PAIA MANUAL

Prepared in terms of section 51 of the Promotion of Access
to Information Act 2 of 2000 as amended (the "Act")

DATE OF COMPILATION: 13/12/2021
DATE OF REVISION: 01/11/2022

1. LIST OF ACRONYMS AND ABBREVIATIONS
2. PURPOSE OF PAIA MANUAL
3. COMPANY DETAILS
4. THE ACT
5. LEGISLATION APPLICABLE TO THE COMPANY
6. AUTOMATICALLY AVAILABLE RECORDS
7. NOT AUTOMATICALLY AVAILABLE RECORDS
8. OTHER TYPES OF RECORDS HELD BY THE COMPANY
9. PROCESSING OF PERSONAL INFORMATION
10. PROCESS OF REQUESTING INFORMATION NOT AUTOMATICALLY AVAILABLE
11. PRESCRIBED FEES
12. INFORMATION OR RECORDS NOT FOUND
13. AVAILABILITY OF THE MANUAL
14. UPDATING OF THE MANUAL

1. LIST OF ACRONYMS AND ABBREVIATIONS

1.1 "CEO" Chief Executive Officer

1.2 "DIO" Deputy Information Officer;

1.3 "IO" Information Officer;

1.4 "Minister" Minister of Justice and Correctional Services;

1.5 "PAIA" Promotion of Access to Information Act No. 2 of 2000( as Amended);

1.6 "POPIA" Protection of Personal Information Act No.4 of 2013;

1.7 "Regulator" Information Regulator; and

1.8 "Republic" Republic of South Africa

2. PURPOSE OF PAIA MANUAL

The Promotion to Access of Information Act (PAIA) enables third parties to approach private bodies and/or government bodies to request information held by them.
The private and/or government body is on request by the third party, obliged to release private information unless PAIA specifically prohibits such.
This manual serves as a guide to requestors of personal information and the procedural requirements of PAIA.

This PAIA Manual is useful for the public to-

2.1 check the categories of records held by a body which are available without a person having to submit a formal PAIA request;

2.2 have a sufficient understanding of how to make a request for access to a record of the body,
by providing a description of the subjects on which the body holds records and the categories of records held on each subject;

2.3 know the description of the records of the body which are available in accordance with any other legislation;

2.4 access all the relevant contact details of the Information Officer and Deputy Information Officer who will assist the public with the records they intend to access;

2.5 know the description of the guide on how to use PAIA, as updated by the Regulator and how to obtain access to it;

2.6 know if the body will process personal information, the purpose of processing of personal information and the description of the categories of data subjects
and of the information or categories of information relating thereto;

2.7 know the description of the categories of data subjects and of the information or categories of information relating thereto;

2.8 know the recipients or categories of recipients to whom the personal information may be supplied;
2.9 know if the body has planned to transfer or process personal information outside the Republic of South Africa
and the recipients or categories of recipients to whom the personal information may be supplied; and

2.10 know whether the body has appropriate security measures to ensure the confidentiality, integrity and availability of the personal information which is to be processed.

3. COMPANY DETAILS

Head of Company/Group: Bradley Sifris.
Physical Address: Glenstar House,C/o Northfield avenue and Queen square, Glenhazel, Johannesburg,2192.
Postal Address: P.O. Box 29305,Sandringham,2131.
E-mail: bradley@altrack.co.za
Landline telephone number: 010-140 0206.

Information Officer: Keanu De Freitas.
Physical Address: Glenstar House,C/o Northfield avenue and Queen square,Glenhazel,Johannesburg,2192.
Postal Address: P.O. Box 29305,Sandringham,2131.
E-mail:keanu@altrack.co.za
Landline telephone number: 010-140 0206.

Deputy Information Officer: Amanda Louw.
Physical Address: Glenstar House,C/o Northfield avenue and Queen square,Glenhazel,Johannesburg,2192.
Postal Address: P.O. Box 29305,Sandringham,2131.
E-mail:amanda@altrack.co.za
Landline telephone number: 010-140 0206.

4. THE ACT

The Act grants a requester access to records of a private body if the record is required for the exercise or protection of any rights.
If a public body lodges a request, the public body must be acting in the public interest. Requests in terms of the Act must be made in accordance with the prescribed procedures and on the prescribed forms, at the rates provided.

In terms of section 10 of PAIA, the Information Regulator has compiled a Guide on how to
use PAIA. This Guide is available in all official languages and contains information such as:

the objectives of PAIA and how it works;
the manner and form of requests for access to information;
remedies available when access to information is denied;
the fees applicable; and
the contact details of public and private bodies.

