Download printable PDF

PAIA Manual: Durbanville Wine Safari (Pty) Ltd

Prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 (as amended by the Protection of Personal Information Act 4 of 2013)

1. List of acronyms and abbreviations

2. Purpose of this PAIA manual

This manual helps members of the public to:

• 2.1 check the categories of records held by DWS that are available without a formal PAIA request;
• 2.2 understand how to request access to a record of DWS, by describing the subjects on which DWS holds records and the categories of records held on each subject;
• 2.3 know which records of DWS are available under other legislation;
• 2.4 find the contact details of the Information Officer, who will help with requests for access;
• 2.5 know about the Regulator's Guide on how to use PAIA and how to obtain it;
• 2.6 know whether DWS processes personal information, why it does so, and the categories of data subjects and of personal information involved;
• 2.7 know the recipients or categories of recipients to whom personal information may be supplied;
• 2.8 know whether DWS transfers or processes personal information outside the Republic; and
• 2.9 know whether DWS has appropriate security measures to protect the confidentiality, integrity and availability of personal information.

3. About Durbanville Wine Safari (Pty) Ltd

DWS is a private company incorporated in South Africa (registration number 2024/280613/07; not VAT-registered). It runs guided wine tours in the Durbanville wine valley under the name "Durbanville Wine Safari", including the Northern Line and Southern Line Wine Safari Tours. It also issues 2-for-1 tour vouchers to guests at Doorstep Blending Experience (DSB) events run by its related company, Doorstep Wines And Events (Pty) Ltd, which publishes its own PAIA manual.

4. Key contact details for access to information

4.1 Information Officer (head of the private body)

4.2 Deputy Information Officer

None designated.

4.3 Access to information general contact

Email: bookings@durbanvillewinesafari.com (subject line: "PAIA request")

4.4 Head office

5. Guide on how to use PAIA and how to obtain access to the Guide

5.1 The Regulator has, under section 10(1) of PAIA (as amended), updated and made available the revised Guide on how to use PAIA ("Guide"), in an easily understandable form, for any person who wishes to exercise a right under PAIA or POPIA.

5.2 The Guide is available in each of the official languages and in braille.

5.3 The Guide describes:

• 5.3.1 the objects of PAIA and POPIA;
• 5.3.2 the postal and street address, phone number and, where available, email address of the Information Officer of every public body and every Deputy Information Officer of every public and private body designated under section 17(1) of PAIA and section 56 of POPIA;
• 5.3.3 the manner and form of a request for access to a record of a public body (section 11) and of a private body (section 50);
• 5.3.4 the assistance available from the IO of a public body under PAIA and POPIA;
• 5.3.5 the assistance available from the Regulator under PAIA and POPIA;
• 5.3.6 all remedies in law for an act or failure to act in respect of a right or duty under PAIA and POPIA, including how to lodge an internal appeal, a complaint to the Regulator, and an application to court against a decision of the head of a private body;
• 5.3.7 the provisions of sections 14 and 51 requiring public and private bodies to compile a manual, and how to obtain access to a manual;
• 5.3.8 the provisions of sections 15 and 52 on voluntary disclosure of categories of records;
• 5.3.9 the notices issued under sections 22 and 54 about fees payable for requests; and
• 5.3.10 the regulations made under section 92.

5.4 Members of the public can inspect or copy the Guide at the offices of public and private bodies, including the Regulator, during normal working hours.

5.5 The Guide can also be obtained:

• 5.5.1 on request to the Information Officer of DWS; or
• 5.5.2 from the Regulator's website: https://inforegulator.org.za/paia-guidelines/

5.6 A copy of the Guide is available at DWS's head office for public inspection during normal office hours in English and Afrikaans.

5.7 Information Regulator contact details: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191 | Tel: 010 023 5200 | Toll-free: 0800 017 160 | Email: enquiries@inforegulator.org.za | Complaints: https://eservices.inforegulator.org.za | Website: https://inforegulator.org.za

6. Categories of records available without a request for access

The following records are available without a formal PAIA request (section 52). No notice under section 52(2) has been published for DWS.

7. Records available in accordance with other legislation

DWS keeps records as required by the following legislation, where applicable. Access to these records may be available under that legislation or under PAIA.

8. Subjects on which DWS holds records and categories of records held on each subject

9. Processing of personal information

9.1 Purpose of processing personal information

DWS processes personal information only for lawful purposes connected to its business, including to:

• 9.1.1 take, manage and confirm tour bookings and deliver guided wine tours;
• 9.1.2 cater for guests' dietary requirements and keep guests safe on tours;
• 9.1.3 process and record payments and refunds;
• 9.1.4 issue, check and honour 2-for-1 tour vouchers, and prevent voucher fraud;
• 9.1.5 send direct marketing (news, specials and event invites), but only to people who have opted in, and honour unsubscribes;
• 9.1.6 respond to enquiries, complaints and requests from guests and the public;
• 9.1.7 recruit, employ, pay and manage staff and interns, and meet employment, tax, UIF and COIDA obligations;
• 9.1.8 manage relationships and contracts with suppliers, partner wine farms, transport operators and other service providers;
• 9.1.9 keep accounting, tax and statutory records;
• 9.1.10 manage insurance and claims; and
• 9.1.11 comply with the law, and establish, exercise or defend legal claims.

9.2 Categories of data subjects and of personal information processed

9.3 Recipients or categories of recipients of personal information

DWS does not sell personal information. Service providers act as operators under written agreements that require confidentiality and security (POPIA s20–21).

