PAIA Manual

ITL OFFICE AUTOMATION (PTY) LTD

(Registration number: 2013/029026/07)

MANUAL

Prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000

Read with the Protection of Personal Information Act 4 of 2013

Date of adoption: 20 June 2026

Compiled with the assistance of kpa Audit Group Incorporated, Chartered Accountants (S.A.)

1.  Introduction

This manual is published in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 (“PAIA”). PAIA gives effect to the constitutional right of access to information held by another person where that information is required for the exercise or protection of any right.

The manual sets out the records held by the company, the procedure for requesting access to them, the applicable fees, and the grounds on which a request may be refused. It also addresses the company’s processing of personal information in terms of the Protection of Personal Information Act 4 of 2013 (“POPIA”), which is administered together with PAIA by the Information Regulator.

The company is a private body as defined in PAIA. All previous exemptions for private bodies from the obligation to compile this manual lapsed on 31 December 2021.

2.  Particulars of the private body

The Information Officer is, in terms of PAIA, the head of the private body, and is responsible for the duties imposed by PAIA and POPIA. Requests for access to records must be addressed to the Information Officer at the contact details below.

Name of companyITL Office Automation (Pty) Ltd
Registration number2013/029026/07
Information OfficerChereen Lara Valsecchi
Registered / business addressUnit 2 Ground Floor, 320 Rivonia Boulevard, Rivonia
Postal addressUnit 2 Ground Floor, 320 Rivonia Boulevard, Rivonia
Telephone(011) 258-6980
EmailChereen@officemd.co.za
VAT registration number 4250263755
Websitewww.officemd.co.za

3.  The Guide of the Information Regulator

The Information Regulator has, in terms of section 10 of PAIA, compiled a guide containing the information a person may require to exercise the rights conferred by PAIA and POPIA. The guide is available from the Information Regulator:

  • The Information Regulator (South Africa), JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001.
  • Postal: P.O. Box 31533, Braamfontein, Johannesburg, 2017.
  • Telephone: 010 023 5200.  Email (PAIA): PAIAComplaints@inforegulator.org.za.  Website: https://inforegulator.org.za.

4.  Categories of records and the basis of access

The records held by the company are classified below according to how they may be accessed. Records in Part A are available otherwise than by way of a request under PAIA — either because they form part of the public CIPC record, or because they are accessible to shareholders in terms of the Companies Act 71 of 2008. Records in Part B are not automatically available and may be requested under PAIA, where access is subject to the grounds for refusal in Chapter 4 of PAIA summarised in section 7 below.

Important: the fact that a record is filed with CIPC does not make it publicly available. In particular, the beneficial ownership register is filed with CIPC but is not open to the public, and the company’s annual financial statements are not lodged with CIPC at all.

4.1  Part A — Records available without a PAIA request

Category of recordHow it may be accessed
Public CIPC record (registration certificate, registered memorandum of incorporation and amendments, registered address, directors)From CIPC on payment of the prescribed CIPC fee
Records shareholders are entitled to inspect under the Companies Act 71 of 2008Available to shareholders on request in terms of the Act
This PAIA manualAvailable at the address in section 2

4.2  Part B — Records available on request under PAIA

All other records held by the company, including those listed in sections 5 and 6, are available only on request in terms of PAIA and subject to the grounds for refusal in section 7.

4.3  Remedies available where access is refused

A requester whose request for access is refused, or who is dissatisfied with a decision relating to fees, form of access or the period for dealing with the request, has the following remedies:

  • Internal appeal: There is no internal appeal against a decision of the Information Officer of a private body. A requester proceeds directly to the remedies below.
  • Complaint to the Information Regulator: A requester may, within 180 days of the decision, lodge a complaint with the Information Regulator in the prescribed manner for investigation and possible resolution.
  • Application to court: A requester may apply to the High Court (or a Magistrate’s Court designated under PAIA) for appropriate relief, either after exhausting the complaint procedure or directly, within 180 days of the decision.

5.  Subjects and categories of records held

The company holds records in the following subject categories. Listing a category does not mean every record in it is available — access remains subject to PAIA.

