Privacy Policy:

BACKGROUND TO THE PROMOTION OF ACCESS TO INFORMATION ACT
1.1 The Promotion of Access to Information Act, no. 2 of 2000 (“PAIA Act”) was enacted on 3
February 2000, giving effect to the constitutional right in terms of section 32 of the Bill of Rights
contained in the Constitution of the Republic of South Africa 108 of 1998 (the “Constitution”) of
access to any information held by the state and any information that is held by another person
that is required for the exercise or protection of any rights.
1.2 In terms of section 51 of the PAIA Act, all private bodies (juristic and natural persons) are
required to compile an Information Manual (“PAIA Manual”).
1.3 Where a request is made in terms of the PAIA Act, the body to whom the request is made is
obliged to release the information, subject to applicable legislative and/or regulatory
requirements, except where the PAIA Act expressly provides that the information may be
adopted when requesting information from a public or private body.

​

PRACTICE DETAILS
Practice Name: Margie Pankhurst, Drama Therapy
Practice address: Ananda Sanctuary, 2 Clyde Street, Woodstock, Cape Town, 7925
Postal address: 27 Bowden Road, Observatory, Cape Town, 7925
Email: margiepankhurst@gmail.com
Cellular phone: 073 993 0211 or 083 412 9341
Description: The provision of mental health services to adults and children using the arts therapies (drama therapy).

​

PURPOSE OF PAIA MANUAL

This PAIA Manual is useful for the public to-
2.1 check the categories of records held by the drama therapist which are available without a person having to submit a formal PAIA request;
2.2 have a sufficient understanding of how to make a request for access to a record of the drama therapist, by providing a description of the subjects on which the drama therapist holds records and the categories of records held on each subject;
2.3 know the description of the records of the drama therapist which are available in accordance with any other legislation;
2.4 access all the relevant contact details of the Information Officer and Deputy Information Officer who will assist the public with the records they intend to access;
2.5 know the description of the guide on how to use PAIA, as updated by the Regulator and how to obtain access to it;

2.6 know if the drama therapist will process personal information, the purpose of processing of personal information and the description of the categories of data subjects and of the information or categories of information relating thereto;
2.7 know the description of the categories of data subjects and of the information or categories of information relating thereto;
2.8 know the recipients or categories of recipients to whom the personal information may be supplied;
2.9 know if the drama therapist has planned to transfer or process personal information outside the Republic of South Africa and the recipients or categories of recipients to whom the personal information may be supplied; and
2.10 know whether the drama therapist has appropriate security measures to ensure the confidentiality, integrity and availability of the personal information which is to be processed.

​

KEY CONTACT DETAILS FOR THE INFORMATION OF MARGIE PANKHURST, DRAMA THERAPY
Chief Information Officer
Name: Margie Pankhurst
Tel: 073 993 0211
Email: margiepankhurst@gmail.com

​

GUIDE ON HOW TO USE PAIA AND HOW TO OBTAIN ACCESS TO THE GUIDE
3.1. The Regulator has, in terms of section 10(1) of PAIA, as amended, updated and made available the revised Guide on how to use PAIA (“Guide”), in an easily comprehensible form and manner, as may reasonably be required by a person who wishes to exercise any right contemplated in PAIA and POPIA.
3.2. The Guide is available in each of the official languages and in braille.

3.3. The aforesaid Guide contains the description of-
3.3.1. the objects of PAIA and POPIA;

3.3.2. the postal and street address, phone and fax number and, if available, electronic mail address of-
3.3.2.1. the Information Officer of every public body, and

3.3.2.2. every Deputy Information Officer of every public and private body designated in terms of section 17(1) of PAIA1 and section 56 of POPIA2;

3.3.3. the manner and form of a request for-
3.3.3.1. access to a record of a public body contemplated in section 11(3); and

3.3.3.2. access to a record of a private body contemplated in section 50(4)
3.3.4. the assistance available from the IO of a public body in terms of PAIA and POPIA;
3.3.5. the assistance available from the Regulator in terms of PAIA and POPIA;
3.3.6. all remedies in law available regarding an act or failure to act in respect of a right or duty conferred or imposed by PAIA and POPIA, including the manner of lodging-
3.3.6.1. an internal appeal;

