Section 51 PAIA Manual
How to request access to records held by Assent Compliance (Pty) Ltd under the Promotion of Access to Information Act, and how we process personal information under POPIA.
1. Introduction and purpose
The Promotion of Access to Information Act 2 of 2000 ("PAIA") gives effect to the constitutional right of access to information held by private bodies where that information is required for the exercise or protection of any rights. Section 51 of PAIA requires a private body to compile a manual explaining what records it holds and how to request access to them.
This manual sets out how to request records from Assent Compliance (Pty) Ltd ("Assent Compliance"), the categories of records we hold, the applicable fees, and how we process personal information as required by the Protection of Personal Information Act 4 of 2013 ("POPIA").
Assent Compliance is a private company that provides compliance consulting services and presents training seminars and webinars, mainly to healthcare practices, on credit management, professional ethics and the law, and data-protection compliance.
2. Company and contact details
- Name of private bodyAssent Compliance (Pty) Ltd
- Registration number2017/000982/07
- Information OfficerAdv. F.J.P. Marais
- Physical and postal address58 Laguna Beach Greenways, Cape Town, Western Cape, 7139
- Telephone061 515 5194
- E-mail for PAIA and POPIA requestsmarais@assentcompliance.co.za
- Websiteassentcompliance.co.za
All requests for access to records, and all POPIA objections, correction and deletion requests, must be addressed to the Information Officer.
3. The Information Regulator's guide on PAIA
The Information Regulator has compiled and made available a guide on how to use PAIA and POPIA, as required by section 10 of PAIA. The guide explains the objects of PAIA and POPIA, the contact details of information officers, the request procedure, the assistance available and the remedies available to requesters. It is available in all official languages.
The guide may be inspected or obtained free of charge on the Information Regulator's website (inforegulator.org.za/paia-guidelines), at the Regulator's offices, or on request from our Information Officer during office hours.
- Information RegulatorWoodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191
- Telephone010 023 5200
- General enquiriesenquiries@inforegulator.org.za
- PAIA complaintsPAIAComplaints@inforegulator.org.za
- Websiteinforegulator.org.za
4. Records automatically available (section 52)
Assent Compliance has not published a notice in terms of section 52(2) of PAIA. The following information is, however, freely available without a formal request: the content of our website, including the details of our seminars and webinars, our Website Terms and Conditions, our Privacy Notification and this manual.
5. Records kept in terms of other legislation
Assent Compliance keeps records as required by the following legislation, where applicable. Some of these records may be available only to the persons or bodies specified in that legislation.
- 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
- Electronic Communications and Transactions Act 25 of 2002
- Employment Equity Act 55 of 1998
- Income Tax Act 58 of 1962
- Labour Relations Act 66 of 1995
- Occupational Health and Safety Act 85 of 1993
- Promotion of Access to Information Act 2 of 2000
- Protection of Personal Information Act 4 of 2013
- Skills Development Levies Act 9 of 1999
- Tax Administration Act 28 of 2011
- Unemployment Insurance Act 63 of 2001 and Unemployment Insurance Contributions Act 4 of 2002
- Value-Added Tax Act 89 of 1991
6. Subjects and categories of records held
The listing of a category does not mean that access will be granted. Every request is considered in terms of PAIA, and access may be refused on the grounds in section 8 below.
