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(in accordance with section 51 of the Promotion of Access to Information Act No. 2 of 2000)

    Section 51 of the Act requires Private Bodies to compile a Manual setting out the procedure and requirements to be adhered to in seeking to obtain access to information held by that Private Body. The section also stipulates the minimum requirements a Manual has to comply with. To this end section 51 of PAIA requires the Manual to contain, amongst others, the following:

    • The postal and street address, phone and fax number and, if available, electronic mail address of the head of the body;

    •  Contact details of the Head of the Private Body;

    • Categories of information available without formal request, if any;

    • A description of the records available in accordance with other legislation;

    • Sufficient detail to facilitate a request for access to a record of the Private Body;

    • A description of the categories of subjects and of the information or categories of information;

    • A description of the subjects on which the body holds records and the categories of records held on each subject,

    •  Such other information as may be prescribed

     

    POPIA requirements pertaining to the processing of information

    Purpose of processing

    the Protection of Personal Information Act (PoPIA), Personal Information must be processed for a specified purpose. The purpose for which Personal Information is processed by Vodacom will depend on the nature of the Personal Information and the particular Data Subject. This purpose is ordinarily disclosed, explicitly or implicitly, at the time when Personal Information is collected.

    Access to Personal Information

    POPIA provides that a Data Subject may, upon proof of identity, request the Responsible Party 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. Further, POPIA provides that where the Data Subject is required to pay a fee for services provided to him/her, the Responsible Party must provide the Data Subject with a written estimate of the payable amount before providing the service and may require that the Data Subject pay a deposit for all or part of the fee.

    Categories of Data Subjects

    Vodacom holds information and records on the following categories of Data Subjects: a) employees / personnel of Vodacom; b) clients of Vodacom; c) any third parties and/or suppliers with whom Vodacom conducts its business services; d) contractors of Vodacom; e) partners and agents f) service providers of Vodacom.

    (This list of categories of Data Subjects is non-exhaustive)

    The categories of recipients to whom the information is supplied

    Depending on the nature of the Personal Information, Vodacom may supply information or records to the following categories of recipients: a) statutory oversight bodies, regulators, law enforcement agencies or judicial commissions of enquiry making a request for information; b) any court, administrative or judicial forum, arbitration, statutory commission, or ombudsman making a request for personal information or discovery in terms of the applicable rules (e.g the Information Regulator ); c) South African Revenue Services, or another similar authority; d) Emergency Service Organisations (if you make an emergency call), including your approximate location; e) anyone making a successful application for access in terms of PAIA; f) subject to the provisions of POPIA and the National Credit Act No. 34 of 2005, Vodacom may share information about a client's creditworthiness with any credit bureau or credit provider.

    Planned transborder flows of information

    If you are visiting our websites from a country other than South Africa the various communications will necessarily result in the transfer of information across international boundaries.

    Vodacom may also need to transfer your information to other Vodacom or Vodafone group of companies or service providers in countries outside South Africa, in which case we will fully comply with applicable data protection legislation. This may happen if our servers or suppliers and service providers are based outside South Africa, or if our services are hosted in systems or servers in Vodafone Operating Companies outside South Africa including Europe or India and/or if you use our services and products while visiting countries outside this areas. Other countries outside South Africa may not have data protection laws which are similar to those of South Africa, however, Vodacom will ensure that your Personal Information is protected and enter into appropriate agreements to achieve this.

    Security measures implemented to ensure the confidentiality and privacy of the information which is to be processed

    Vodacom is committed to implementing leading data security safeguards. For this reason, Vodacom has specialised security teams who constantly review and improve its measures to protect your Personal Information from unauthorised access, accidental loss, disclosure or destruction.

    If Vodacom has an agreement with another organisation to provide it with services or a service on its behalf to process your Personal Information, then Vodacom will make sure they have appropriate security measures and only process your Personal Information in the way we have authorised them to. These organisations will not be entitled to use your Personal Information for their own purposes. If necessary, our security teams will conduct a due diligence them to make sure they meet the security requirements we have set.

    Communications over the internet (such as emails) are not secure unless they have been encrypted. Further, your communications may go through a number of countries before being delivered, as this is the nature of the internet. Consequently, we cannot accept responsibility for any unauthorised access or loss of Personal Information that is beyond our control.

    The following words  shall bear the same meaning as under PoPIA:

    "Act/PAIA" means the Promotion of Access to Information Act No. 2 of 2000

    "Data Subject"  means the person to whom Personal Information relates

    "Information Officer" means the head of Vodacom as contemplated in section 1 of PoPIA

    "Minister" means the Minister of Justice and Correctional Services

    "Personal information"  means information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person including:

    • 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 or other particular assignment to the person;

    • the blood type or any other 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

    "PoPIA" means Protection of Personal Information Act, Act No 4 of 2013

     "Private body" means a natural person who carries or has carried on any trade, business or profession in that capacity, a partnership or juristic person

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

    • the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use;

    • dissemination by means of transmission, distribution or making available in    any other form; or

    • merging, linking, as well as blocking, degradation, erasure or destruction of information;

     "Public body" means any department of state or administration in the national, provincial or local sphere of government or functionary exercising pubic power or exercising public function in terms of any legislation;

    "Responsible party"  means a public or private body or any other person which, alone or in conjunction with others, determines the purpose of and means for processing Personal Information;

    "Requester" in relation to -

    • a public body, means any person making a request for access to a record of that public body (or authorised representative);

    • a private body, means  any person, including, but not limited to, a public body or an official thereof, making a request for access to a record of that private body  (or authorised representative).

