PAIA & POPIA Manual

PrintQ Xpress (Pty) Ltd

PAIA and POPIA Manual

This manual was prepared in accordance with section 51 of the Promotion of Access to Information Act 2 of 2000 (as amended) and to address requirements of the Protection of Personal Information Act 4 of 2013.

Date of compilation: 22/07/2025

1. List of Acronyms and Abbreviations

CEO – Chief Executive Officer
DIO – Deputy Information Officer
IO – Information Officer
Minister – Minister of Justice and Constitutional Development
PAIA – Promotion of Access to Information Act No. 2 of 2000 (as amended)
POPIA – Protection of Personal Information Act No. 4 of 2013
Regulator – Information Regulator
Republic – Republic of South Africa

2. Overview of PrintQ Xpress (Pty) Ltd

2.1 PrintQ Xpress (Pty) Ltd (the "company") is based in Brackenfell, Cape Town, South Africa and provides printing services to the public.

2.2 For more information about the company and its services, visit the company's website at www.printq.co.za.

3. Purpose of PAIA and POPIA Manual

This PAIA Manual is useful for the public to:

check the categories of records held by the company which are available without a person having to submit a formal PAIA request;
have a sufficient understanding of how to make a request for access to a record of the company, by providing a description of the subjects on which the company holds records and the categories of records held on each subject;
know the description of the records of the company which are available in accordance with any other legislation;
access all the relevant contact details of the Information Officer and Deputy Information Officer who will assist the public with the records they intend to access;
know the description of the guide on how to use PAIA, as updated by the Regulator and how to obtain access to it;
know if the company will process personal information, the purpose of processing of personal information and the description of the categories of data subjects and of the information or categories of information relating thereto;
know the recipients or categories of recipients to whom the personal information may be supplied;
know if the company has planned to transfer or process personal information outside the Republic of South Africa and the recipients or categories of recipients to whom the personal information may be supplied; and
know whether the company has appropriate security measures to ensure the confidentiality, integrity and availability of the personal information which is to be processed.

4. Key Contact Details for Access to Information (Section 14(1)(b))

4.1 Chief Information Officer
Name: Marisa Mouton
Tel: 021 987 1164
Email: marisa@printq.co.za

4.2 No Deputy Information Officer.

4.3 Head Office
Postal & Physical Address: Unit M4, Okavango Junction, Kenwil Drive, Brackenfell, 7560
Telephone: 021 987 1164
Website: www.printq.co.za

5. Guide on How to Use PAIA and How to Obtain Access to the Guide (Section 51(1)(b) read with Section 10)

5.1 The Regulator has, in terms of section 10(1) of PAIA, as amended, updated and made available the revised Guide on how to use PAIA ("Guide"), in an easily comprehensible form and manner, as may reasonably be required by a person who wishes to exercise any right contemplated in PAIA and POPIA.

5.2 The Guide is available in each of the official languages and in braille.

5.3 The aforesaid Guide contains the description of:

the objects of PAIA and POPIA;
the postal and street address, phone and fax number and, if available, electronic mail address of the Information Officer of every public body, and every Deputy Information Officer of every public and private body designated in terms of section 17(1) of PAIA and section 56 of POPIA;
the manner and form of a request for access to a record of a public body contemplated in section 11; and access to a record of a private body contemplated in section 50;
the assistance available from the IO of a public body in terms of PAIA and POPIA;
the assistance available from the Regulator in terms of PAIA and POPIA;
all remedies in law available regarding an act or failure to act in respect of a right or duty conferred or imposed by PAIA and POPIA, including the manner of lodging an internal appeal, a complaint to the Regulator, and an application with a court against a decision by the information officer of a public body, a decision on internal appeal or a decision by the Regulator or a decision of the head of a private body;
the provisions of sections 14 and 51 requiring a public body and private body, respectively, to compile a manual, and how to obtain access to a manual;
the provisions of sections 15 and 52 providing for the voluntary disclosure of categories of records by a public body and private body, respectively;
the notices issued in terms of sections 22 and 54 regarding fees to be paid in relation to requests for access; and
the regulations made in terms of section 92.

