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Broad-Based Black Economic Empowerment Act, 2003 (Act No. 53 of 2003)

Verification Manual

16. Documentation



16.1 The Verification Agency shall document matters that are significant in providing evidence that supports the verification result, and that the verification was performed in accordance with this guide.


16.2 Documentation shall include a record of the Verification Agency's reasoning on all significant matters that require the exercise of judgment, and related conclusions. The existence of difficult questions of principle or judgment requires the documentation to include the relevant facts that were known by the Verification Agency at the time the conclusion was reached.


16.3 It is neither necessary nor practical to document every matter the Verification Agency considers. In applying professional judgment to assessing the extent of documentation to be prepared and retained, the Verification Agency shall consider what is necessary to provide an understanding of the work performed and the basis of the principal decisions taken (but not the detailed aspects of the verification) to another Verification Agency which has no previous experience with the verification where this does not conflict with the confidentiality requirements of the Verification Agency. The second Verification Agency may only be able to obtain an understanding of detailed aspects of the verification by discussing them with the first Verification Agency who prepared the documentation, and where possible such an understanding should be achievable by reference to documentation only.


16.4 Records On BEE-Verified Clients


16.4.1 The Verification Agency shall maintain records on the verification process for all verified measured entities, including all measured entities that submitted requests for verification, and all measured entities verified.


16.4.2 Records on verified measured entities shall include: request for verification information and initial and on-going verifications justification for the time determined for verification records of complaints and appeals, and any subsequent corrections or corrective actions deliberations and decisions, if applicable documentation of the decisions, and record of Verification Certificates issued.


16.4.3 The Verification Agency shall keep the records on verified measured entities in such a way as to ensure that the information is kept confidential. When records are transported, transmitted or transferred, secured handling shall ensure that confidentiality is maintained.


16.4.4 The Verification Agency shall have a document policy and documented procedures on the retention of records