9.4 Planned transborder flows of personal information

Some of DWS's service providers store or process personal information on servers outside the Republic, including Google (Google Workspace / Gmail / Google Sheets / Apps Script – data centres in the USA, the EU and elsewhere) and Cloudflare (global network). Categories affected: guest, voucher-claimant and marketing-subscriber contact and booking information, and business records stored in Google Workspace. DWS transfers personal information outside the Republic only as permitted by section 72 of POPIA, for example where the recipient is subject to law, binding corporate rules or a binding agreement providing an adequate level of protection, or where the data subject consents or the transfer is necessary to perform a contract with the data subject.

9.5 General description of information security measures

DWS takes appropriate, reasonable technical and organisational measures to protect the confidentiality, integrity and availability of personal information (POPIA s19), including:

• encrypted (HTTPS/TLS) connections for its website, forms and online services;
• access to personal information limited to authorised people who need it for their work, with role-based permissions on shared drives and spreadsheets;
• strong passwords and two-factor authentication on email, cloud and booking/payment accounts;
• payment card data handled by the payment processor (PayGenius), not stored by DWS;
• staff HR and payroll records (ID numbers, bank details, tax numbers, PINs) kept in restricted folders accessible only to management and the accountant;
• written operator agreements with service providers;
• deleting or anonymising personal information when it is no longer needed (see 9.6);
• device security (screen locks, up-to-date software and anti-malware); and
• a procedure to notify the Regulator and affected data subjects of security compromises (POPIA s22).

9.6 Retention (summary)

• Voucher claim records: kept for the voucher's validity (3 years from issue) plus 12 months after the voucher expires or is redeemed, whichever comes first, and then deleted.
• Marketing opt-in records: kept for as long as the person stays subscribed, plus 12 months. After a person unsubscribes, only their email address is kept on a suppression list so that the opt-out can be honoured.
• Accounting, tax and employment records: kept for the periods required by law (generally 5 years under the Tax Administration Act and Companies Act; 3 years under the BCEA).
• Information may be kept longer where the law requires it or where it is needed for a legal claim.

10. Request procedure

10.1 Who may request access. Any person may request access to a record of DWS if the record is required for the exercise or protection of any right, the requester complies with PAIA's procedural requirements, and no ground for refusal in Part 3, Chapter 4 of PAIA applies (section 50). A data subject may also ask DWS whether it holds personal information about them and request a record of it under section 23 of POPIA, using the same procedure.

10.2 Form. The request must be made on Form 2 (Request for Access to Record, regulation 7 of the Regulations), available from the Regulator's website (https://inforegulator.org.za/paia-forms/) or from the Information Officer. Submit it to the Information Officer by email, post or hand delivery to the details in section 4.

10.3 Content of the request. The requester must provide enough detail to identify the record(s) and the requester; state the form of access required; give a postal address or email address in the Republic; identify the right the requester seeks to exercise or protect and explain why the record is required; state if the requester wishes to be informed of the decision in another manner; and, if acting for someone else, provide proof of authority. A copy of the requester's ID may be required.

10.4 Assistance. A requester who cannot read or write, or has a disability, may make the request orally; the Information Officer will complete Form 2 on their behalf and give them a copy.

10.5 Fees (Annexure B of the Regulations, "Fees in respect of private bodies"):

10.6 Process and timelines. DWS will notify the requester (Form 3) whether the request is granted or refused, and of any fees, within 30 days of receiving a complete request. This period may be extended once by up to 30 days in the circumstances set out in section 57. The request fee must be paid before the request is processed. If the request is granted, access is given once any access fee is paid.

10.7 Grounds for refusal. DWS may or must refuse access on the grounds in sections 62 to 70 of PAIA, including to protect the privacy of third parties, commercial information of third parties or DWS, confidential information, the safety of individuals and property, privileged legal records, and research information. Where a record contains third-party information, DWS will follow the third-party notification procedure in sections 71 to 73.

10.8 Remedies. DWS has no internal appeal procedure. A requester or third party who is dissatisfied with a decision may, within 180 days of being notified, lodge a complaint with the Regulator (Form 5) or apply to a court with appropriate jurisdiction (sections 77A and 78).

10.9 Records that cannot be found or do not exist. If DWS cannot find a record after all reasonable steps, the Information Officer will notify the requester by affidavit or affirmation, setting out the steps taken (section 55).

11. Availability of the manual

11.1 A copy of this manual is available:

• 11.1.1 online at https://dsb-blend.pages.dev/paia/dws, with a link from the DSB voucher privacy policy;
• 11.1.2 at DWS's head office (Protea Hotel Durbanville, 99 Jip De Jager Drive, Durbanville) for public inspection during normal business hours;
• 11.1.3 to any person on request, on payment of a reasonable prescribed fee; and
• 11.1.4 to the Information Regulator on request.

11.2 A fee for a printed copy of the manual, as set out in Annexure B of the Regulations (R2.00 per A4 page), is payable.

12. Updating of the manual

The head of DWS will review and update this manual regularly, at least once a year and whenever DWS's contact details, Information Officer, records, processing purposes, recipients, cross-border transfers or security measures change.

Issued by

Joss Terry
General Manager and Information Officer, Durbanville Wine Safari (Pty) Ltd (designated by board resolution)

See also: PAIA manual of Doorstep Wines And Events (Pty) Ltd · DSB voucher privacy policy