5.4 Members of the public can inspect or make copies of the Guide from the offices of the public and private bodies, including the office of the Regulator, during normal working hours.

5.5 The Guide can also be obtained:

upon request to the Information Officer; and
from the website of the Regulator (https://www.justice.gov.za/inforeg/).

5.6 A copy of the Guide is also available in all official languages, for public inspection during normal office hours from the Information Regulator.

6. Categories of Records Available Without a Request (Section 51(1)(c))

6.1 Records that are automatically available to the public are:

All records of the company lodged in terms of government requirements with various statutory bodies, including the Companies and Intellectual Property Commission (CIPC) and the Registrar of Deeds.
All records in booklets, brochures, pamphlets, and magazines (if any) published by the company or any of its agents or representatives for distribution to the public relating the company services and/or products.
All records on the company website.

6.2 A requester may request a copy of a record referred to under 6.1 above and must be provided with such copy, upon payment of the fee for reproduction, as provided for in Items 2 to 8 of Annexure B to this Manual.

7. Records Available in Terms of Other Legislation (Section 51(1)(d))

7.1 The company is required to keep particular records, in terms of certain statutes. Insofar as may be applicable, the company keeps records of information to the extent required in terms of the following legislation, as amended, and codes of best business practice:

Basic Conditions of Employment Act 75 of 1997
BBBEE Act 53 of 2003
Companies Act 38 of 2005
Compensation for Occupational Injuries and Health Diseases Act 130 of 1993
Competition Act 89 of 1998
Constitution of South Africa Act 108 of 1996
Consumer Protection Act 68 of 2008
Criminal Procedures Act 51 of 1977
Copyright Act 98 of 1978
Corporate Laws Amendment Act 24 of 2006
Currency and Exchanges Act 9 of 1933
Debt Collectors Act 114 of 1998
Electronic Communications & Transactions Act 25 of 2002
Employment Equity Act 55 of 1998
Employment Equity Regulations of 2006
Financial Advisory and Intermediary Services Act 37 of 2002
Financial Intelligence Centre Act 38 of 2001
Financial Relations Act 65 of 1976
Financial Services Board Act 97 of 1990
Income Tax Act 58 of 1962
King IV Report on Corporate Governance
Labour Relations Act 66 of 1995
National Credit Act 34 of 2005
Occupational Health and Safety Act 85 of 1993
Pension Fund Act 24 of 1956
Prevention of Combating of Corrupt Activities Act 12 of 2004
Prevention of Organised Crime Act 121 of 1998
Promotion of Access to Information Act 2 of 2000
Protected Disclosures Act 26 of 2000
Protection of Personal Information Act 4 of 2013
Protection of Business Act 99 of 1978
Regulation of Interception of Communications and Provision of Communication-Related Information Act; Revenue Laws Amendment Act 45 of 2003
Skills Development Act 97 of 1998
Skills Development Levies Act 9 of 1999
Unemployment Contributions Act 4 of 2002
Unemployment Insurance Act 63 of 2001
Tax Administration Act 28 of 2011
Value-Added Tax Act 89 of 1991

7.2 Information and records held by the company in terms of any of the abovementioned legislation will be made available in terms of the provisions of the relevant legislation, but without prejudice to the provisions of the Promotion of Access to Information Act. The above list is non-exhaustive.

8. Types of Records Held by the Company (Section 51(1)(e))

The company maintains records on the following categories and subject matters. Please note that recording a category or subject matter in this Manual does not imply that a request for access to such records would be granted. All requests for access will be evaluated on a case-by-case basis in accordance with the provisions of PAIA. Please further note that the below listed records are not exhaustive.

