment Management Act, 1998
• National Health Act, 2003
• Occupational Health and Safety Act, 1993
• Pension Funds Act, 1956
• Prescription Act, 1969
• Prevention of Organised Crime Act, 1998
• Protected Disclosures Act, 2000
• Protection of Personal Information Act, 2013
• Promotion of Access to Information Act, 2000
• Regulation of Interception of Communications and Provision of Communication – Related Information Act, 2002
• Short Term Insurance Act, 1998
• Skills Development Act, 1998
• Skills Development Levies Act, 1999
• Trademarks Act, 1993
• Unemployment Insurance Act, 2001
• Unemployment Insurance Contributions Act, 2002
• Value Added Tax Act, 1991

7. CATEGORIES OF RECORDS SUBJECT TO REQUEST

The organisation has the following categories of records on the subject matters referred to hereunder and for which a request for access needs to be made in terms of PAIA or the POPI Act. Recording a category or subject matter in this Manual does not imply that a request for access to such records would be granted. All access requests will be evaluated on a case-by-case basis under PAIA.

GENERAL INTERNAL AND OPERATIONAL RECORDS:

• Audit reports and compliance-related records
• Copies of the relevant trust deeds and rules
• Financial records
• Fixed assets register
• General administration records
• General and/or internal contracts and agreements
• General and/or internal correspondence
• Health and safety records
• Information technology, including computer software, support, and maintenance agreements
• Insurance records, including group life assurance and disability income protection insurance
• Intellectual property and trademarks
• Internal policies and procedures
• Internal reports and communications
• Investment records
• Leases
• Long-term share-based incentive schemes
• Marketing records
• Minute books and minutes of meetings
• Mission statement
• Operational records
• Presentations
• Provident fund records and rules
• Proxy forms
• Records of resolutions
• Records relating to the incorporation of the organisation, shareholder(s), and director(s)
• Risk management records
• Service records
• Share registration records
• Statutory records

FINANCIAL RECORDS:

• Accounting records
• Administrative records
• Annual financial statements and returns
• Asset registers
• Auditors' reports
• Consolidation records
• Copies of agreements
• Credit application forms
• Electronic banking records
• General and/or internal contracts and agreements
• General and/or internal correspondence
• Internal reports and communications
• Investment records
• Invoices
• Management accounts and reports
• PAYE records and returns, including IRP5's
• Policies & procedures
• Statements of account
• Statutory records
• Tax records and returns
• Terms & conditions
• Transactional records
• Treasury dealing and settlement records
• VAT records and returns
• Working files

EMPLOYEE RECORDS:

• Any personal records provided to the organisation by its current, past, or prospective employees
• Disciplinary and grievance procedures and hearings, including CCMA records
• Disciplinary records
• Confidentiality agreements
• Employment agreements
• Employee benefit records, Provident Fund, Group Risk, and medical aid (including information of minors)
• Employee tax records (IRP 5's)
• Employment equity records and statistics
• Employment policies and procedures
• Employee photos
• Employee ID
• Employee date of birth
• Employee banking details
• Employee contact numbers
• Employee home address
• Employee next of kin
• General and/or internal contracts and agreements
• General and/or internal correspondence
• Health and safety records
• Incentive scheme rules
• Internal evaluation
• Internal reports and communications
• Job descriptions
• Labour relations records
• Leave records
• Medical aid records
• Medical records
• Minutes of meetings
• Nominated beneficiaries iro SUF & SGR funds, including information of minors
• Payroll reports and payslips
• Pension and Provident fund rules
• Pension records
• Policies and procedures
• Probation evaluations
• Performance reviews
• Relevant contracts and agreements
• Salary records
• SETA records
• Skills development levies
• Skills development plan and report
• Standard terms and conditions of employment
• Statutory records
• Third-party records provided to the organisation about any of their current, past, or prospective employees
• Training records
• Traveling records
• UIF contributions records
• Work skills development plans
• Workmen's compensation documentation and claims

INFORMATION TECHNOLOGY RECORDS:

• Third party contracts and agreements
• Disaster recovery plans
• General and/or internal contracts and agreements
• General and/or internal correspondence
• Hardware
• Internal reports and communications
• IT asset registers
• IT policies, standards, procedures, and guidelines
• Operating systems
• Software packages and licence agreements

