Licentia operates under a franchised, territorially governed model with centralised governance and system oversight. This section explains how personal information is accessed, shared, governed, and protected across Licentia Franchise SA (Pty) Ltd, the provincial entities, internal departments, and authorised franchise operators, in accordance with POPIA.

6.1 Territorial Processing and Provincial Operational Responsibility

Personal information is ordinarily collected and processed by the relevant provincial entity within its assigned territorial jurisdiction to deliver services requested by clients.

Provincial entities and authorised franchise operators engage directly with clients and are responsible for accurate data capture, process feedback, and workflow progression within the Licentia systems, subject to Licentia Head Office governance controls.

6.2 Centralised System Governance, Oversight, and Audit

Licentia Franchise SA (Pty) Ltd maintains centralised governance and oversight over the Licentia network, including governance over:

• operational system access and permissions;
• workflow integrity and process compliance;
• evidence pack completeness and traceability;
• audit logging and compliance monitoring;
• standardisation of templates, procedures, and submissions; and
• enforcement of POPIA-aligned processing rules.

Licentia Franchise SA may access provincial records where reasonably necessary for governance, compliance oversight, risk management, audit, dispute resolution, legal escalation, and system integrity.

6.3 Controlled Data Sharing within the Licentia Group

Personal information may be shared within the Licentia Group on a controlled, need-to-know basis for lawful service execution and governance, including between:

• Licentia Franchise SA (Pty) Ltd (Head Office);
• the relevant provincial entity;
• authorised franchise operators acting under provincial authority and Licentia governance; and
• internal departments (including Compliance, Finance, Audit, IT Governance, and the Legal Department operated within MaxMind Group).

Such sharing is limited to the minimum necessary information required to execute the mandate/SLA and maintain lawful governance and compliance oversight.

6.4 Financial Governance and Payment Controls (Provincial Payments under Head Office Governance)

Clients request services through franchise operators and provincial structures. Fees are ordinarily payable to the relevant provincial entity.

Licentia Franchise SA exercises governance and control over financial workflows within the provincial entities through its centralised systems and governance framework, including:

• invoicing and workflow verification controls;
• service tracking and audit trail requirements;
• payment status monitoring and reporting;
• financial governance oversight required for franchise administration, compliance, and risk management; and
• controls intended to ensure traceability, integrity, and lawful processing of financial records.

This governance structure exists to protect clients, the provincial entities, the franchise network, and the Licentia Group, and to ensure consistent compliance across territories.

6.5 Secure Portal/System Requests (Current Holder and Third-Party Inputs)

Where a matter involves an existing licence/permit/certificate and a Current Holder must provide information (for example, transfer/amendment/change workflows), Licentia may request such information directly from the Current Holder.

Where possible, this request is facilitated through a secure Licentia portal/system to:

• ensure controlled data capture;
• maintain traceability and audit logs; and
• protect confidentiality and data security.

Information submitted by Current Holders or third parties is processed strictly for the lawful purpose of executing the regulated mandate/SLA and compliance process.

6.6 Role-Based Access and Confidentiality Controls

Access to personal information within Licentia systems is restricted through role-based access control and operational permissions.

Licentia limits access to staff and authorised persons who require access for lawful performance of their functions and applies confidentiality duties and governance policies to prevent unauthorised processing, disclosure, or misuse.

6.7 Third-Party Professionals and Authorities (Facilitated Services)

Where regulated services require third-party registered professionals or competent authorities (e.g., architects, engineers, fire specialists, town planners, environmental practitioners, legal firms, regulators), Licentia may share the minimum necessary information required to obtain approvals, certificates, plans, and lawful signoffs, subject to:

• mandate/SLA authority;
• purpose limitation;
• confidentiality controls; and
• POPIA-aligned safeguards.

6.8 Governance Enforcement and Non-Compliance Controls

Licentia Franchise SA retains authority to enforce governance and compliance requirements across provincial entities and franchise operators, including implementing corrective actions where:

• POPIA risks are identified;
• workflow or recordkeeping failures occur;
• unauthorised access or processing is suspected;
• regulatory exposure arises; or
• systemic integrity requires intervention.

Such actions may include audit escalation, workflow suspension, access restriction, and legal escalation where necessary.