8.1 Company Secretariat

Applicable statutory documents such as, but not limited to:

Minutes of executive and other decision-making operational bodies;
Documents of Incorporation;
Memorandum of Incorporation;
Minutes of Board of Directors' Meetings and Board sub-committee Meetings;
Share Registers and other Statutory Registers;
Statutory Registers;
Delegations of authority;
Other statutory documents of a legal and commercial nature; and
Attendance Registers and Directors Registers.

8.2 Enterprise-wide Risk Management

Anti-money laundering;
Fraud Prevention Policy, Strategy and Plans; and
Risk Management and Compliance Programme.

8.3 Finance and Support Services

All accounting records as required by the Companies Act, 1973;
Asset register;
Finance and Lease Agreements;
Copies of all Income Tax Returns and other tax returns and documents; and
Internal and External Audit Reports.
Procurement Policy.

8.4 Human Resources and Industrial Relations

Human Resources Policy Manual;
Employee recruitment records;
Records and contracts entered into with the employees;
Records pertaining to employee benefits;
Records pertaining to statutory obligations of the company as employer;
Documents pertaining to Human Resources Policies and Procedures;
Documents pertaining to staff performance reviews;
Documents pertaining to the development of employees;
Documents relating to appointments, promotions, disciplinary actions and termination; and
Attendance registers.

8.5 Information Management and Technology

IT Governance Framework;
IT Risk Management Framework;
IT standards, policies, procedures and guidelines;
Licensing agreements;
Disaster Recovery Plan; and
Audit of Systems.

8.6 Client Related Records

A "client" refers to any natural or juristic entity that receives services from the company. These records include but are not limited to:

records provided by clients in respect of their business and in terms of the contractual arrangements between the company and clients;
records generated by or within the company related to its clients, including transactional records;
records pertaining to third-party information provided by clients; or
records provided by third parties in the course of doing business with the company.

8.7 Other Company Records

Documents relating to the operational, commercial and financial interests of the company;
Commercial and other legal contracts or agreements;
Client and other data bases;
Information on existing and past litigation;
Trade Mark and Intellectual Property applications, certificates and information;
Administrative Information;
Licenses;
Human Resources Information;
Insurance Policies;
Marketing records;
Internal and external correspondence;
Disaster recovery plans;
The company services records;
Internal policies and procedures;
Records held by officials of the company.

8.8 Where any of the above records contain Personal Information and a request is submitted, the provisions of PAIA as well as POPIA will apply accordingly. "Personal information", as defined in POPIA, means information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, including, but not limited to those categories as defined in section 1 of POPIA.

9. Other Information as May Be Prescribed (Section 51(1)(f))

The company may possess records pertaining to other parties, including without limitation contractors, suppliers, subsidiary/holding/sister companies, joint venture companies and service providers. Alternatively, such other companies may possess records that can be said to belong to the company.

Personnel, client or private records which are held by another party as opposed to the records held by the company.
Records held by the company pertaining to other parties, including but not limited to financial, commercial, operational and legal records, contractual records, correspondence, records provided by the other party, and records provided by third parties about contractors/suppliers.

10. Processing of Personal Information (Section 11, Section 24 to 33)

10.1 Purpose of Processing Personal Information

At all times, personal information will be collected and only used for specific purposes that are linked to the business needs or interests of the company.
The data subject will be aware of the information being collected and the specific purposes for which it is being collected.
Personal information will only be kept for such time as required for the specified purpose, as specified by the individual (where lawful), as specified by organisational rules and as required by law.
Once personal information is no longer needed to fulfil the specific purpose it was collected for, it will be securely disposed of in such a way that prevents its reconstruction in an intelligible form.
In cases where personal information needs to be retained, archived or kept for proof or evidentiary purposes, access to such records will be appropriately secured so that this information cannot be used for any other purposes.
If personal information is to be used for a purpose other than the one that was specified at the time it was collected, consent from the data subject for the new purpose will be obtained prior to using the personal information for the new purpose.
In cases where personal information is anonymised to the extent that it is not possible to identify data subjects, then such information may be used for other purposes and data subject consent is not required.