The Guide is available free of charge from the Information Regulator and can be downloaded from their website.

Contact details of the Information Regulator are as follows:

Physical Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg,2001
Postal Address: P.O Box 31533, Braamfontein, Johannesburg, 2017
Telephone Number: +27 (0) 10 023 5200
Email: enquiries@inforegulator.org.za
Website: www.inforegulator.org.za

5. LEGISLATION APPLICABLE ON THE COMPANY

Companies Act No. 61 of 1973;

Employment Equity Act No. 55 of 1998;

Income Tax Act No. 95 of 1967;

Value Added Tax Act No. 89 of 1991;

Labour Relations Act No. 66 of 1995;

Basic Conditions of Employment Act No. 75 of 1997;

Electronic Communications and Transactions Act No. 25 of 2002;

Promotion of Access of Information Act No. 2 of 2000;

Unemployment Insurance Act No. 30 of 1996.

6. AUTOMATICALLY AVAILABLE RECORDS

The following records are automatically available to all employees:

Personnel records are available to the employee whose file it is;
Records of disciplinary hearings and related matters are available to the employee concerned;
The company's implemented policies and procedures.

7. NOT AUTONATICALLY AVAILABLE RECORDS

The following records are not automatically available without a request in terms of the Act:
- All statutory returns regarding:
- VAT:
- Workmen's Compensation;
- UIF;
- Regional Service Levies;
- Skills Development Levies;
- Documents concerning compliance by the company, insofar as it may be necessary, the
Occupational Health and Safety Act No. 85 of 1993, and any other applicable environmental legislation.

8. OTHER TYPES OF RECORDS HELD BY THE COMPANY

These records are not automatically available without a request in terms of the Act.
A request in terms of this section is subject to section 63(1) of the Act, which provides that the head of a company must refuse a request
for access to a record of the company if the disclosure of the record would involve the unreasonable disclosure of personal information about a third party including a deceased individual.

HUMAN RESOURCES DEPARTMENT

Personnel information including personal information, employment history and health records that the company may hold from time to time;

Training and development information;

General files containing information on employee benefits and employee recruitment and selection information.

FINANCE/ACCOUNTS DEPARTMENT

Financial records;

A list of company's creditors and debtors;

Salary information;

Bank account information;

Fixed assets register.

9. PROCESSING OF PERSONAL INFORMATION

9.1 Description of the categories of Data Subjects and of the information or categories of information relating thereto

Categories of Data Subjects	Personal Information that may be processed
Customers / Clients	Inter alia, name, address, registration numbers or identity numbers, employment status and bank details.
Service Providers	Inter alia, names, registration number, vat numbers, address, trade secrets and bank details.
Employees	Inter alia, address, qualifications, gender and race.

9.2 The recipients or categories of recipients to whom the personal information may be supplied

Category of personal information	Recipients or Categories of Recipients to whom the personal information may be supplied
Identity number and names, for criminal checks	Inter alia, South African Police Services.
Qualifications, for qualification verifications	Inter alia, South African Qualifications Authority.
Credit and payment history, for credit information	Inter alia, Credit Bureaus.

9.3 Planned trans-border flows of personal information

N/A.

9.4 General description of Information Security Measures to be implemented by the responsible party to ensure
the confidentiality, integrity and availability of the information

Manually stored personal information will be stored in a locked area inside a locked cabinet with restricted access;

Electronically stored personal information will be secured by the necessary password security measures, anti-virus, firewalls and restricted access.

10. PROCESS OF REQUESTING INFORMATION NOT AUTOMATICALLY AVAILABLE

To facilitate the processing of a request for access to a record that is not automatically available, requesters must:

Complete the prescribed Form 2 (Request for Access to Record) as set out in Annexure A of the Regulations relating to PAIA, 2021. A copy of Form 2 is available on the website of the Information Regulator (www.inforegulator.org.za).
Address the completed form, together with the prescribed request fee (if applicable), to the Information Officer of the company at the contact details provided in this Manual.
Provide sufficient details to enable the company to identify:
- The record/s requested;
- The form of access required (inspection, printed copy, electronic copy, etc.);
- The postal address, email address, or fax number of the requester in the Republic; and
- If the requester wishes to be informed of the decision in a manner other than written, the manner and particulars thereof.
Indicate the right that the requester is seeking to exercise or protect, and explain why the record requested is required for the exercise or protection of that right.