| Subject | Categories of records |
|---|---|
| Company and statutory | Memorandum of incorporation, registration documents, records of directors, minutes and resolutions, share register, statutory returns. |
| Financial and tax | Accounting records, annual financial statements, bank records, invoices and pro-forma invoices, asset register, tax and VAT records and returns. |
| Personnel | Employment contracts, personnel files, payroll and leave records, tax and UIF records, training records, disciplinary records (where any). |
| Clients and consulting | Engagement letters and agreements, correspondence, compliance assessments, reports and working papers prepared for clients. |
| Training and events | Seminar and webinar registrations, delegate lists and attendance records, assessment and CPD records, certificate register, course manuals, presentations and templates, venue and event arrangements. |
| Marketing and communications | Mailing lists of persons who opted in, newsletters, website contact-form messages, marketing material. |
| Suppliers and service providers | Supplier agreements, operator agreements under POPIA, quotations, invoices and correspondence. |
| Information technology | Website and hosting records, IT policies, system and security logs, software licences. |
| Policies and compliance | POPIA and PAIA compliance documents, information-security policies, this manual, internal policies and procedures. |
7. How to request access to a record
- Use the prescribed form. Complete Form 2 (Request for access to record, regulation 7 of the PAIA Regulations, 2021), available from the Information Regulator's website or from our Information Officer.
- Send it to the Information Officer at the e-mail or physical address in section 2.
- Give enough detail to identify the record and the requester, state the form of access you want, and give your contact details. You must identify the right you are seeking to exercise or protect and explain why the record is required for that purpose (section 53 of PAIA).
- Requests on behalf of someone else must include proof of the capacity in which you make the request.
- Pay the request fee (see section 10), unless you are requesting your own personal information. Proof of payment must accompany the request.
- Decision. We will decide on the request within 30 days after receiving it and notify you of the outcome on Form 3 (regulation 8), including any access fee payable. The period may be extended once by up to 30 days in the circumstances set out in section 57 of PAIA, in which case we will notify you. If we do not decide within the prescribed period, the request is regarded as refused (section 58).
- Assistance. If you need help completing the form, or cannot read or write, the Information Officer will assist you.
8. Grounds for refusal
Access to a record may or must be refused on the grounds set out in Chapter 4 of Part 3 of PAIA, including where access would involve:
- the unreasonable disclosure of personal information about a third party, including a deceased individual (section 63);
- the commercial information of a third party, such as trade secrets or confidential financial, commercial or technical information (section 64);
- a breach of a duty of confidence owed to a third party in terms of an agreement (section 65);
- a danger to the life or physical safety of an individual, or to the security of property (section 66);
- records privileged from production in legal proceedings (section 67);
- the commercial information of Assent Compliance, including trade secrets, information that would prejudice our commercial or financial interests, or computer programs we own (section 68);
- research information of Assent Compliance or a third party where disclosure would seriously disadvantage the researcher or the subject matter (section 69).
A request may also be refused if it is manifestly frivolous or vexatious, or if processing it would substantially and unreasonably divert our resources. Access must nevertheless be granted where disclosure would reveal a substantial contravention of the law or an imminent and serious public-safety or environmental risk, and the public interest clearly outweighs the harm (section 70).
9. Remedies
Assent Compliance has no internal appeal procedure. If you are dissatisfied with a decision on your request (including a refusal, the fees, an extension or the form of access), you may:
- lodge a complaint with the Information Regulator within 180 days of the decision, using Form 5 (section 77A of PAIA); or
- apply to a court with appropriate jurisdiction for relief, after exhausting the complaints procedure with the Information Regulator (section 78 of PAIA).
10. Fees
The fees below are prescribed for private bodies under the PAIA Regulations, 2021. No request fee is payable by a personal requester (a person requesting their own personal information), although reproduction fees may apply. Where applicable, VAT may be added.
| Item | Fee |
|---|---|
| Request fee (payable by every requester other than a personal requester) | R140.00 |
| Photocopy or printed copy of an A4 page (or part of a page) | R2.00 per page |
| Copy in a computer-readable form on a flash drive or CD supplied by the requester | R40.00 |
| Copy in a computer-readable form on a CD supplied by Assent Compliance | R60.00 |
| Transcription of an audio record | R24.00 per A4 page |
| Copy of an audio record on a flash drive or CD supplied by the requester / by Assent Compliance | R40.00 / R60.00 |
| Transcription or copy of visual images | As quoted by the service provider |
| Search and preparation time, per hour or part of an hour, excluding the first hour | R145.00 |
| Maximum search and preparation fee | R435.00 |
| Deposit where search and preparation will exceed six hours | One third of the access fee |
| Postage, e-mail or other electronic transfer | Actual cost, if any |
Access to a record will be withheld until all applicable fees have been paid. If a request is refused, any deposit paid will be refunded.
