PAIA Policy

Access to Information Manual 

June 2022 | Version 1.2

We respect your right of access to information. This manual will help you (the requester of information) to exercise that right and help you know how you may get access to our records. The Promotion to Access of Information Act 2 of 2000 as amended from time to time (known as PAIA) requires us to draft and make this manual available to you.

  • Know what types of information we have.
  • Know how to request access to it.

Keeping you updated

1510 Blue Francolin Street, Rietvalleirand, Pretoria, South Africa, 0174 Reg No. 2017 / 377799 / 07

Contents

1. Introduction 3

2. Our contact details 3

3. Further guidance from the Information Regulator 4

4. Records which we make automatically available 4

5. Records we hold to function 4

Establishment records 5

Business records 5

Financial records 5

Insurance records 5

Income tax records 6

Personnel records 6

Policies and directives 6

Agreements or contracts 7

Regulatory documents 7

Published information 7

Customer information 7

Reference materials 7

6. Records we hold to comply with the law 8

7. How you can request access 8

8. How we will give you access 9

9. How much it will cost you 9

Request fees 9

Access fees 9

10. Grounds for us to refuse access 10

Protection of someone else’s privacy (a natural person) 11

Protection of another organisation’s commercial information 11

Protection of the safety of individuals and property 11

Protection of research information 12

Our decision on giving you access 12

11. Remedies available if we refuse to give you access 12

  1. Introduction

We assist customers and businesses to manage, update and verify personal and customer information.

We act as a neuron that informs businesses and individuals when information has been updated. By doing so companies will always have their clients’ latest personal information available.

Customers will be notified when their information are verified and when they need to verify their updated details. By doing so customers are made aware of possible identity fraud and can proactively react on misuse of their information.

PAIA requires the information officer of a private body to compile a manual that contains information on the records it holds. A ‘private body’ means a natural person, company or other type of juristic entity that carries on any trade, business or profession and includes a political party. We are a private body.

  1. Our contact details
Organisation nameNeuronMe (Pty) Ltd
Websitehttps://neuronme.co.za/
Registration number2017/377799/07
Postal address1510 Blue Francolin Street, Rietvalleirand, Pretoria, South Africa, 0174 
Physical address1510 Blue Francolin Street, Rietvalleirand, Pretoria, South Africa, 0174 
Phone number073 943 4701
Default information officerHeinrich Barnes
Deputy information officer (if applicable)Piet Dreyer
Information officer emailinfo@neuronme.co.za
Information officer phone number073 943 4701
  1. Further guidance from the Information Regulator

For further guidance, contact the Information Regulator. They have compiled a PAIA guide in each official language of South Africa on how to exercise your rights under PAIA. 

Visit their websitewww.inforegulator.org.za 
Postal addressP.O Box 3153, Braamfontein, Johannesburg, 2017
Physical address JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
Phone number010 023 5200
Ask a general enquiry by emailenquiries@inforegulator.org.za  
Lodge a complaint by emailPAIAComplaints@inforegulator.org.za 
  1. Records which we make automatically available

We make some records automatically available to you without you needing to request access to them. 

Type of recordHow you can access it
Memorandum of incorporation (MOI)BizPortal
Directors’ namesBizPortal
Documents of incorporationBizPortal
Banking detailsRequest by email
BrochuresRequest by email
External newsletters and circularsSubscribing or on our website
Information on our websiteVisit our website
  1. Records we hold to function

We hold the following subjects and categories of records in electronic or physical format, which we do not make automatically available. You may request access to them. 

  1. Establishment records

Our records related to the establishment, registration, incorporation, or administration of our organisation. Some of them may be available from BizPortal, via BizProfile, a search tool for all companies registered on the Companies and Intellectual Property Commission (CIPC).

  • Minutes of board or director meetings 
  • Written resolutions
  • Records relating to appointment of directors, auditor, secretary, public officer, or other officers
  • Share register and other statutory registers
  • Other statutory records
  1. Business records

Documents that have economic value to the business.

  • Operational records
  • Databases
  • Published works
  • Internal correspondence
  • Product records
  1. Financial records

Our records related to our finances.

  • Financial statements  
  • Tax returns
  • Other documents relating to tax
  • Accounting records
  • Auditor reports
  • Banking records
  • Bank statements
  • Electronic banking records
  • Paid cheques
  • Asset register
  • Invoices
  • Financial agreements
  1. Insurance records

Our records related to our insurable assets.

