PROTECTION OF PERSONAL INFORMATION ACT (POPIA) MANUAL

(Prepared in accordance with Section 51 of the Promotion of Access to Information Act, 2 of 2000 ("PAIA"))
Effective Date: 2025

Introduction
Purpose of the Manual
Company Information
Information Officer
Available Records
Request Procedure (PAIA Access Requests)
Grounds for Refusal
POPIA Compliance Framework
Types of Personal Information Processed
Purpose for Processing Personal Information
Data Subject Rights
Security Measures
Information Sharing & Operators
Cross-Border Transfer of Information
Retention of Records
Direct Marketing
Complaints Procedure
Manual Availability
Appendices (Forms & Fees)

1. INTRODUCTION

The Protection of Personal Information Act, 4 of 2013 (POPIA) governs how private entities process, store, use, and share personal information.
The Promotion of Access to Information Act, 2 of 2000 (PAIA) enables individuals to request access to records held by private bodies, provided the correct procedures are followed.

This POPIA Manual explains how DWD Financial Planners (“the Company”) processes personal information, how data subjects may request access to information, and the measures implemented to ensure compliance with POPIA and PAIA.

2. PURPOSE OF THE MANUAL

This Manual aims to:

Provide the structure and process for anyone seeking access to records in terms of PAIA.
Describe the categories of information held by DWD Financial Planners.
Outline the Company's responsibilities under POPIA.
Provide clarity on the rights of clients, employees, service providers and other data subjects.
Demonstrate the Company’s commitment to protecting all personal information it processes.

3. COMPANY INFORMATION

Business Name: DWD Financial Planners
Registration Type: Financial Services Provider
FSP Number: 46313
Physical Address: 90 Vleiroos St, Winchester Hills, Johannesburg South, 2091
Phone: 083 783 3369
Email: info@dwdfinancialplanners.co.za
Website: www.dwdfinancialplanners.co.za

4. INFORMATION OFFICER

Information Officer: [Insert Name, e.g., “Denzil Williams” or appointed representative]
Deputy Information Officer: [If applicable]
Email: info@dwdfinancialplanners.co.za
Telephone: 083 783 3369
Postal Address: 90 Vleiroos St, Winchester Hills, Johannesburg South, 2091

Responsibilities include:

Ensuring POPIA compliance
Responding to PAIA access requests
Managing data breaches
Maintaining internal POPIA policies
Overseeing operator contracts

5. AVAILABLE RECORDS

The following categories of records may be held and accessed in terms of PAIA:

5.1 Internal Company Records

Company registration documents
FSP license information
Employment records
Operational policies and procedures
Internal manuals

5.2 Client Records

Financial planning information
FICA documentation
Investment and retirement planning details
Signed agreements, mandates & application forms
Risk profile assessments

5.3 Marketing Records

Opt-in databases
Communication consent records

5.4 Accounting Records

Invoices
Payment records
Tax documents

Access to any record is not guaranteed and will depend on whether a refusal ground applies.

6. REQUEST PROCEDURE (PAIA ACCESS REQUESTS)

To request access to records:

Complete Form 2 (Request for Access to Record).
Submit the completed form to the Information Officer via email or hand delivery.
Include proof of identity.
Pay the required request fee where applicable.
The Company will respond in writing within 30 days.

Email for Requests: info@dwdfinancialplanners.co.za

The requestor must:

State the right they wish to exercise or protect.
Explain why the requested record is required.

7. GROUNDS FOR REFUSAL

DWD Financial Planners may refuse access to information where:

It includes personal information of third parties
It contains confidential financial or proprietary information
It includes legally privileged information
It poses a risk to security measures
It is protected under a confidentiality agreement

All refusals will be supported by written reasons.

8. POPIA COMPLIANCE FRAMEWORK

DWD Financial Planners processes personal information in accordance with POPIA’s eight conditions:

Accountability
Processing Limitation
Purpose Specification
Further Processing Limitation
Information Quality
Openness
Security Safeguards
Data Subject Participation

Internal measures include:

Confidentiality agreements
Secure digital and physical storage
Access control
Employee POPIA training
Incident & breach response procedures

9. TYPES OF PERSONAL INFORMATION PROCESSED

Clients (Individuals & Employers)

Contact details
Identity documents
Financial information
Income & tax information
Retirement & investment details
Employment details
Medical/health information (when required for risk products)

Employees & Job Applicants

HR & payroll information
Qualifications & background checks

Suppliers & Business Partners

Banking details
Contractual information

DWD Financial Planners only collects and processes information necessary for legitimate financial services activities.

10. PURPOSE FOR PROCESSING PERSONAL INFORMATION

Information is processed for:

Providing financial planning and advisory services
Fulfilling FICA, FAIS and SARS regulatory obligations
Contractual obligations to clients or employees
Investment management and insurance product administration
Compliance and risk assessment
Direct marketing (client consent required)
Reporting to product providers and regulatory bodies

11. DATA SUBJECT RIGHTS

Under POPIA, data subjects have the right to:

Access their personal information
Request corrections or deletion
Object to processing
Withdraw consent
Lodge complaints
Not be subject to automated decision-making
Opt out of direct marketing

Requests must be made in writing to the Information Officer.

12. SECURITY MEASURES

DWD Financial Planners employs:

Secure cloud-based storage
Data encryption
Password-protected systems
Limited access based on role
Physical document security
Regular security audits
Secure destruction of outdated records

In the case of a data breach, affected parties and the Information Regulator will be notified.

13. INFORMATION SHARING & OPERATORS

Personal information may be shared with:

Financial product providers (insurers, investment platforms, retirement fund administrators)
Compliance officers
IT and cloud service providers
Auditors and regulators

All operators are contractually bound to POPIA compliance.

14. CROSS-BORDER TRANSFER OF INFORMATION

Information may be transferred outside South Africa where:

A product provider or platform is hosted abroad
A third-party system stores data internationally

Transfers occur only where:

The receiving country has adequate protection laws, or
Contractual protections are in place

15. RETENTION OF RECORDS

Information is retained:

5 years for FAIS/FICA client records
5 years for transactional and financial records
As long as required for legal or contractual purposes
Until the purpose for collection has been achieved

After retention periods lapse, records are securely destroyed or de-identified.

16. DIRECT MARKETING

DWD Financial Planners follows POPIA’s direct marketing requirements:

Consent is required for marketing to non-clients
Existing clients may be marketed similar services
Opt-out instructions are included in all communications

17. COMPLAINTS PROCEDURE

Complaints may be submitted to:

Information Officer

Email: info@dwdfinancialplanners.co.za

Information Regulator of South Africa

Email: complaints.IR@justice.gov.za
Website: www.inforegulator.org.za

18. MANUAL AVAILABILITY

This POPIA Manual is available:

On the Company’s website
At the DWD Financial Planners office
Upon request via email

19. APPENDICES

Appendix 1 — Form 2: PAIA Request for Access to Record

(We can insert or recreate your uploaded PDF Form 2.)

Appendix 2 — Applicable Fees (PAIA Private Bodies Fee Schedule)

Request fee: R140
Photocopies: R2.00 per page
Flash drive: R40 (if supplied by requester)
CD copy: R60
Audio transcription: R24 per A4 page
Search/preparation fee: R145 per hour (max R435)
Postage/email: actual cost