TABLE OF CONTENTS
- Introduction to the Group
- Companies and Their Contact Details
- Guide of the Information Regulator
- Records Held by the Practice
- Information Available in Terms of Legislation
- Records Automatically Available
- Purpose of Processing Personal Information
- Data Subjects, Their Personal Information and Potential Recipients of Information
- Personal Information Sent Across the Borders of the Republic of South Africa
- Security Measures to Protect Personal Information
- Procedure to Obtain Access to Records or Information
- Fees Payable to Obtain the Requested Records or Information
- Availability of This Manual
1. Introduction to the Group
All the companies to which this Manual applies are structured as personal liability companies incorporated under the laws of South Africa and administered by the Path 24 Group of Companies. These practices operate according to the requirements of the Health Professions Act 56 of 1974 and are subject to the authority of the Health Professions Council of South Africa (HPCSA). Practitioners are registered with the HPCSA and provide healthcare services within their scope of practice. They are bound by the Ethical Rules of the HPCSA, including the duty to preserve patient confidentiality.
2. Companies and Their Contact Details
CENTRAL LABORATORY MANAGEMENT SERVICES (PTY) LTD
Company Name: CENTRAL LABORATORY MANAGEMENT SERVICES (PTY) LTD
Registration Number: 2015/226147/07
Physical Address: 243 Victoria Road, Georgetown, Germiston, 1401
Postal Address: P.O. Box 2489, Saxonwold, 2132
Telephone Number: 010 026 8021
Email: info@path24.co.za
Website: www.path24.co.za
Information Officer: Imraan Varachhia
Deputy Information Officer: Muhammad Bholat
Email: info@path24.co.za
Dr Hajee and Partners
Practice Name: Dr Hajee and Partners
Practice Number: 1090321
Registration Number: 2023/639027/21
Head of Practice: Dr Suleiman Hajee
Physical Address: 243 Victoria Road, Georgetown, Germiston, 1401
Postal Address: P.O. Box 2489, Saxonwold, 2132
Telephone Number: 010 026 8021
Email: info@path24.co.za
Website: www.path24.co.za
Information Officer: Imraan Varachhia
Deputy Information Officer: Muhammad Bholat
3. Guide of the Information Regulator
The Information Regulator has compiled a Guide in terms of Section 10 of PAIA to assist persons wishing to exercise their rights. The Guide includes information on:
- The purpose of PAIA
- The manner, form and fees for access to information
- Remedies when access is denied
- Assistance provided by the Information Regulator
- Contact details of Information Officers
- Relevant legislation
The Guide is available on the Information Regulator’s website or from their offices at:
Physical address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg
Postal address: P.O. Box 31533, Braamfontein, 2017
Email: enquiries@inforegulator.org.za
A copy is also available from the practice Information Officer and for inspection during office hours.
4. Records Held by the Practice
The practices hold the following categories of records:
4.1 Records relating to the form of practice
Documents required under the Companies Act, shareholders’ agreements, statutory records, governance documents, practice code registrations, etc.
4.2 Employment records
Contracts, registrations, workplace policies, salary records, tax records, leave records, permits, correspondence.
4.3 Patient records
Medical records, patient forms, payment records.
4.4 Referral records
Referral notes and reports.
4.5 Clinical trial / research study records
Documents related to trials and studies.
4.6 Health and safety records
Evacuation plans, incident reports.
4.7 Financial records
Statements, audit reports, bank records, VAT records, invoices, receipts.
4.8 Records related to assets
Asset registers, purchase records, stock sheets, delivery notes.
4.9 Agreements
Contracts with service providers, suppliers, locums, medical schemes, clinical trial agreements.
4.10 Legal records
Complaints, legal documents, opinions.
4.11 Public and private body records
Official publications, benefit schedules, correspondence.
4.12 Insurance records
Policies, claims, indemnity documentation.
5. Information Available in Terms of Legislation
The practices maintain records required by laws including:
- Basic Conditions of Employment Act
- Labour Relations Act
- Children’s Act
- Companies Act
- Consumer Protection Act
- Medical Schemes Act
- Disaster Management Act
- Electronic Communications and Transactions Act
- Employment Equity Act
- Health Professions Act
- Nursing Act
- Income Tax Act
- Tax Administration Act
- Medicines and Related Substances Act
- National Health Act
- Occupational Health and Safety Act
- COIDA
- PAIA
- POPIA
- Road Accident Fund Act
- Skills Development Acts
- Unemployment Insurance Acts
- VAT Act
6. Records Automatically Available
Information available on the website is automatically accessible without submitting a formal PAIA request. Use of this information is subject to the Website Terms and Conditions and the Path 24 Privacy Policy.
7. Purpose of Processing Personal Information
Personal information is processed for purposes including:
- Practice administration and billing
- Patient treatment and care
- Communication
- Record maintenance
- Employment and HR functions
- Reporting to authorised bodies
- Historical, statistical and research purposes
- Clinical trials
- Procurement
- Enforcement of rights
- Any lawful purpose related to practice activities
8. Data Subjects, Their Personal Information and Potential Recipients
8.1 Practitioners
Information includes names, identity numbers, contact details, qualifications, employment information, health information, remuneration, tax numbers, CVs, etc.
Recipients may include SARS, funders, patients, service providers, auditors, advisers, public bodies, law enforcement and potential buyers.
8.2 Job Applicants
Information includes names, CVs, qualifications, references, identity numbers, etc.
Recipients may include practitioners, service providers, auditors, advisers and law enforcement.
8.3 Patients
Information includes personal and medical details, treatment information, billing records, next-of-kin details, clinical trial participation information, etc.
Recipients may include treating practitioners, funders, hospitals, advisers, estates, debt collectors and law enforcement.
8.4 Referring Practitioners
Information includes names, contact details, practice details and correspondence.
Recipients may include practitioners, funders, auditors and advisers.
8.5 Hospitals / Healthcare Facilities
Information includes contact details, practice numbers and correspondence.
Recipients may include practitioners, auditors and advisers.
8.6 Service Providers, Contractors and Suppliers
Information includes names, organisation details, pricing, VAT numbers, correspondence.
Recipients may include practitioners, banks, auditors and advisers.
8.7 Insurers
Information includes premiums, benefits and correspondence.
Recipients may include practitioners, auditors, advisers and public bodies.
8.8 Public and Private Bodies
Information includes fees, benefit schedules, employee details, invoices, statements, visitor records.
Recipients may include practitioners, debt collectors, patients, auditors and advisers.
9. Personal Information Sent Across South African Borders
The practices do not currently transfer personal information outside South Africa. If such transfer becomes necessary, it will only occur with consent (when required) or in accordance with the law.
10. Security Measures to Protect Personal Information
Security measures include:
- Secure storage areas
- Access control
- Off-site data backups
- Confidentiality agreements
- Restricting access to authorised personnel
- Enforcing vendor compliance
- Addressing security breaches according to law
11. Procedure to Obtain Access to Records
Access to records is not automatic. A requester must:
- Complete Form 2, available from reception or the Information Officer
- Provide sufficient detail to identify the record
- State the right being exercised or protected
- Provide proof of authority if acting for another person
Requests may be refused as permitted by law. Requesters will be informed of outcomes.
12. Fees Payable
Fees may apply for requesting or accessing information. These fees are prescribed in terms of PAIA and are available from reception, the Information Officer or the Information Regulator.
13. Availability of This Manual
This Manual is available free of charge for inspection at the practices and on the website. A copy may also be requested from the Information Officer subject to applicable fees.