MARKETING AND COMMUNICATIONS RECORDS:

• Advertising and promotional material
• Brand information management
• Customer records
• General and/or internal contracts and agreements
• General and/or internal correspondence
• Internal reports and communications
• Marketing material and media releases: brochures, newsletters, and advertising materials
• Marketing and communications
• Press releases
• Proposals and new business development
• Terms & conditions

DAY-TO-DAY OPERATIONAL INFORMATION:

• Access control records
• Architectural drawings
• Archive and data and retention administration
• Client databases
• Company policies and procedures
• Customer and suppliers' information, contracts, and service levels
• Construction contracts
• Internal telephone and address lists
• Industry-related statistical data
• Insurance documentation
• Property information such as title deeds and/or lease agreements
• Patents and trademark documents
• Management Reports
• Third party agreements
• Travel and flight information and documentation

8. Record Request Process

Under Section 5(1)(b) of the Protection of Personal Information Act, 2013 of South Africa, a data subject has the right to establish whether a responsible party holds personal information on them and may request access to his, her, or its personal information as provided for in terms of section 23.

The data subject may exercise their right under Section 23 of the Protection of Personal Information Act, 2013 of South Africa, by completing"Form 02 Request for Access to Record of a Private Body."

The Form 2 Request for Access to Record of a Private Body can, at the time of publishing this policy, be located here: https://contourlogistics.com/pdf/InfoRegSA-PAIA-Form02-Reg7.pdf and as Appendix A to this Manual.

Any request for access to records should be submitted on the prescribed Form 02 (Appendix A), which should be sent to the Information Officer whose details are provided in this Manual.

All requesters should note that Form 02 must be completed by filling in all lines and spaces and that proof of identity must be submitted with the application.

Requests for information will be evaluated, and the requester will be notified within 30 days after receipt of the request in the prescribed format.

Requesters are advised that, in terms of PAIA, the 30 days mentioned above may be extended for a further period of not more than 30 days under certain circumstances.

If the organisation requires a data subject to pay a fee for services provided to the data subject to enable the organisation to respond to a request, the organisation will give the applicant a written estimate of the fee before providing the services and may require the applicant to pay a deposit for all or part of the fee.

When the organisation has responded to a request regarding access to personal information, the organisation shall, upon responding to the request, advise the data subject of their right to correct personal information.

9. Record Request Fees

The fees payable in respect of access to Records are attached as Appendix B.

10. Record Request Refusals

The organisation may and in some cases must withhold information if:

1. its disclosure would involve the unreasonable disclosure of personal information about a third party, including a deceased individual.
2. the record contains:
   1. trade secrets of a third party;
   2. financial, commercial, scientific, or technical information, other than trade secrets, of a third party, the disclosure of which would be likely to cause harm to the commercial or financial interests of that third party; or
   3. information supplied in confidence by a third party, the disclosure of which could reasonably be expected to:
      • put that third party at a disadvantage in contractual or other negotiations; or
      • prejudice that third party.
3. its disclosure would constitute an action for breach of a duty of confidence owed to a third party in terms of an agreement.
4. its disclosure could reasonably be expected to endanger the life or physical safety of an individual.
5. the record is privileged from production in legal proceedings unless the person entitled to the privilege has waived the privilege.
6. the record contains information about research being or to be carried out by or on behalf of a third party, the disclosure of which would be likely to expose:
   1. the third party;
   2. a person that is or will be carrying out the research on behalf of the third party; or
   3. the subject matter of the research, to serious disadvantage.

If the request for access is refused, reasons for the refusal will be provided. The requester will be advised that they may lodge an application with a court against the refusal of the request and the procedure for lodging the application.

11. Availability of Manual

This Manual is available for inspection, free of charge, at the organisation's offices and on its website.

Appendix A

https://inforegulator.org.za/wp-content/uploads/2020/07/InfoRegSA-PAIA-Form02-Reg7.pdf

Appendix B

https://contourlogistics.com/pdf/Appendix B_PAIA.pdf

Form 3

https://inforegulator.org.za/wp-content/uploads/2020/07/Form-3-PAIA.pdf