GUIDANCE NOTE – APPOINTMENT AND REGISTRATION OF YOUR INFORMATION OFFICER AND DEPUTY INFORMATION OFFICER
The recent Guidance Note regarding the requirement to appoint and register an organization’s Information Officer and Deputy Information Officer/s with the Information Regulator, has reference.
We have prepared a few templates regarding this important step, including:
- A step-by-step process which has to be followed in order to ensure that this important registration requirement is completed timeously;
- A register housing the details of all the various companies which fall under your organization, which have to give notice of and register their Information Officer and Deputy Information Officer/s with the Regulator. NOTE– each subsidiary of a group of companies has to register separately – this cannot be done under the group entity only or by way of an annexure – a separate registration form per organization has to be submitted!
- The ‘Authorisation of Information Officer’ form required for the appointment of Information Officers, where the CEO or MD of a private organization will not act as the Information Officer, following the prescribed format as laid down by the Regulator;
- The ‘Designation and Delegation of Authority’ in respect of the appointment of Deputy Information Officer/s, where the Information Officer has deemed it necessary to appoint and make use of Deputies, following the prescribed format as laid down by the Regulator; This form, which houses the details of the Information Officer and Deputy Information Officer/s, has to be completed and submitted to the Regulator and details should be extracted and inserted into the ‘Registration Register’ referred to under point 2 above.
- Each subsidiary / company falling under your organisation should complete a separate form;
- A ‘job description’ or ‘terms of reference’;
A template documenting all PAIA requests, has to be compiled in terms of section 17 of POPIA and section 32 of PAIA.
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