    Vodacom is a leading African communications company providing a wide range of communication services, including mobile voice, messaging, data, financial and converged services to over 103 million (including Safaricom) customers. With its roots in South Africa, Vodacom has grown its mobile network business to include operations in Tanzania, the DRC, Mozambique, Lesotho and Kenya. Vodacom's mobile networks cover a population of over 284 million people. Through Vodacom Business Africa (VBA), we offer business managed services to enterprises in 32 countries. Vodacom is listed on the JSE Limited.

    Vodacom is majority owned by Vodafone Group Plc, one of the world's largest mobile communications companies by revenue. As such Vodacom is bound by and adheres to Vodafone Group Privacy Commitments.

    To confirm whose particulars to be included, in particular, telephone, email and fax

    Company Registration:

    Vodacom Group Limited

    Vodacom (Pty) Ltd  

    1993/005461/06

    1993/003367/07

    Chief Executive Officer & Managing Director

    Shameel Joosub

    Privacy & Information Officer

    Mpumi Simelane

    Street Address

    082 Vodacom Boulevard

    Vodacom Valley

    Midrand

    1685

    Postal Address

    Private Bag X9904

    Sandton

    2146

    Telephone

    011 653

    Website

    www.vodacom.co.za

    www.vodacom.com

    E mail

    [email protected]

    The information held by Vodacom has been divided into different categories grouped into twelve subjects, each of which describes a single business unit, for example, "Human Resources". For ease of understanding and navigation, an additional level has been added between the "subject" and "category" levels. This additional level describes more accurately the sub-set of categories that falls under it. For example, under the additional level, the subject "Performance and Remuneration" is made up of information categories describing payroll, bonus and incentives, and employee performance information.

    The categories of information are not exhaustive but are merely meant to give a broad indication of the information subject and categories held by Vodacom, without specification. A category may therefore contain sub-categories and sub-sets of information, which are not specifically listed. (For purposes of the list of records and information held by Vodacom see Appendix A: Categories and Types of Information).

    Purpose of processing

    In terms of POPIA, personal information must be processed for a specified purpose. The purpose for which personal information is processed by Vodacom will depend on the nature of the personal information and the particular data subject. This purpose is ordinarily disclosed, explicitly or implicitly, at the time the personal information is collected.

    Access to personal information

    POPIA provides that a data subject may, upon proof of identity, request the responsible party 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 also provides that where the data subject is required to pay a fee for services provided to him/her, the responsible party must provide the data subject with a written estimate of the payable amount before providing the service and may require that the Requestor pay a deposit for all or part of the fee.

    Categories of data subjects

    Vodacom holds information and records on the following categories of data subjects:

    • employees / personnel of Vodacom;

    • any third party with whom Vodacom conducts its business services;

    • contractors of Vodacom;

    • suppliers of Vodacom; and

    • service providers of Vodacom.

    (This list of categories of data subjects is non-exhaustive.)

    The categories of recipients to whom the information is supplied

    Depending on the nature of the Personal Information, Vodacom 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 (i.e. the Competition Commission in terms of the Competition Act No. 89 of 1998);

    •  South African Revenue Services, or another similar authority;

    •  anyone making a successful application for access in terms of PAIA; and

    •  subject to the provisions of POPIA and the National Credit Act No. 34 of 2005, Vodacom 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 Vodacom operates.

    Planned transborder flows of  information -

    If you are visiting our websites from a country other than the country in which our servers are located, the various communications will necessarily result in the transfer of information across international boundaries.

    We may need to transfer your information to other Vodacom or Vodafone group companies or service providers in countries outside South Africa, in which case we will fully comply with applicable data protection legislation. This may happen if our servers or suppliers and service providers are based outside South Africa, or if our services are hosted in systems or servers in Vodafone Operating Companies outside South Africa including Europe or India and/or if you use our services and products while visiting countries outside this area. These countries may not have data-protection laws which are similar to those of South Africa.

    Security measures implemented to ensure the confidentiality and privacy of the information which is to be processed -

    We are committed to implementing leading data security safeguards.

    We have specialised security teams who constantly review and improve our measures to protect your personal information from unauthorised access, accidental loss, disclosure or destruction.

    If we have a contract with another organisation to provide us with services or a service on our behalf to process your personal information, we will make sure they have appropriate security measures and only process your information in the way we have authorised them to. These organisations won't be entitled to use your personal information for their own purposes. If necessary, our security teams will check them to make sure they meet the security requirements we have set.

    Communications over the internet (such as emails) are not secure unless they've been encrypted. Your communications may go through a number of countries before being delivered - as this is the nature of the internet. We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.

    In order to ensure that Vodacom complies with the Act, management has designated Vodacom Customer Care as the only entry point through which any request in terms of the Act must be channeled.

    All requests in terms of the Act must be addressed to:

    VODACOM CUSTOMER CARE

    Physical Address

    Vodacom Customer Care

    082 Vodacom Boulevard, Vodacom Valley, Midrand, 1685                                                                  

    Postal Address

    Vodacom Customer Care

    Private Bag X9904, Sandton, 2146

    Other

    Telephone: (082) 135

    Electronic mail: [email protected] / [email protected]

    1. The purpose for which Information is required

      The Act provides that a person may only request information in terms thereof if that information is required for the exercise or protection of a right.

      Further, PoPIA provides that a Data Subject may, upon proof of identity, request the Responsible Party 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, and may, where necessary, request the correction, destruction or deletion of his or her personal information.  PoPIA further provides that where the Data Subject is required to pay a fee for services provided to him/her/it the Responsible Party:

      • Must provide the Data Subject with a written estimate of the payable amount before providing the service; and

      • May require that the requestor pay a deposit for all or part of the fee  

    2. Categories of Requestors

      The capacity under which a Requester requests documentation/ information will determine the category he or she falls in. Please note that the Requester category has a bearing on the conditions of access to the information.

