Information Manual for Access to Information (PAIA & POPIA)

Prepared in accordance with Section 51 of the Promotion of Access to Information Act, 2 of 2000 (PAIA), and updated in terms of the Protection of Personal Information Act, 4 of 2013 (POPIA).

1. Introduction

This manual has been prepared for Resolute Actions (Pty) Ltd (“the Company”) in compliance with PAIA and updated to include the obligations set out under POPIA.

2. Purpose of PAIA

PAIA provides the right to access information held by public and private bodies, provided the information is required for the exercise or protection of any rights. The Act seeks to foster transparency and accountability within organizations.

However, access to information is limited to protect the privacy of individuals, commercial confidentiality, and good governance, among other concerns, all balanced with the constitutional rights of access to information.

3. Purpose of POPIA

POPIA was enacted to promote the safeguarding of personal information. It sets conditions for lawful processing and handling of personal data. It also introduces amendments to PAIA that ensure that access to personal information respects privacy rights.

4. Company and Information Officer Details

Company Name: Resolute Actions (Pty) Ltd
Information Officer: Shelly-Anne McQuade
Email: shelly@resolutactions.co.za
Physical Address: 4 Lunar Avenue, Signal Hill, Newcastle, KZN
Telephone: 078 692 1613

5. Availability of this Manual

This manual is available:

  • For inspection at the Company’s physical offices (free of charge);

  • On the Company website (if applicable);

  • Upon request to the Information Officer (a fee may apply as prescribed by PAIA).

6. Guide from the Information Regulator

A PAIA guide compiled by the Information Regulator is available at https://inforegulator.org.za/paia-guidelines/.
The guide provides practical guidelines for individuals seeking to exercise their rights.

7. Automatically Available Records

Resolute Actions may voluntarily make available records without a formal request, such as:

  • Marketing brochures

  • Newsletters

  • Public statements

  • Company profile

Only the reproduction fee will be payable for such information.

8. Types and Categories of Records Held

8.1 Personnel Records

  • Employment contracts

  • CVs and job applications

  • Training material

  • Internal correspondence

  • Payroll and banking details

8.2 Client Records

  • Identity and contact information

  • Application and transaction records

  • Property data and offer to purchase documents

  • Confidential correspondence

  • Compliance documents (e.g., FICA)

8.3 Company Records

  • Financial statements and reports

  • Tax records and invoices

  • Contracts and service agreements

  • Policies and procedures

  • Internal communication

  • IT and software-related records

8.4 Supplier and Service Provider Records

  • Contracts and SLA documents

  • Payment records

  • Performance evaluations

  • Correspondence

9. Processing of Personal Information

9.1 Purpose of Processing

  • Personnel: HR management, payroll, legal compliance

  • Clients: Property marketing, transaction processing, compliance

  • Suppliers/Contractors: Performance management, payments

  • Other Third Parties: Administration, legal compliance

10. Categories of Data Subjects

  • Employees and job applicants

  • Clients

  • Contractors and suppliers

  • Business partners

  • Website visitors (if applicable)

11. Categories of Recipients of Personal Information

  • Statutory and regulatory bodies (e.g., SARS, Information Regulator)

  • Legal bodies (courts, ombudsman)

  • Third-party service providers (e.g., IT providers, auditors)

  • Financial institutions

  • Anyone who successfully applies for access in terms of PAIA

12. Planned Transborder Flows of Information

Personal information may be transferred outside of South Africa for hosting or processing, but only where the recipient ensures similar levels of data protection as required under POPIA.

13. Security Measures

The Company implements organizational and technical measures to:

  • Prevent unauthorized access

  • Secure electronic and physical records

  • Backup and recover data in case of breach or loss

Examples include:

  • Secure servers and firewalls

  • Access control

  • Employee confidentiality agreements

14. Grounds for Refusal of Access

Access to information may be refused if it involves:

  • Unreasonable disclosure of personal information of a third party

  • Trade secrets or commercially sensitive data

  • Information disclosed in confidence

  • Legal privilege

  • Frivolous or vexatious requests

15. Access Procedure

Anyone requesting access must:

  1. Complete the PAIA Request Form (Form C);

  2. Submit it to the Information Officer (see details above);

  3. Provide proof of identity;

  4. Pay a request fee (R140) and, if applicable, a reproduction fee.

16. Prescribed Forms and Fees

Forms and fee structure are available from the Information Regulator or via:

17. Updates to the Manual

This manual will be reviewed regularly and updated as needed in accordance with changes to PAIA, POPIA, or company operations.

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