  • Insurance policies we hold
  • Records of insurance claims
  • Register of all immovable property owned by the company
  1. Income tax records

Our records related to our income tax obligations.

  • PAYE Records
  • Corporate tax records
  • Customs tax
  • Documents issued to employees for income tax purposes
  • Records of payments made to SARS on behalf of employees
  • VAT records
  • Regional Services Levies
  • Skills Development Levies
  • UIF
  • Workmen’s Compensation
  1. Personnel records

Our records about anyone who works for us, provides services to us, or provides services on our behalf and who we remunerate. This includes our employees, contractors, and other personnel.

  • List of employees
  • Employee personal information
  • Employee employment contracts
  • Employment applications and appointment letters
  • Employment policies and procedures
  • Employment Equity Plan
  • Health and safety records
  • Medical aid records
  • Pension and provident fund records
  • Salaries or wages of employees
  • Leave records
  • Internal evaluations and performance records
  • Disciplinary records
  • Disciplinary codes
  • Training records
  • Operating manuals
  • Personal records provided by personnel
  • Other statutory records
  • Related correspondence
  1. Policies and directives

Both internal and external documents.

  • Internal: relating to employees and the organisation
  • External: relating to customers and other third parties
  • Information technology systems and documents
  1. Agreements or contracts

Both the documents themselves and all related documents.

  • Standard agreements
  • Contracts concluded with customers
  • NDAs
  • Letters of intent, MOUs
  • Third party contracts (such as JV agreements, VAR agreements, etc.)
  • Office management contracts
  • Bond agreements
  • Rental agreements
  • Supplier or service contracts
  1. Regulatory documents

Any documents we need to comply with any laws.

  • Permits
  • Licences
  • Authorities
  1. Published information

Any document that we prepare and produce.

  • Internal newsletters and circulars
  • Information on the company published by third parties
  1. Customer information

Any information about anyone that we provide goods or services to, including our customers, leads, or prospects.

  • Customer details
  • Contact details of individuals within customers
  • Communications with customers
  • Sales records
  • Transactional information
  • Marketing records
  1. Reference materials

Any sources of information that we contribute to.

  • Books
  • Newsletters and journals articles
  • Magazines
  • Newspaper articles
  1. Records we hold to comply with the law

We hold records that all organisations are required by law to hold. We also hold records that the law specifically requires organisations like ours to retain. Please ask our information officer for details.

Although we have used our best endeavours to supply a list of applicable legislation, it is possible that this list may be incomplete. Whenever it comes to our attention that existing or new legislation allows you access on a basis other than as set out in PAIA, we will update the list accordingly. If you believe that a right of access to a record exists in terms of other legislation listed above or any other legislation, you must indicate what legislative right the request is based on, to allow our information officer to consider the request.

  1. How you can request access

We have appointed our information officer to deal with all matters relating to PAIA so we can comply with our PAIA obligations. To request access to a record, please complete Form 2

Please submit the completed form (together with the relevant request fee we explain below) to our information officer’s email address, our physical address, or by fax using the details we provide. Please ensure that the completed form:

  • has enough information for the information officer to identify you, the requested records, and the form of access you require,
  • specifies your email address, postal address, or fax number,
  • describes the right that you seek to exercise or protect,
  • explains why you need the requested record to exercise or protect that right,
  • provides any other way you would like to be informed of our decision other than in writing, and
  • provides proof of the capacity in which you are making the request if you are making it on behalf of someone else (we will decide whether this proof is satisfactory).

If you do not use the standard form, we may:

  • reject the request due to lack of procedural compliance,
  • refuse it if you do not provide sufficient information, or
  • delay it.
  1. How we will give you access

We will evaluate and consider all requests we receive. If we approve your request, we will decide how to provide access to you – unless you have asked for access in a specific form. Publication of this manual does not give rise to any rights to access information records, except in terms of PAIA.

  1. How much it will cost you
    1. Request fees

When submitting your request, you must pay us a request fee as the law prescribes, which needs to be paid before we give you access. You will receive a notice from our information officer upon your request, setting out the application procedure.  

  1. Access fees

If we grant the request, you will have to pay us a further access fee as the law prescribes that includes a fee for the time it takes us to handle your request, or if the time has exceeded the prescribed hours to search and prepare the record for disclosure. Our information officer will notify you if you need to pay a deposit for the access fee. The deposit may be up to one third of the prescribed access fee. The access fee will provide for:

  • the costs of making the record, or transcribing the record, 
  • a postal fee (if applicable), and 
  • the reasonable time we need to search for the record and prepare the record for you.