      Requesters have been classified into four categories:

      • A Personal Requester: requests information about himself/herself/itself.

      • A Representative Requester: requests information relating to and on behalf of someone else.

      • A Third Party Requester: requests information about another person.

      • A Public Body: requests information in the public interest. 

    3. Third party notifications

      Where the records requested relates to third parties the Information Officer will take all reasonable steps to inform a third party to whom or which the record relates of the request. The third party will be informed as soon as reasonably possible, but within 21 days after that request is received and by the fastest means reasonably possible. When informing the third party about the information request the Information Officer will:

      • inform the third party that he or she is considering a request for access to its records and describe the content of the record;

      • furnish the name of the requester;

      • describe the type of information in question;

      • if the disclosure is in the public interest, describe circumstances under which the disclosure is made

      • inform the third party that it may, within 21 days after the third party is informed:

        • make written or oral representations to the head why the request for access should be refused; or

    1. Completion of Form C

      Any request for information in terms of the Act must be submitted in terms of Form C (a copy of the form is enclosed as Annexure B hereto). These forms are available on request from Vodacom Customer Care and upon payment of a prescribed fee. The forms can also be downloaded from www.vodacom.co.za / www.vodacom.com.

      Form C must be completed in full and returned to Vodacom Customer Care at the address referred to in paragraph 6 above as soon as reasonably possible together with any other information that may be required in order to consider and decide on the request. A request which does not comply with the formalities contained in this Manual will be referred back to the Requester with advice on the necessary steps for compliance. This includes Forms that are not completed in full.

      The Affidavit contained in Form C must also be completed in full and signed by a Commissioner of Oaths,

    2. Proof of identity

      Proof of identity is required to authenticate the request and the Requester. In view hereof, a Requester will, in addition to Form C, be required to submit acceptable proof of identity such as a certified copy of their Identity Document or other legal form of identification.

    3. Vodacom Products

      In instances where information or records pertaining to any of Vodacom's products (other than marketing information) is requested, the Requester will have to prove ownership of the MSISDN (Mobile Station International Subscriber Directory Number) to which the requested information or records relate. The Requestor may also be required to provide further particulars to prove ownership or to provide an explanation why access to the identified records is required.

      Note: Information will not be furnished unless a person clearly provides sufficient particulars to enable the company to identify the right the Requester is seeking to protect as well as an explanation of why the requested information is required for the exercise or protection of that right.

    4. Checklist for submission of information requests  

      Form C

      • Number B - particulars of person requesting access to the records

      • Number C - only if the request is a third party request

      • Number D1 - the time period as well as type of information required

      • Number D2 - the cell number or ref. number that was provided by Vodacom (if available)

      • Number E - exemption from paying the fees, if so the client will need to supply his/her salary advice and if the client is married, a copy of the spouse’s salary advice will need to be supplied as well

      • Number F1 - copy in a computer readable form (memory stick or compact disc)

      • Number G1 - indicate which right is to be exercised or protected

      • Number G2 - the reason for which this information is required (we will not accept ‘personal reasons’ as a reason)

      • Number H - preferred method of communication

      • Documentation signed and every page must be initialed.

      Affidavit

      • Number 3 - choose a, b or c

      • Number 6 - choose a, b or c

      • Number 7 - only in the case of a Third Party request

      • The affidavit must be commissioned by a Commissioner of Oath (eg SAPS or Notary).

      • NB the following information must also be attached:

      • A certified copy of your identity document. Please also initial the identity document.

      • For pre-paid clients. A Vodacom prepaid certificate, if available. This must also be initialed.

      • Contract clients must supply a copy of their latest Vodacom statement. This must also be initialed.

      • If it is a company owned contract, a letter from the company providing permission for the release of this information must be provided.

    In terms of POPIA, a data subject has the right to request Vodacom to confirm, free of charge, whether or not it holds personal information about the data subject. However, both in terms of PAIA and PoPIA, Vodacom is entitled to levy a prescribed fee (as set out below) for the provision of records of personal information about the data subject or third parties in its possession.

    The fees that may be charged have been published by the Minister of Justice and Correctional Services and are displayed below.

    1.  ACCESS FEES FOR REPRODUCTION

      1.1

    For every photocopy of an A4-size page or part thereof R1.10
    1.2 For every photocopy of an A4-size page or part thereof held on a computer or in electronic or machine-readable form R0.75
    1.3 For a copy in a computer-readable form on memory stick R7.50
    1.4 For a copy in a computer-readable form on compact disc R70.00
    1.5 For a transcription of visual images for an A4-size page or part thereof R40.00
    1.6 For a copy of visual images R60.00
    1.7 For a transcription of an audio record for an A4-size page or part thereof R20.00
    1.8 For a copy of an audio record R30.00
    2. ACCESS FEE FOR TIME SPENT
    2.1 The time reasonably required to search for the record for disclosure and preparation R30.00/hr or part thereof
    3. REQUEST FEE
    3.1 For a request for access to a record by a person other than a personal Requestor R50.00
    4. DEPOSIT
    4.1  
    5. POSTAL FEE
    5.1 When a copy of a record must be posted to the Requestor R9.75
    6. APPEAL FEES
    6.1 For lodging an internal appeal against the refusal of a request for access to a record R50.00
    7. VAT
    7.1 Vodacom, as a private body registered under the Value Added Tax Act, 1991 will add VAT to all the above-mentioned fees  

    All requests complying with the requirements set out above will be processed and considered expeditiously.