Subject categoryExamples of records held
Statutory and constitutionalRegistration certificate, memorandum of incorporation and amendments, register of directors, register of shareholders and beneficial ownership register, resolutions and minutes.
Financial and accountingAnnual financial statements, management accounts, accounting records, ledgers, invoices, bank statements and supporting vouchers.
TaxIncome tax, VAT and (where applicable) PAYE records, returns, assessments and correspondence with SARS.
Banking and financeBank account records, loan agreements and related correspondence.
Contracts and correspondenceAgreements with suppliers, customers and other third parties, general business correspondence and email.
Employment recordsEmployment contracts, payroll records and personnel files.
Stock and inventoryStock and inventory records, supplier price lists and purchase orders.
InsuranceBusiness, asset and related insurance policies, schedules and claims records.
Asset registerAsset register and records relating to equipment and vehicles.
Information technologyInformation-technology records and systems data.
MarketingMarketing and market-information records.
Intellectual propertyDatabank, benchmark and related proprietary information.

6.  Records held in terms of other legislation

Records are also kept in accordance with, among others, the following legislation:

  • Companies Act 71 of 2008
  • Income Tax Act 58 of 1962
  • Value-Added Tax Act 89 of 1991
  • Tax Administration Act 28 of 2011
  • Protection of Personal Information Act 4 of 2013
  • Consumer Protection Act 68 of 2008

7.  Grounds for refusal of access

Access to a record may or must be refused on the grounds set out in Chapter 4 of PAIA, which include:

  • Mandatory protection of the privacy of a third party who is a natural person.
  • Mandatory protection of commercial information of a third party (trade secrets, financial, commercial, scientific or technical information).
  • Mandatory protection of certain confidential information of a third party.
  • Mandatory protection of the safety of individuals and the protection of property.
  • Mandatory protection of records privileged from production in legal proceedings.
  • Commercial information of the private body, including trade secrets and information that could harm its commercial or financial interests.
  • A request that is manifestly frivolous or vexatious, or that would involve an unreasonable diversion of resources.

Access must nevertheless be granted where required by the public-interest override in section 70 of PAIA.

8.  Request procedure and fees

  • A requester must use the prescribed PAIA request form (Form 2 of the PAIA Regulations) and address it to the Information Officer at the details in section 2.
  • The request must provide sufficient particulars to identify the record and the requester, the form of access required, and the right the requester seeks to exercise or protect, together with an explanation of why the record is required for that right.
  • A request fee and an access fee are payable as prescribed in the PAIA Regulations. The Information Officer will notify the requester of the access fee before giving access, and access may be withheld until the fee is paid.
  • The Information Officer must decide the request within 30 days, which period may be extended in the circumstances permitted by PAIA, with notice to the requester.

9.  Processing of personal information (POPIA)

The company processes personal information as a responsible party under POPIA. This section is included for transparency.

9.1  Categories of data subjects and personal information

Data subjectPersonal information processed
Directors and shareholdersIdentity and contact details, shareholding interest and remuneration where applicable.
EmployeesIdentity, contact, banking and tax details, payroll and personnel records.
CustomersIdentity and contact details, account and transaction records.
Service providers and contractorsContact, banking and tax details and contract records.

9.2  Purpose of processing

Personal information is processed for the company’s ordinary business purposes, including statutory and tax compliance, financial reporting, employee administration, customer and supplier account management, and the management of contractual relationships.

9.3  Recipients of personal information

RecipientReason
South African Revenue ServiceTax compliance and statutory returns
CIPCStatutory filings and beneficial ownership
Banks and financial institutionsBanking, payments and finance
Auditors and accountantsCompilation, accounting and tax services
Regulators and authoritiesWhere required by law

9.4  Transborder flows

The company does not, as a matter of course, transfer personal information outside the Republic of South Africa. Where any such transfer occurs, it will be done in accordance with section 72 of POPIA.

9.5  Security safeguards

The company maintains appropriate, reasonable technical and organisational measures to safeguard personal information against loss, damage, unauthorised access and unlawful processing, as required by section 19 of POPIA.

10.  Availability of the manual

This manual is available: at the address in section 2; from the Information Regulator on request; and in the languages in which it is published. A copy will be provided on request, subject to the prescribed fee.