Failure to complete Form 2 properly may result in delays in processing the request or in refusal of the request.

11. PRESCRIBED FEES

In terms of Annexure B to the Regulations relating to the Promotion of Access to Information, 2021 (Government Notice R. 757, 27 August 2021), the following fees apply to requests for access to records by private bodies:

11.1 Request Fee

A non-refundable request fee of R 140.00 is payable by every requester, except where the requester is a personal requester (i.e., the data subject themselves)

11.2 Access Fee (for search, preparation, and reproduction)

Access fees are applicable when a request is granted and are capped as follows:

Search and preparation fee:
- R 145.00 per hour, up to a maximum of R 435.00
Reproduction fees for copies of records must follow the prescribed schedule (to be detailed in your Annexure B).

11.3 Application of Fees

Personal requesters (those requesting records about themselves) are exempt from the request fee, but remain liable for access fees unless otherwise exempt.
Total access fees may consist of:
1. Search and preparation costs;
2. Reproduction costs (photocopies, CD, electronic delivery, etc.);
3. Postal or delivery costs, where applicable.

A deposit of up to one-third of the access fee may be required before the records are processed, particularly when substantial time or reproduction is involved, in line with PAIA section 22(4)

Please refer to Annexure B for the full Fees Schedule

12. INFORMATION OR RECORDS NOT FOUND

If all reasonable steps have been taken to find a record, and such a record cannot be found or if the records
do not exist, then the head of the company or management shall notify the requestor, by way of an affidavit or
affirmation, that it is not possible to give access to the requested record;

The affidavit or affirmation shall provide a full account of all the steps taken to find the record or to
determine the existence thereof, including details of all communications by the head of the company or the
request liaison officer with every person who conducted the search;

The notice shall be regarded as a decision to refuse a request for access to the record concerned for the purposes of the Act;

If the record in question should later be found, the requestor shall be given access to the record in the
manner stipulated by the requestor in the prescribed form unless access is refused by the head of the company or the request liaison officer;

The attention of the requestor is drawn to the provisions of Chapter 4 of Part 3 of the Act in terms of which
the company may refuse, on certain specified grounds, to provide information to a requestor.

13. AVAILABILITY OF THE MANUAL

a. A copy of the Manual is available-

i. On our website;

ii. Our head office for public inspection during normal business hours;

iii. To any person upon request and upon the payment of a reasonable prescribed fee; and

iv. To the Information Regulator upon request.

b. A fee for a copy of the Manual, as contemplated in annexure B of the Regulations, shall be payable per each A4-size photocopy made.

14. UPDATING OF THE MANUAL

This manual will be updated on a regular basis.

ANNEXURE A

In terms of Regulation 7(1) of the Regulations relating to the Promotion of Access to Information, 2021, all requests for access to records of a private body must be made on the prescribed Form 2 (Request for Access to Record).

This form must be completed and submitted to the Information Officer or Deputy Information Officer of the company at the contact details set out in this Manual.

A copy of Form 2 is included below for ease of reference. The form is also available on the website of the Information Regulator (www.inforegulator.org.za).

ANNEXURE B

Fees in Respect of Private Bodies

Item	Description	Amount
1	The request fee payable by every requester	R140.00
2	Photocopy/printed black & white copy of A4-size page	R2.00 per page or part thereof.
3	Printed copy of A4-size page	R2.00 per page or part thereof.
4	For a copy in a computer-readable form on: (i) Flash drive (to be provided by requestor) (ii) Compact disc - If provided by requestor - If provided to the requestor	R40.00 R40.00 R60.00
5	For a transcription of visual images per A4-size page	Service to be outsourced. Will depend on quotation from Service provider.
6	Copy of visual images	Service to be outsourced. Will depend on quotation from Service provider.
7	Transcription of an audio record, per A4-size page	R24.00
8	Copy of an audio record on: (iii) Flash drive (to be provided by requestor) (iv) Compact disc - If provided by requestor - If provided to the requestor	R40.00 R40.00 R60.00
9	To search for and prepare the record for disclosure for each hour or part of an hour, excluding the first hour, reasonably required for such search and preparation. To not exceed a total cost of	R145.00 R435.00
10	Deposit: If search exceeds 6 hours One third of amount per request calculated in terms of items 2 to 8.	One third of amount per request calculated in terms of items 2 to 8.
11	Postage, e-mail or any other electronic transfer	Actual expense, if any.

Issued by

Amanda Louw
Deputy Information Officer