    If the request for access is granted then Vodacom will advise the Requestor on the following:

    • the prescribed fee for accessing the information or documentation

    • payable deposit fee and balance outstanding

    • the form in which access will be given

    • the right to lodge an internal appeal against the access fee to be paid or the form of access to be granted.

    If the request for access is refused then Vodacom will advise the Requestor about the reasons for refusal of access and may advice the Requestor to lodge an application with the Information Regulator against the refusal of the request after the Requestor has exhausted all Vodacom's internal appeal process. 

    Chapter 4 of the PAIA Act stipulates the following grounds for refusing requests for information:

    • protection of the privacy of a third party who is a natural person 

    • protection of commercial information of a third party 

    • protection of certain confidential information of a third party 

    • protection of safety of individuals and protection of property

    • protection of records privileged from production in legal proceedings 

    • commercial information of the Private Body

    • protection of research information of a third party and of the Private Body.

    These grounds of refusal are also endorsed under PoPIA.

    Vodacom will give the Requester a written notice of the decision within 30 days after the decision is made. In case of a request being refused, the notification will include the reasons for the refusal. Vodacom may extend the 30 day notice period for a further period not exceeding 30 days due to the nature of the request and the amount of time required to gather the requested information. The Requester will however be given notice of the extension prior to the expiry of the 30 day period and provided with reasons for the extention.

    The Act makes provision for the lodgment of complaint against:

    • Access fee charged or the form of access granted

    • Refusal of the request to grant access

    • Decision to extend the 30 days' period for granting the requested access

    • Form in which access is granted

    A complaint or an internal appeal must:

    • be lodged within 30 days after the decision is communicated to the Requestor;

    • be delivered or sent to the address, fax or electronic mail address contained in paragraph 6 above;

    • identify the subject of the complaint or internal appeal and state the reasons for the complaint or internal appeal;  

    • be accompanied by the prescribed appeal fee as prescribed in paragraph 10 above;

    • specify a postal address, fax number or electronic mail for the return of the decision. 

    (see Annexure D for the copy of the form to be used in lodging the internal appeal)

    Where, in addition to a written reply, the complainant/appellant wishes to be informed of the decision in any other manner he/she/it must state that manner and provide the necessary particulars to be so informed. 

    The complainant/appellant who is not happy with the decision of the internal process may lodge an application with the Information Regulator  against the decision made within 30 days after the decision was communicated to him/her/it. 

    Where the complaint or internal appeal is lodged after the expiry of the 30 days period the Information Officer may, on good cause shown, allow the late lodgment of the complaint or internal appeal.

    Section 51(1)(f) of the Act grants the Minister powers to publish a notice prescribing any other information that companies will have to disclose.

    As provided for in terms of section 51(2) of PAIA this Manual will be updated as and when the need arises and as soon as any amendments have been finalized the latest version of the Manual will be made public through:

    The Vodacom website: www.vodacom.co.za / www.vodacom.com

    Alternatively, on request from:

    The Information Officer

    Vodacom Group Ltd

    082 Vodacom Boulevard

    Vodavalley Midrand

    1685

    Email: [email protected] ;

    This Manual is available for inspection during office hours and at no charge. Should you wish to obtain a copy of this Manual or part thereto such copy can be obtained from either:

    the address set out above subject to payment of applicable fees (refer to clause 9 above); or

    downloaded from our website free of charge.

    1.1 Categories and type of records automatically available without having to request access to these records (Section 52(2) of  PAIA  read with regulation 9A to the PAIA ): Web and Magazine Content

    The PAIA makes provision for the automatic disclosure of certain records. These records need not be formally requested from Vodacom since they are automatically available from our website www.vodacom.co.za / www.vodacom.com

    The following are categories of records automatically available:

    Description  of category of records automatically available in terms of section 52(1)(a) of the PAIA Act Manner of access to records (Section 52(1)(b)
    For inspection in terms of section 52(1)(a)(i)  
    Product Information Soft copy/website
    Public Customer Information Softcopy
    Registers Softcopy
    For copying in terms of section 52(1)(a)(ii)  
    Annual Reports Soft copy/website
    Financial Statements Soft copy/website
    Available free of charge in terms of section 52(1)(a)(iii)
    Media Releases Website/Soft copy

    1.2 Categories and types of records that can be requested (section 51(1)(e) of the PAIA): 

    Vodacom maintains the types and categories of records as listed below. Each request for information will be dealt with on a case by case basis and the mere fact that a record is listed below does not mean that access to that record will be granted.

    The following are categories of records that can be requested from Vodacom:

    Business partners

    Information Category

    Business partners

    Information Category

    Information Category Information Category Description
    Commercial agreement with business partners This is the document, which records the agreement with the business partner, and is the output of contractual negotiations undertaken previously. It is co-owned by the business unit(s) involved and Legal Affairs Department.
    Contractual issues with Business Partners

    Corporate Social Investment

    Information Category

    Information Category Information Category Description
    Corporate Social Investment - Application for Funding This details all Corporate Social Investment applications received for funding by Vodacom Foundation.
    Corporate Social Investment - Projects Details of the projects that have been approved and are underway.
    Corporate Social Investment - Vodacom response The information relating to process of approval or rejection of the applications received for Corporate Social Investment.

    External Communication

    Information Category Information Category Description
    External Publication All publications for external bodies, includes all press clippings
    Press Release/Communiqué Issuing of media statements, press releases, official speeches etc.
    Web and Magazine Content Content available on Vodacom internet sites (for e.g. vodacom.net) and magazines (for e.g. Vodaworld Magazine) as well as at POS (Point of Sale) Kiosks (e.g. at Vodaworld).

