Compliance

Comprehensive PAIA & POPIA Compliance Manual for Jenweedie (Pty) Ltd

Registration Number: 2019/165864/07

This document combines:

• The Manual required in terms of Section 51 of the Promotion of Access to Information Act (PAIA).

• The company's policy and procedures regarding PAIA and the Protection of Personal Information Act (POPIA).

• Templates for internal and external compliance notices as required by law.

Date of Compilation: 2 September 2025

Date of Next Revision: 1 September 2026

Table of Contents

PART 1: PUBLIC-FACING PAIA MANUAL

1. Introduction

2. Contact Details (Information Officer)

3. The PAIA Guide (From the Information Regulator)

4. Records Automatically Available Without a Request

5. Records Available in Accordance with Other Legislation

6. Subjects and Categories of Records Held

7. Processing of Personal Information (POPIA Requirements)

8. Procedure for Requesting Access to Records

9. Prescribed Fees

10. Availability of This Manual

PART 2: INTERNAL COMPLIANCE POLICIES & PROCEDURES

11.   Annual Reporting Requirements

12.  Duty to Make PAIA Guide Available

13.  Implementation and Compliance Checklist

ANNEXURES

• ANNEXURE A: Notice of Categories of Records Automatically Available

PART 1: PUBLIC-FACING PAIA MANUAL

1. Introduction

This manual is prepared in accordance with Section 51 of the Promotion of Access to Information Act, 2 of 2000 ("PAIA") and incorporates the requirements of the Protection of Personal Information Act, 4 of 2013 ("POPIA"). It is designed to provide a reference to the records held by Jenweedie (Pty) Ltd and the process to request access to such records.

2. Contact Details

The responsibility for ensuring compliance with PAIA and POPIA has been delegated to the Information Officer.

Role:

Information Officer

Full Name:

Jenine A de Wet

Position:

Managing Director

Postal Address:

16 Capricorn Drive, Lonehill, Johannesburg

Street Address:

16, Capricorn Drive, Lonehill, Johannesburg

Phone Number:

084 018 8025

Fax Number:

N/A

Email Address:

jenine@jenweedie.earth

3. The PAIA Guide (From the Information Regulator)

The Information Regulator has compiled a guide in terms of Section 10 of PAIA to assist any person who wishes to exercise any right contemplated in PAIA. This guide is available from the Information Regulator in all official languages. Any enquiries regarding this guide should be directed to:

The Information Regulator (South Africa)

JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001

Postal Address: P.O. Box 31533, Braamfontein, Johannesburg, 2017

Website: https://www.inforegulator.org.za/

General Enquiries: enquiries@inforegulator.org.za

4. Records Automatically Available Without a Request

Certain categories of records are automatically available without a person having to request access in terms of PAIA. The formal notice outlining these records is attached as Annexure A to this document. These records include, among others, marketing material, public company policies, and website content.

5. Records Available in Accordance with Other Legislation

Where applicable, Jenweedie (Pty) Ltd retains records in terms of the following legislation. Access to these records must be conducted in accordance with the procedures of the relevant act.

• Basic Conditions of Employment Act 75 of 1997

• Companies Act 71 of 2008

• Compensation for Occupational Injuries and Diseases Act 130 of 1993

• Consumer Protection Act 68 of 2008

• Employment Equity Act 55 of 1998

• Income Tax Act 58 of 1962

• Labour Relations Act 66 of 1995

• Value Added Tax Act 89 of 1991

6. Subjects and Categories of Records Held

Jenweedie (Pty) Ltd holds the following categories of records on the following subjects.

Companies Act Records

• Memorandum of Incorporation • Minutes of Board and Shareholder meetings • Records relating to the appointment of directors • Share Register • Annual Financial Statements

Financial Records

• Accounting Records • Invoices, Statements, and Proofs of Payment • Tax Records (VAT, PAYE, Income Tax) • Asset Register • Bank Statements

Human Resources

• Employment contracts • Employee personal information • Employment equity plans • Disciplinary records • Salary and payroll information • Leave records • Training records

Operations

• Client/Customer records • Supplier agreements and records • Service level agreements • Project management records • Operational policies and procedures

Information Technology

• IT policies and procedures • Network and systems documentation • Software licensing agreements • Information security records

7. Processing of Personal Information (POPIA Requirements)

7.1 Purpose of Processing Personal Information

Jenweedie (Pty) Ltd processes personal information for purposes including, but not limited to:

• Fulfilling contractual obligations with clients and suppliers.

