PAIA Manual

1. INTRODUCTION TO TECHTRADERS

1.1 – TechTraders is a private body as defined in PAIA, conducting business as a B2B technology distributor in South Africa.

1.2 – This manual explains the procedure to be followed when requesting access to a record held by TechTraders, and the categories of records we hold.

2. PARTICULARS OF THE PRIVATE BODY

3. INFORMATION OFFICER

Requests for access to records must be directed to the Information Officer (or a designated Deputy Information Officer):

4. THE INFORMATION REGULATOR'S GUIDE

The Information Regulator has compiled a guide, in terms of section 10 of PAIA, containing information to assist a person wishing to exercise any right under PAIA and the Protection of Personal Information Act. The guide is available from the Information Regulator:

5. RECORDS AVAILABLE IN TERMS OF OTHER LEGISLATION

Certain records are maintained and made available in accordance with other legislation, including (where applicable):

• Companies Act, 2008
• Income Tax Act, 1962 and Value-Added Tax Act, 1991
• Tax Administration Act, 2011
• Basic Conditions of Employment Act, 1997 and Labour Relations Act, 1995
• Protection of Personal Information Act, 2013
• Consumer Protection Act, 2008

Access to records under those laws is governed by the relevant statute, not necessarily by PAIA.

6. CATEGORIES OF RECORDS HELD

TechTraders holds records in, among others, the following categories (to be confirmed against actual record-keeping):

• Company records – registration, statutory and governance documents.
• Financial records – invoices, statements, tax records, banking and audit records.
• Customer & supplier records – trade-account applications, credit information, orders, quotes and contracts.
• Employee records – contracts, payroll and HR documentation.
• Operational records – inventory, logistics, correspondence and IT-system records.
• Marketing records – consent records and campaign data.

7. PROCEDURE TO REQUEST ACCESS

7.1 – A requester must complete the prescribed Form 2 (Request for Access to Record of Private Body) and submit it to the Information Officer at the address in section 3.

7.2 – The request must provide sufficient detail to identify the record and the requester, the form of access required, and a contact address. Where the request is made in the interest of another person, proof of capacity must be supplied.

7.3 – A requester (other than for their own personal information) must identify the right they are seeking to exercise or protect, and explain why the record is required for that purpose.

7.4 – TechTraders will respond within 30 days, which period may be extended in the circumstances permitted by PAIA.

8. FEES

PAIA provides for a request fee and an access fee, as prescribed by regulation. Requests for a requester's own personal information are not subject to a request fee. The Information Officer will notify the requester of any fees payable before processing the request, and may require a deposit where applicable. Current prescribed fees are set out in the regulations published under PAIA.

9. GROUNDS FOR REFUSAL

TechTraders may refuse a request for access on the grounds set out in Chapter 4 of Part 3 of PAIA, including:

• Mandatory protection of the privacy of a third party who is a natural person;
• Mandatory protection of commercial information of a third party;
• Mandatory protection of confidential information;
• Protection of records privileged from production in legal proceedings;
• Commercial information of TechTraders;
• Where the request is manifestly frivolous or vexatious.

10. REMEDIES

A requester who is dissatisfied with a decision may lodge a complaint with the Information Regulator, or apply to a competent court, in accordance with PAIA. There is no internal appeal in respect of a private body.

11. AVAILABILITY OF THE MANUAL

This manual is available on this Website, at the registered office of TechTraders during business hours, and on request from the Information Officer. It will be updated as required.