If you paid the deposit and we refused your request, we will refund you the deposit amount. Until you have paid the fees, we may withhold the record you requested.

ItemDescriptionAmount
1Request fee, payable by every requesterR 140.00
2Photocopy or printed black & white copy for every A4 pageR 2.00 per page or part of the page
3Printed copy of A4-size pageR 2.00 per page or part of the page
4    For a copy in a computer-readable form on: a flash drive (provided by the requester)
a compact disc (CD) if the requester provides the CD to us
a compact disc (CD) if we give the CD to the requester

R 40.00

R 40.00

R 60.00
5For a transcription of visual images, for an A4-size page or part of the pageThis service will be outsourced. The fee will depend on the quotation from the service provider.
6For a copy of visual imagesThis service will be outsourced. The fee will depend on the quotation from the service provider.
7For a transcription of an audio record, per A4-size pageR 24.00
8For a copy of an audio record on a flash drive (provided by the requester)
For a copy of an audio record on compact disc (CD) if the requester provides the CD to us
For a copy of an audio record on compact disc (CD) if we give the CD to the requester
R 40.00


R 40.00


R 60.00
For each hour or part of an hour (excluding the first hour) reasonably required to search for, and prepare the record for disclosure
The search and preparation fee cannot exceed
R 145.00

R 435.00
10Deposit: if the search exceeds 6 hoursOne-third of the amount per request. It is calculated in terms of items 2 to 8 above.
11Postage, email, or any other electronic transferActual expense, if any.
  1. Grounds for us to refuse access

We may have to refuse you access to certain records in terms of PAIA to protect:

  • someone else’s privacy,
  • another company’s commercial information,
  • someone else’s confidential information,
  • research information,
  • the safety of individuals and property, or
  • records privileged from production in legal proceedings.

Some of these grounds are explained in further detail below.

  1. Protection of someone else’s privacy (a natural person)

We may refuse to give you access to a record if access would unreasonably disclose a natural person’s personal information, including a deceased person.

We will not refuse access in certain circumstances. 

  • The person who the information pertains to, has given consent. 
  • The information is publicly available. 
  • The information belongs to a class of information, and the private body notified the individual upfront that the specific class of information might be made public. 
  • The record is physical or mental health information or information about someone’s well-being who is:
    • under the requester’s (your) care and below 18 years, or  
    • incapable of understanding the nature of the request and giving access would be in the individual’s best interests. 
  • The information is about a deceased person and:
    • you are the next of kin, or 
    • the request is made with the written consent of the individual’s next of kin. 
  • The information is about a person who is, or was an executive at your organisation, and the information relates to their position or functions, for example:
    • that the person was an official at our organisation,  
    • the title, work address, work phone number and other similar details, 
    • the classification, salary scale or remuneration and responsibilities of the position or services, and
    • the name of the person on a record prepared by them while employed. 
  1. Protection of another organisation’s commercial information

We may refuse to give you access to a record if the record contains another organisation’s:

  • trade secrets, 
  • financial, commercial, scientific, or technical information and the disclosure could cause harm to the financial or commercial interests of that company, 
  • information and the disclosure could put that company at a disadvantage in negotiations or commercial competition, or
  • information on a computer programme owned by us, protected by copyright.
  1. Protection of the safety of individuals and property

We may refuse access if it could reasonably be expected to endanger someone’s life or physical safety. We may refuse access to a record if disclosing it would be likely to prejudice or impair the security of: 

  • a building, structure, or system, including a computer or communication system,
  • a means of transport, 
  • any other property, 
  • methods, systems, plans or procedures for the protection of someone in a witness protection scheme, 
  • the public, or a part of the public, or 
  • the property contemplated above. 
  1. Protection of research information

We may refuse you access to a record that contains research done by us or someone else, if disclosing it would disclose our identity, the researcher’s or the subject matter of the research and would place the research at a serious disadvantage.

  1. Our decision on giving you access

We will notify you in writing whether your request has been approved or denied within 30 calendar days after receiving your request. If we cannot find the record you asked for or it does not exist, we will notify you by way of affidavit that it is not possible to give access to that record.

  1. Remedies available if we refuse to give you access

If we deny your request for access, you may:

  • apply to a court with appropriate jurisdiction, or 
  • complain to the Information Regulator, 

for the necessary relief within 180 calendar days of us notifying you of our decision.

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