• Employment purposes (recruitment, administration, payroll).

• Complying with legal and regulatory obligations.

• Marketing and communication, subject to consent.

• Security and access control.

7.2 Categories of Data Subjects and Personal Information Processed

• Employees / Directors 

  • Name, ID number, contact details, address, qualifications, employment history, tax information, banking details, performance information. 

• Clients / Customers

  • Name, contact details, address, VAT/Tax numbers, financial information, contract details. 

• Suppliers / Service Providers

  • Name, contact details, VAT/Tax numbers, B-BBEE status, banking details, contract details.

7.3 Recipients of Personal Information

We may share personal information with statutory bodies (e.g., SARS), third-party service providers (e.g., payroll administrators, IT support), and professional advisors (e.g., auditors, legal counsel).

7.4 Transborder Flows of Personal Information

Jenweedie (Pty) Ltd may transfer personal information across South African borders for specific business purposes, such as using cloud-based services for data storage, email, or application hosting (e.g., Microsoft 365, Google Workspace, Dropbox). We ensure that any such transfer complies with POPIA, ensuring the recipient is subject to laws or binding corporate rules that provide an adequate level of protection for personal information.

7.5 Information Security Measures

We have implemented suitable organisational and technical security measures to protect the personal information under our care, including access controls, firewalls, data encryption where appropriate, and internal data protection policies.

8. Procedure for Requesting Access to Records

A request for access to a record must be made on the prescribed Form 2, which is available from the Information Regulator's website (www.inforegulator.org.za) or from our offices. The completed form, along with the prescribed request fee, must be submitted to the Information Officer at the contact details provided in Section 2 of this manual.

9. Prescribed Fees

The following fees apply to requests made under PAIA:

• Request Fee: A requester must pay the prescribed fee of R140.00 (or the latest prescribed amount).

• Access Fees: An access fee will be charged for the search, preparation, and reproduction of the record if the request is granted. A schedule of these fees is available from the Information Officer.

10. Availability of This Manual

This manual is available for inspection at the principal place of business of Jenweedie (Pty) Ltd during normal business hours, on our website at www.jenweedie.earth and has been submitted to the Information Regulator via its designated portal.

PART 2: INTERNAL COMPLIANCE POLICIES & PROCEDURES

11. Annual Reporting Requirements

The Information Officer is responsible for submitting an annual report to the Information Regulator in terms of Section 32 of PAIA. This report details the number of PAIA requests received, granted, and refused during the reporting period (01 January to 31 December).

• Responsibility: Information Officer

• Deadline: 30 June of each year for the preceding year.

• Action: Monitor the Information Regulator's website for the latest report template and submission guidelines.

12. Duty to Make PAIA Guide Available

The Information Officer is responsible for ensuring that a copy of the official PAIA Guide, as published by the Information Regulator, is made available for public inspection at the company's head office during normal business hours.

• Action: Download the guide in at least two official languages from the Regulator's website and ensure it is accessible (either as a printed copy or on a readily available computer).

13. Implementation and Compliance Checklist

The Information Officer shall use this checklist to ensure ongoing compliance:

Finalise and approve this Manual. ☐

Make Manual available on the company website. ☐

Make Manual available for inspection at the office. ☐

Upload Manual to the Information Regulator's portal. ☐

Finalise and display the Annexure A Notice. ☐

Upload the Annexure A Notice to the Regulator's portal. ☐

Register Information Officer & Deputies with the Regulator. ☐

Submit annual Section 32 report by 30 June. ☐

Make PAIA Guide available at the office. ☐

ANNEXURE A: Notice of Categories of Records Automatically Available

(Notice in terms of Section 51(1)(c) of PAIA)

In terms of Section 51(1)(c) of the Promotion of Access to Information Act, 2 of 2000 ("PAIA"), Jenweedie (Pty) Ltd makes the following categories of records automatically available for inspection, purchase, or photocopying. No formal PAIA request is required.

• Company Information: Publicly available company statutory information and website content (www.jenweedie.earth).

• Marketing & Communication: Product and service brochures, public newsletters, and published press releases.

• Public Policies: Website Privacy Policy, Public Terms of Service.

These records are available for inspection at our principal place of business at 16 Capricorn Drive, Lonehill, Johannesburg or via our website.