    Government Protocol

    Information Category Information Category Description
    South African Government structure Details of the structure and holders of the South African government
    South African Parliament structure Details of the structure and holders of the South African parliament
    Visiting Foreign Governments structure Details of the positions held by foreign government visitors to South Africa
    Information Category Information Category Description
    Finalised litigation Litigation that has been concluded by court process or mutual consent

    Management

    Information Category Information Category Description
    Board reports & meeting minutes Reports prepared for the board meetings, and the subsequent minutes recording these meetings.
    Project Activity and Schedule Details of projects (tasks, resources, dependencies, durations, etc.)
    Project Lifecycle and Macro Plan Information This records the status and overarching objectives of the project.  Project planning is undertaken according to the "Manage by Project" standard and all projects are registered in a project register.

    Regulatory

    Information Category Information Category Description
    Compliance certification Compliance to international standards such as ISO9000 and COBIT
    Compliance to license
    Policies and procedures The documented policies and procedures of Vodacom's business processes and practices, for example relating to customer complaints

    Regulatory Submissions

    Information Category Information Category Description
    Draft Legislations, Draft Regulations, Policy Directives Information regarding Vodacom’s position on  draft legislation, regulations and policy directives

    VIP events

    Information Category Information Category Description
    VIP event management  Vodacom Events with business partners and other third parties and including staff functions of a high profile.

    Customer Information

    Information Category Information Category Description
    Customer Contract Details Contract customer details received during application process
    Customer Credit Checking Criteria and results of the credit checking process for customers requiring a contract
    Customer Detail All other customer details recorded during customer creation process, which are not covered by information categories Customer Contract Details and Customer Credit Checking, and including customer preferences.
    Customer passwords & identification Passwords, for e.g. PIN and PUK, and identification required for release
    Customer Profile Information relating to the customer profile, for e.g. which services are activated
    Customer Type Information relating to the customer type, for e.g. type of tariff plan.
    Loyalty Award Information relating to awards given to loyal customers.
    Number and growth of subscribers The count of active subscribers and prepaid customers as measured at a certain period, and the growth this reflects.
    Payment History Information relating to payments made.
    Subscriber demographics The subset of customer information which describes the demographic information of that subscriber.

    Customer Management

    Information Category Information Category Description
    Call Centre Call Data The details of calls handled by the call centre (call centre agent, time, duration, query, etc.)
    Customer Complaint Details of specific customer complaints which are (or have been) communicated to the Advertising Standards Authority, ICASA and the National Consumer Commission.
    Customer Frequently Asked Questions (FAQ) database Information on the most frequently asked questions
    Customer Inquiry Details of general customer inquiries
    Customer Service Request The recording of an issue raised by a customer which requires attention.
    Outbound Response Information relating to responses communicated to customers
    VIP customer complaints The complaints of customers categorised as VIP customers

    Distribution Channel Management

    Information Category Information Category Description
    Dealer Competitive Information Information relating to the market conditions and environment for dealers
    Dealer Promotion Information relating to dealer promotions (type of handset, price, conditions etc.)
    Field Marketing Executive (FME) Visit Information relating to the visit of a FME (to a dealer)

    Distribution Channel Structure

    Information Category Information Category Description
    Community Services' dealer commission The commission paid to Community Services' dealers
    Community Services Phone Shop / Container Information on Community Services phone shops (type, location, number of, size of, etc.)
    Dealer Dealer information
    Franchise vetting The criteria and results of the credit checking process for franchisees
    ranchisee Franchisee information
    Independent Service Provider Information about Service Providers who are independent of Vodacom Group (dual SPs)
    Outlet Information about the outlet (location, size, type, etc.)
    Retailer Retailer information
    Sales Cluster The geographic area within South Africa in which a sale took place

    Accounting

    Information Category Information Category Description
    Budget Budget information (amount, code, responsibility)
    Cash / Bank Transaction Information generated by a financial transaction as a result of the flow of information to or from Vodacom
    Creditor Creditor information (name, amount, status, etc.)
    Debtor Debtor information (name, amount, status, etc.)
    Electricity bill payment Specific information generated with respect to the electricity consumed by Vodacom GSM network element devices installed on sites not owned by Vodacom, as well as electricity consumed in Vodacom's administrative buildings.
    Financial transactions Information generated by a financial transaction
    General Ledger Account General Ledger Account information (code, name, responsibility)
    General Ledger Account General Ledger Account information (code, name, responsibility)
    Payment terms The details of payment terms with creditors and debtors
    Property rental value The rental paid / due from Vodacom sites
    Vodacom Invoice Invoices from Vodacom to debtors

    Asset

    Information Category Information Category Description
    Asset All assets, including the financial aspect of IT or GSM equipment

    Financial Performance

    Information Category Information Category Description
    Financial Management Statistics The description, definition and measurement of financial metrics which measures the financial performance of the organisation and which are reported in the monthly management report
    Financial Target The planned goal of a financial metric (for example "Earnings before Income Tax, Depreciation and Amortisation")

    Wholesale Bill

    Information Category Information Category Description
    3rd Party Contract Wholesale Bill Wholesale Billing information prepared related to contract customers' revenue, forwarded as invoices to Service Providers
    3rd Party Interconnect Bill Billing information prepared for third party network operators related to calls which originated and/or terminated on their networks, also presented as invoices
    3rd Party Prepaid Wholesale Bill Wholesale Billing information related to prepaid customers' revenue forwarded as invoices to Service Providers (for connection bonus purposes).