3.3.6.2. a complaint to the Regulator; and

3.3.6.3. an application with a court against a decision by the information officer of a public body, a decision on internal appeal or a decision by the Regulator or a decision of the head of a private body;
3.3.7. the provisions of sections 14(5) and 51(6) requiring a public body and private body, respectively, to compile a manual, and how to obtain access to a manual;
3.3.8. the provisions of sections 15(7) and 52(8) providing for the voluntary disclosure of categories of records by a public body and private body, respectively;
3.3.9. the notices issued in terms of sections 229 and 54(10) regarding fees to be paid in relation to requests for access; and
3.3.10. the regulations made in terms of section 92(11);
3.4. Members of the public can inspect or make copies of the Guide from the offices of the public and private bodies, including the office of the Regulator, during normal working hours.

3.5. The Guide can also be obtained-
3.5.1. upon request to the Information Officer;

3.5.2. from the website of the Regulator (https://www.justice.gov.za/inforeg/).

​

CATEGORIES OF RECORDS OF MARGIE PANKHURST, DRAMA THERAPY, WHICH ARE
AVAILABLE WITHOUT A PERSON HAVING TO REQUEST ACCESS​

​

​

​​​​​

DESCRIPTION OF THE RECORDS OF MARGIE PANKHURST, DRAMA THERAPY, WHICH
ARE AVAILABLE IN ACCORDANCE WITH ANY OTHER LEGISLATION

​

​

​

​​​PROCESSING OF PERSONAL INFORMATION
Purpose of Processing Personal Information
1. Contact information (telephone and email) for the purpose of making appointments, and billing.
2. Contact information (telephone and email) of client support services;
3. Emergency contact details as supplied by the client with consent from the relevant party.

​​

​

​​

​

​

​

​​​​

I need to collect and process relevant personal information, an emergency contact, and the
person responsible for the account, in order to adhere to the administrative requirements of th e
practice. By providing this information, the client confirms that they have obtained consent from the
person/s listed to provide their details.
In order to provide a therapeutic service, I additionally might need to collect sensitive
personal information, related to medical history, family history, mental health, and other areas of
life. I need to collect, store and process the above and any other relevant personal information,
including but not limited to session records or notes and communications or correspondence
required to provide therapeutic services, as per Health Professions Council of South Africa
(HPCSA) regulations and the Protection of Personal Information Act 4 of 2013 (POPIA). This
information will only be used for the purposes for which it was collected (administrative running of
practice, and providing drama therapy services).
Information will be securely stored in physical and/or electronic forms. All electronic
information is stored in an encrypted, password-protected location. I review security safeguards
regularly to ensure information is kept safe and confidential. Physical information is stored in a
locked cabinet in a secure practice room.
I may disclose the information to service providers that are involved in or enable delivering
services to, such as medical schemes or other healthcare professionals (as stipulated in the
‘Confidentiality’ section of the therapy agreement), where this supports treatment and with consent
of the client. This may include processing and sharing information for the purposes of billing and
collecting unpaid debts. Other third parties include email and text message service providers (e.g.,
Gmail, WhatsApp), online therapy platforms (WhatsApp video) and cloud storage providers which
may be located outside South Africa. Relevant password protections will secure information stored
on these virtual platforms. I will take all reasonable steps to ensure that all the privacy protections
of these third parties comply with POPIA.
Client notes and materials are kept for a period of 6 years from the date of last consultation
or as regulated by professional standards set out by the HPCSA, and will be safely disposed
of/destroyed thereafter, in line with POPIA guidelines. Where specific requests are received to
disclose information records (e.g., medical aid audits), a separate consent form detailing the
particulars of this request will be provided to you.

​

AVAILABILITY OF THE MANUAL
A copy of the Manual is available
- on https://margiepankhurst5.wixsite.com/margiepankhurst;
- the private practice of the Margie Pankhurst for public inspection during normal business hours;
- to any person upon request and upon the payment of a reasonable prescribed fee; and
- to the Information Regulator upon request.

 

A fee for a copy of the Manual, as contemplated in annexure B of the Regulations, shall be payable per each A4-size photocopy made.

​

UPDATING OF THE MANUAL
The manual will be updated by Margie Pankhurst on an annual basis.

Margie Pankhurst
(Drama therapist)