ImagePro Radiology / Legal documents
PAIA Manual
Access-to-information guidance for Dr De Villiers and Partners Inc. in terms of PAIA, read with POPIA.
1. Introduction to the practice
Dr De Villiers and Partners Inc., trading as ImagePro Radiology, is a private radiology practice conducted in accordance with the Health Professions Act 56 of 1974 and subject to the authority of the Health Professions Council of South Africa.
Its practitioners are registered with the HPCSA, provide radiology services within their registration, competence and training, and are bound by professional ethical rules, including the duty to preserve patient confidentiality.
Back to top ↑2. Contact details of the practice
Trading as ImagePro Radiology
Registration: 2012/037745/21
15 Lawley Avenue
Northcliff, 2195
Roosevelt Park, 2129
3. Information Regulator’s PAIA guide
The Guide on How to Use PAIA, prepared under section 10 of PAIA, assists people wishing to exercise access-to-information rights. It explains PAIA, the prescribed forms and fees, possible grounds for refusal, available remedies and the duties of Information Officers.
PAIA Guide, request forms and fee information: inforegulator.org.za/paia
General enquiries: enquiries@inforegulator.org.za
Telephone: 010 023 5200
4. Records held by the practice
Practice and governance
Establishment and incorporation documents, directors and shareholder records, agreements, statutory records, policies, meeting minutes and practice-code registrations.
Employment
Contracts, registrations, workplace policies, training, salaries, tax, leave, medical-scheme and employment correspondence.
Patients and referrals
Medical records, patient forms, payment records, correspondence, referral notes and reports.
Research and safety
Clinical-trial and research-study records, evacuation plans, and health-and-safety incident reports.
Financial and asset records
Statements, audits, accounting and banking records, invoices, VAT and tax records, asset registers, purchases, leases, stock and delivery documentation.
Agreements
Records involving contractors, consultants, suppliers, vendors, medical schemes, locums, professional assistants and clinical trials.
Public and private bodies
Official publications, benefit schedules, regulator and medical-scheme correspondence.
Insurance
Professional-indemnity and other policies, cover, claims and related records.
5. Information available under legislation
The practice holds records required by applicable legislation, subject to the protection provided by each law, including:
- Basic Conditions of Employment Act 75 of 1997
- Children’s Act 38 of 2005
- Companies Act 71 of 2008
- Compensation for Occupational Injuries and Diseases Act 130 of 1993
- Consumer Protection Act 68 of 2008
- Disaster Management Act 57 of 2002
- Electronic Communications and Transactions Act 25 of 2002
- Employment Equity Act 55 of 1998
- Hazardous Substances Act 15 of 1973
- Health Professions Act 56 of 1974
- Income Tax Act 58 of 1962
- Labour Relations Act 66 of 1995
- Medical Schemes Act 131 of 1998
- Medicines and Related Substances Act 101 of 1965
- National Health Act 61 of 2003
- Occupational Health and Safety Act 85 of 1993
- Promotion of Access to Information Act 2 of 2000
- Protection of Personal Information Act 4 of 2013
- Road Accident Fund Act 56 of 1996
- Skills Development Levies Act 9 of 1999
- Skills Development Act 97 of 1998
- Unemployment Contributions Act 4 of 2002
- Unemployment Insurance Act 63 of 2001
- Value Added Tax Act 89 of 1991
6. Records automatically available
The manual states that no notice was submitted regarding categories of records available without a formal PAIA request. Information published on the practice website is automatically available, subject to the Website User Agreement and Privacy Policy.
7. Purpose of processing personal information
- Conducting and administering the practice and collecting payment for services.
- Treating and caring for patients.
- Communicating and maintaining practice and patient records.
- Managing employment and practitioner matters.
- Reporting to referring practitioners and other authorised bodies or persons.
- Historical, statistical, research and clinical-trial purposes.
- Enforcing the practice’s rights and performing other lawful practice activities.
8. Data subjects and potential recipients
Information is disclosed only where necessary and authorised by law or with the relevant person’s consent. The manual identifies these groups:
Practitioners and employees
Identity, contact, professional registration, employment, remuneration, health-and-safety, banking, tax and next-of-kin information.
Job applicants
CVs, contact and identity information, qualifications, employment history, interview notes, references and relevant screening information.
Patients
Identity and contact details, medical history, health and procedure information, referrals, research participation, accounts and correspondence.
Referring practitioners
Identity and contact details, practice numbers, registered profession and correspondence.
Hospitals and healthcare facilities
Organisation and contact details, relevant personnel, website and practice numbers, privileges and correspondence.
Contractors, vendors and suppliers
Organisation, representative and contact information, correspondence, commercial arrangements, pricing and VAT information.
Insurers
Names, contact details, premiums, benefits and correspondence.
Public and private bodies
Regulator and funder details, office bearers, fee and benefit structures, published rules, payment records and correspondence.
Potential recipients include authorised practitioners and employees; medical schemes, hospitals and other healthcare providers; regulators, public bodies and law-enforcement agencies; banks, contractors and suppliers; auditors, legal and professional advisers and insurers; debt collectors, executors and authorised representatives; and, where applicable, a prospective purchaser of the practice. Information is shared only where it is necessary, lawful or authorised.
9. Information sent outside South Africa
The practice stores electronic information in cloud services and takes care when selecting providers to support legal compliance and data-subject privacy.
If further cross-border transfers become necessary, consent will be obtained where required and transfers will be made in accordance with applicable law.
10. Security measures
The practice uses technical, organisational and policy safeguards to protect personal information against unauthorised processing, access, loss, damage or destruction.
Measures include securing offices, locking physical records, password-controlled electronic access, off-site backups, limiting access to authorised practitioners and employees, confidentiality obligations and security requirements for suppliers and vendors. Security breaches are addressed in accordance with the law.
11. Procedure to request access
The fact that the practice holds a record does not automatically give a requester a right of access. Under PAIA, a record of a private body must generally be required for the exercise or protection of a right.
- Complete the prescribed Form 2: Request for Access to Record, available from the practice or on the Information Regulator’s PAIA forms page.
- Provide enough detail to identify the requester and the requested record.
- Identify the right being exercised or protected and explain why the record is required.
- When acting for another person, provide satisfactory proof of authority or capacity.
- The request may be refused where permitted by law. The requester will be advised of the outcome.
12. Fees
PAIA-prescribed request, search, preparation, reproduction and access fees may apply. The outcome and any fees or deposit due are communicated using the prescribed Form 3. Current forms and fee information are available from reception, the Information Officer or on the Information Regulator’s PAIA page.
13. Availability of this manual
The manual is available for inspection free of charge at the practice and on the ImagePro Radiology website. A copy may also be requested from the Information Officer, subject to any applicable fee.