     

    GSM Device Site

    Information Category Information Category Description
    Environmental Impact Assessment results Information relating to Environmental Impact Assessments
    Environmental standards The environmental standards within which Vodacom needs to construct sites (for example cellular masts).
    Site Detail Details of the site of a Vodacom GSM network element
    Site Maintenance Information relating to site maintenance
    Site Rollout Planned and Actual This information is available regionally and nationally as part of the regional Project Management Work Order documentation. Available in hard copy format or software format.

    GSM Network and IT Configuration

    Information Category Information Category Description
    Actual and Planned Coverage The areas of South Africa where coverage on the Vodacom network is received
    GSM & Information Technology (IT) Network Device This is any device on either the GSM or IT network.  Examples are MSC / BSC / cell for GSM and server / PC / software for IT network.
    GSM Network Equipment Configuration The (initial) configuration and setup of GSM network equipment
    Handset Detail Details on handset (Make, model, settings etc.)
    Information Technology (IT) Equipment Change History Details of changes performed on Information Technology equipment
    Information Technology (IT) Equipment Configuration The (initial) configuration and setup of Information Technology equipment
    Information Technology (IT) Performance Data
    Internal e-mail - content and parties Includes internet email originating from or terminating with Vodacom
    Voice Mail Configuration The (initial) configuration and setup of voicemail equipment

    GSM Network and IT Statistics

    Information Category Information Category Description
    GSM Network Capacity and Throughput Data
    GSM Network Performance Data
    GSM Network Quality Indicator Definitions and measurements of the quality of the network (for example number of dropped calls %)
    GSM Network Test Result Results of GSM network tests
    Information Technology (IT) Capacity and Throughput Data The measurement of IT equipment's performance.
    Raw GSM Network Statistics The unprocessed data relating to measurement of the GSM network
    Transmission Performance

    Technical Alarm / Event

    Information Category Information Category Description
    GSM Network Alarm and Event The information relating to an alarm, which is generated, alerting support personnel to a failure (or possible failure) of an element or elements in the GSM network.
    GSM Network Equipment Fault History The history of faults and resolutions relating to items of IT equipment
    Information Technology (IT) Alarm and Event The information relating to an alarm, which is generated, alerting support personnel to a failure (or possible failure) of an element or elements in the IT network.
    Information Technology (IT) Equipment Fault History The history of faults and resolutions relating to items of IT equipment

    Internal Communication

    Information Category Information Category Description
    Internal Communiqué The information contained within any internal communication, via email or physical (paper) distribution. Examples are e-mail, Yeboflash and Vodacom Express.
    Policy and Procedure Tracking and Documentation The dissemination and implementation of policy and procedure information
    Reference Material Reference material used in internal communications
    Research Material Research material used in internal communications

    Organisation Structure and Position

    Information Category Information Category Description
    Archive of Senior Management Photographs Photographs of senior management
    Job Profiling The categorisation of responsibilities associated with an employment position
    Organisational Structure The structure of the organisation into business units, commonly depicted in an organogram.  This usually includes the top "n" levels of an organisation, for example the executive directors, name of departments reporting into their business units and position.
    Position The title and responsibilities of employment positions, including information related to the role and current incumbents.  This includes information on contractors and other non-permanent staff members.

    Performance and Remuneration

    Information Category Information Category Description
    Employee Performance Record The records relating to the employee performance, for example performance awards
    Employee Timesheet Information The records relating to the working hours' availability of an employee
    Payroll
    Salary/Incentive/Bonus

    Personnel Detail

    Information Category Information Category Description
    Curriculum Vitae (CV) and Application Detail Details of applicants for employment, including CV details
    Disciplinary Record Records of disciplinaries, for example, person, reason, status
    Employee Lifecycle Information The information about an employee "life" at Vodacom, i.e. when joined, promoted, positions held etc.
    Employee Personal Detail Personal details kept on employees, for example, next of kin

    Personnel Development

    Information Category Information Category Description
    Employee Promotion criteria The criteria for promotion
    Skill Level The skills required for positions
    Training Event / Course Details of training courses available and held

    Facility

    Information Category Information Category Description
    Bookings & appointments Details of bookings for infrastructure elements, for example parking for visitors or video conference facilities
    Facility/Security Access Record Records of access to buildings by individuals
    Loan Item Items loaned to employees, for example training material
    Office Layout and Maintenance Details on office layout and maintenance performed, for example air-conditioning maintenance

    Audit Information

    Information Category Information Category Description
    Service Level Agreement The details of service levels agreed between two parties
    Service Level Rating The measurement of a service level's performance.
    Supplier and Partner Contract/Agreement The contract between a supplier and/or a business partner.

    Contract/SLA Management

    Information Category Information Category Description
    Service Level Agreement The details of service levels agreed between two parties.
    Service Level Rating The measurement of a service level's performance.
    Supplier and Partner Contract/Agreement The contract between a supplier and/or a business partner.

    Inventory Control

    Information Category Information Category Description
    Stock The physical items required to be distributed throughout Vodacom, for example, SIM cards and Handsets distributed to the distribution channel outlets or the stock of equipment to upgrade the radio network stored in a warehouse distributed to the Network Operations' units.

    Procurement

    Information Category Information Category Description
    Information Service Provider The information about an information service provider
    Manufacturer
    Procurement decisions
    Request for Information (RFI) Details contained within a request for information document, for example services and deliverables required
    Statement of Work
    Supplier Details relating to Supplier for example, registered name, banking details, status
    Supplier demographics Demographics of suppliers, with specific attention to the Historically Disadvantaged Individual (HDI) indicators
    Supplier Invoice
    Vodacom Purchase Order

    Production

    Information Category Information Category Description
    Operator Schedule Details of Production and operators' schedules.
    Production Capacity and Throughput Details of maximum production capability and current measurement of production.
    Production Schedule Details of scheduled production.