11. Processing of personal information (POPIA)
11.1 Purposes of processing
- to register delegates for seminars and webinars, issue pro-forma and tax invoices, manage attendance, issue certificates and maintain the certificate register so that certificates can be verified;
- to provide consulting services to clients and to communicate with clients, delegates and enquirers;
- to send information about future events to persons who have opted in, with an option to unsubscribe in every communication;
- to manage suppliers and service providers;
- to employ and manage staff, and to meet our obligations under labour, tax and other legislation;
- to keep accounting and tax records, protect our legal rights and comply with the law;
- to keep our website and systems secure.
11.2 Categories of data subjects and personal information
| Data subjects | Personal information processed |
|---|---|
| Delegates | Name, e-mail address, practice or organisation, dietary and accessibility requirements (only if provided), attendance, assessment and certificate details. |
| Clients and booking contacts | Name, contact details, organisation, VAT number, billing address, purchase-order references, payment and invoice records, correspondence. |
| Enquirers and website users | Name, contact details and message content submitted through our forms; technical data such as IP address for security and spam prevention. |
| Marketing subscribers | Name, e-mail address and subscription preferences. |
| Suppliers and service providers | Names of contact persons, contact details, banking details, VAT and company registration numbers, agreements. |
| Employees and job applicants | Identity and contact details, qualifications, employment history, remuneration, banking, tax and statutory information, and other information required by employment law. |
11.3 Recipients or categories of recipients
Personal information may be shared, where necessary and lawful, with: our website hosting and e-mail service providers; video-conferencing providers used for webinars; event venues (delegate names only, where required); our accountants, auditors and legal advisers; banks; professional or accrediting bodies (for CPD purposes, where applicable); and SARS and other regulators, courts or authorities where required by law. Service providers who process personal information on our behalf are bound by operator agreements or confidentiality obligations as required by section 21 of POPIA.
11.4 Planned transborder flows of personal information
Some of our service providers, such as e-mail, cloud-storage and video-conferencing providers, may store or process personal information on servers outside South Africa. We only use providers that are subject to a law, binding corporate rules or a binding agreement providing an adequate level of protection, or where the transfer is otherwise permitted by section 72 of POPIA.
11.5 Security measures
We take appropriate, reasonable technical and organisational measures to protect personal information against loss, damage, unauthorised destruction and unlawful access or processing, as required by section 19 of POPIA. These include encrypted (HTTPS) connections to the website, storing registration and certificate records outside the publicly accessible part of the web server, password-protected and access-restricted systems, limits on repeated access attempts, regular back-ups, operator agreements with service providers, and limiting access to personal information to persons who need it.
12. Objection, correction and deletion
- Objection to processing. A data subject may object to the processing of their personal information on reasonable grounds, or to processing for direct marketing at any time, using Form 1 of the POPIA Regulations, 2018.
- Correction or deletion. A data subject may request the correction or deletion of personal information, or the destruction or deletion of a record, using Form 2 of the POPIA Regulations, 2018.
- Access to your own information. You may ask us whether we hold personal information about you and request a copy, using Form 2 of the PAIA Regulations, 2021 as described in section 7. No request fee is payable for your own personal information.
Send these forms to the Information Officer at marais@assentcompliance.co.za. You also have the right to lodge a complaint with the Information Regulator about the processing of your personal information.
13. Availability and updating of this manual
This manual is available on our website, for inspection at our address during office hours free of charge, and to the Information Regulator on request. A printed copy may be obtained on payment of the prescribed reproduction fee. Assent Compliance will update this manual whenever there are material changes to the information in it.
Issued by Adv. F.J.P. Marais, Information Officer, Assent Compliance (Pty) Ltd. Last updated 28 October 2026.