    Product/Service Management

    Information Category Information Category Description
    Bearer Service A bearer service is a basic service that provides the capabilities for the transmission of information between user-network interfaces.
    Brand promotion Information about promotions on Vodacom brands, including venue, date, format, leaflets, competition entry forms.
    Brand tracking & research Research and measurement of Vodacom's brands, done formally quarterly.
    Price List (wholesale and retail) Details of the available tariff plans, including prices, bundled minutes, services available etc
    Product Configuration Covered in the TAPCM, tariff and product configuration management, which covers product planning, designing, packaging, technical development and supply for a product, for example "Starter Pack Vodago".
    Product Launch
    Product Life Cycle The product life cycle is a sequence of stages (status) a product moves through from inception to decommissioning
    Product Package & Media
    Product Performance Information The metrics and performance of products
    Product Specification The specifications of a product
    Sponsorships Information about the sponsorships Vodacom is involved with which leverage the brand.  These include Sport, cultural, CSR and broadcast.
    Value Added Service The information about value added services, for example voicemail.

    Retail Sale

    Information Category Information Category Description
    Customer Delivery Information generated during a delivery of an item to a customer, for example delivery address of an upgrade handset
    Customer Order Information on a customer order
    Point of Sale (POS) Merchandising material All consumer educational literature, including leaflets, posters, in-kiosk branding, material from sponsorship properties such as Idols, Super 15 etc.

    Sales Management

    Information Category Information Category Description
    Advertisements and Promotions
    Commission Information on the commission a distribution channel receives for customer transactions, which may be a new subscription or usage.
    Incentive and Target Information on the incentives and targets a distribution channel receives for customer transactions, which may be a new subscription or usage.
    Sales Figure and Target Information on the actual sales as well as the target sales figures for the distribution channels

    Wholesale Sales & Distribution

    Information Category Information Category Description
    Dispatch The information generated during the dispatch of goods to the distribution channel.
    Wholesale Order (SIM card/Voucher) Information on the orders received from distribution channel for SIM cards and vouchers.

    Fault

    Information Category Information Category Description
    Diagnostic Support Information The information generated by the diagnostic tests done on a faulty network element.
    Trouble Ticket Information on the faults logged (manually or automatically) for example date and time logged, element involved, type of problem. Also known as a service request.
    Trouble Ticket Resolution Information on the resolution of a trouble ticket, for example, time resolved.
    Works Order The information on planned engineering activity to network elements in order to install, maintain or upgrade it.

    Service Event

    Information Category Information Category Description
    Credit Card Recharge Transaction The information generated during a credit card recharge transaction, for example date, amount.
    Provisioning Command (recharge event) The information created during a recharge event, which is disseminated throughout the GSM network.
    Recharge Transaction The information generated during a non-credit card recharge transaction, for example date, and amount.
    Service Event Information
    Subscription Item Activity Information on activities (or events), which are related to the subscription, for example, SIM swap.

    Service Profile

    Information Category Information Category Description
    Procedures & policies with regard to stolen phones The information on the specific procedures and policies relating to the recording or handling of stolen phones.
    Suspected Fraud Alert The information on alerts, which are triggered when fraud is suspected.

    Usage Event

    Information Category Information Category Description
    Call Data (Rated) The information on call data which has been rated, i.e. billed according to the defined rules for the tariff which includes factors such as duration, time of day, called party, etc.
    GPRS Event Record The information generated during a GPRS event.
    Short Message Service (SMS) Event Record The information generated during an SMS event, for example, date and time, number SMS'ed etc.
    Traffic info The information generated by aggregated traffic
    Voice Mail Event Record The information generated during a voicemail event, for example voicemail box, date, time, message etc.

    Risk Management

    Information Category Information Category Description
    Biometric Information Information that personally identifies the customer/employee/third party/business partner based on physical or behavioral characterization including blood type, fingerprint, DNA Analysis, retinal scanning and voice recognition 

    1.3 Access to records held by Vodacom

    The following procedure must be followed when requesting information and/or documents:

    1. i) The request must be sent in the prescribed form. (The form can be downloaded from Vodacom's website at www.vodacom.co.za / www.vodacom.com).  
    2. ii) The Request must be submitted to the Information Officer and sent to the address, fax number or electronic mail address as set out in paragraph 6 of the Manual.
    3. iii) The Requestor must provide proof of identity of the person requesting the record
    4. iv) If the request is made on behalf of another person, the Requestor must provide proof of the capacity in which he/she/it is making the request.

     

    1.4 The following procedure will be followed by Vodacom after receipt of the request for access:

    1. a) Once a request is made, the Requestor will receive notice from Vodacom to pay the prescribed deposit fee
    2. b) The prescribed deposit fee must be paid before the request is processed
    3. c) Payment of this fee should be made as directed by the Information Officer
    4. d) After receiving payment of a deposit fee Vodacom will then make a decision in respect of the request and will notify the Requestor of the decision
    5. e) Should the request be refused, the Requestor may lodge an application or appeal in accordance with paragraph 11 of the Manual  against the refusal of the request or payment of the requested fee and this will be advised in the notice to be sent to the Requestor (in terms of section 54(3) of the PAIA Act).
    6. f) If the request is granted then the Requestor might be required to pay a further access fee for the search, reproduction and preparation of the record as well as for the time that has exceeded the prescribed hours to search and to prepare the record for disclosure to the Requestor (in terms of section 54(6) of the PAIA Act).
    7. g) The fee schedule can be downloaded from the Department of Justice and Constitutional Development’s website at www.justice.gov.za

    Vodacom keeps information and/or documents in accordance with the following legislation (This is not an exhaustive list):

    Legislation Type of information to be retained
    a) Basic Conditions of Employment Act No. 75 of 1997 The Act requires employers to keep records of information containing the personal details of all its employees, working times and remuneration package.
    b) Broad Based Black Economic Empowerment Act o. 53 of 2003 ("BBBEE") The BBBEE Act has as one of its objectives the promotion of economic transformation in order to enable meaningful participation of black people in the mainstream economy. It is expected that companies should keep records of activities undertaken in order to promote economic transformation and meaningful participation of black people in the mainstream economy.
    Companies Act No. 71 of 2008 The Act requires all company documents and records to be kept in a written format. Companies are also expected to maintain memorandum of incorporation and a record of their directors.  
    Compensation for Occupational Injuries and Health Diseases Act No. 130 of 1993 Employers are expected to keep a register, employee record or reproduction of same relating of wages, time worked, payment for piece work and overtime
    Consumer Protection Act No. 68 of 2008 The Act applies to all transactions in South Africa and is aimed at promoting and protecting the economic interests of consumers. The Act however does not deal with consumer personal information nor impose obligations on businesses in respect of treatment and/or protection of such information. 
    Criminal Procedure act No. 51 of 1977 The Act makes provision for the admissibility of documents as evidence where such documents were compiled in the course of trade or business by persons who have personal knowledge of matters contained in the document.
    Electronic Communications Act No. 36 of 2005 There are no specific requirements on the type of information to be retained. However it is expected that companies protect confidentiality of customer and to use it only for purpose authorized by the customer or in terms of the law
    Electronic Communications and Transactions Act No. 25 of 2002 The Act requires that information emanating from electronic transactions only be collected, collated, processed and disclosed with customer’s consent. Further, the purpose for which information is collected must be disclosed to the customer and must only be used for that purpose unless customer consents otherwise
    Employment Equity Act No. 55 of 1998 Employers are required to maintain records relating to the workforce, employment equity plans and other relevant records
    Financial Advisory and Intermediary Services Act No. 37 of 2003

    An authorized financial service provider is required to maintain records relating to:

    premature cancellation of transactions or financial products complaints received and an indication whether such complaints were resolved

    cases of non-compliance with the Act and reasons for such non-compliance

    Financial Intelligence and Centre Act No. 38 of 2001

    The Act requires that prior to establishing a relationship with a client Intelligence Centre’s should collect information relating to

    Client’s Identity Document ID of a person on whose behalf the client is acting and proof of authority

    Nature of business relationship/transaction

    Amounts involved

    Details of employee who captured info on behalf of company

    Labour Relations Act No. 66 of 1995 The Act requires employers to keep records of disciplinary transgressions against employees, actions taken and reasons for the action
    National Credit Act No. 34 of 2005 A credit provider is expected to maintain records of all applications for credit, credit agreements and credit accounts in the prescribed manner and form and for the prescribed time.
    Occupational Health and Safety Act No. 85 of 1993 Employers are required to keep records relating to the health and safety of persons in the workplace
    Pension Funds Act 24 of 1956 Every fund is expected to maintain books of account and other records as may be necessary for the purpose of the fund. All the money and assets belonging to the fund may be kept in the name of the pension fund by other institutions subject to conditions determined by the Minister
    Prevention and Combating of Corrupt Activities Act No. 12 of 2004 The Act provides for the strengthening of measures to prevent and combat corruption and corrupt activities. To this end companies are expected to keep records relating to any offer of improper gratification relating to the procurement or execution of contracts or employment relationship
    Prevention of Organized Crime Act No. 121 of 1998 The Act requires that any person who is aware of criminal activities is obliged to report them to the authorities. The duty of confidentiality or other restrictions on the disclosure of information, whether imposed by law, the common law or by agreement does not affect the obligation to report or disclose information or to permit access to any registers, records or other documents unless that obligation of confidentiality relates to attorney-client privilege.
    Public Prosecution Authority Act No. 32 of 1998 The Act regulates the establishment of a single National Prosecuting Authority. To this end the Director-General: Justice is required to cause the necessary accounting and other related records to be kept by the National Prosecuting Authority.
    Regulation of Interception of Communications and Provision of Communication Related Information Act No. 70 of 2002 (“RICA”)

    The Act requires the following information to be stored in respect of all customers:

    Name, surname, ID number, MSISDN and one address

    For businesses: name, registration number, business address, name and surname of business representative, his or her ID number as well as the address

    The above information should be stored in a separate RICA database which complies with specific security requirements prescribed under the Act and is used only for RICA purposes

    Short Term Insurance Act No. 53 of 1998 Under the Act the policyholder, and the person who entered into the short-term policy, are entitled, against payment of a prescribed fee to be provided, upon request, with a copy of the policy agreement.
    Skills Development Act no. 97 of 1998 The Act requires, amongst other things, that employers who commence with learnership programmes to enter into learnership agreements with the learner concerned specifying the learnership to be provided, the duration of the learnership and an undertaking to provide the learner with the specified practical experience. To comply with this requirement Employers are expected to keep records of all learnership agreements.
    Skills Development Levies Act No. 9 of 1999 Every employer is expected to make payments towards the skills development levy at a rate of 1% of the leviable amount. Records detailing payments made by the Employer are expected to be kept.
    Unemployment Insurance Act No. 30 of 1996 An Employer is expected to keep records relating to payment of contributions to the Unemployment Insurance Fund relating to: illness, maternity and for dependents. The Act does however, subject to the provisions of the Promotion of Access to Information Act, No. 2 of 2000, prohibits the disclosure of information obtained in the performance of functions under the Act.