10.2 Description of the Categories of Data Subjects and of the Information Relating Thereto

10.3 Categories of Data Subjects

Natural Persons: Names; contact details; physical and postal addresses; date of birth; ID number or passport number; tax related information; nationality; gender; confidential correspondence.
Service Providers: Names, registration number, VAT numbers, address, trade secrets and bank details.
Employees: ID number, contact details, address, qualifications, gender and race.
Juristic Persons / Entities: Names of contact persons; name of legal entity; physical and postal address and contact details; financial information; registration number; founding documents; tax related information; authorised signatories, beneficiaries; ultimate beneficial owners.
Board of directors: Names; gender; marital status; ethnicity; age; home language; educational information; financial information; employment history; ID number; physical and postal address; contact details.

10.4 Recipients or Categories of Recipients to Whom the Personal Information May Be Supplied

the company's employees;
third parties such as Government Institutions, Funds and Service Providers;
auditors; and
as required by law.

10.5 Planned Transborder Flows of Personal Information

The transfer of personal information to third parties outside the Republic of South Africa is prohibited unless the transfer adheres to the requirements of POPIA.
Personal information may only be transferred to legal jurisdictions which have similar data protection laws to POPIA and as allowed by any regulations.
Where such laws do not exist, the company will ensure that appropriate security safeguards are in place and that the organisation to which the information is transferred agrees to uphold the conditions of POPIA. The company's CIO must evaluate such transfers of information.

10.6 Description of Information Security Measures Being Implemented by the Company

In order to secure the integrity and confidentiality of the personal information in our possession, and to protect it against loss or damage or unauthorised access, the Company has implemented the following security safeguards:

firewalls;
anti-virus;
locked storage;
password protected computers;
password protected payroll software;
encrypted servers;
encrypted email;
business premises where records are kept will remain protected by access control, burglar alarms and armed response;
vulnerability assessments will be carried out on the Company digital infrastructure to identify weaknesses and to ensure we have adequate security in place; and
the Company's staff will be trained to carry out their duties in compliance with POPIA, and this training will be ongoing.

The Company will continually assess the suitability of the information security measures in order to ensure that the Personal Information that is processed by the Company is safeguarded and processed in accordance with the Conditions for Lawful Processing.

11. Data Subject Participation and Information Officer Duties and Responsibilities

This PAIA Manual gives effect to sections 23 and 55 of POPIA.

11.1 Section 23(1) of POPIA states that: "A data subject, having provided adequate proof of identity, has the right to – (a) request a responsible party to confirm, free of charge, whether or not the responsible party holds personal information about the data subject; (b) request from a responsible party the record or a description of the personal information about the data subject held by the responsible party, including information about the identity of third parties, or categories of third parties, who have, or have had, access to the information – (i) within a reasonable time; (ii) at a prescribed fee, if any; (iii) in a reasonable manner and format; and (iv) in a form that is generally understandable."

11.2 Section 55(1)(b) of POPIA confirms that one of the Information Officer's responsibilities is to deal with requests for information made to the body (the company). Address your (as Data Subject) request to the Information Officer at the address, telephone number or electronic mail addresses referred to at 4.3 above.

11.3 Other Data subject rights are confirmed under the company's Privacy Policy (Addendum A).

12. Availability of the Manual

A copy of the Manual is available at the head office of the company for public inspection during normal business hours;
to any person upon request and upon the payment of a reasonable prescribed fee; and
to the Information Regulator upon request.

A fee for a copy of the Manual, as contemplated in annexure B of the Regulations, shall be payable per each A4-size photocopy made.

13. Fees

The Act provides for the payment of two types of fees, namely a request fee (a standard fee) and an access fee which must be calculated by taking into account production costs, search and preparation time and cost, as well as postal costs.
When a request is received by the Information Officer, such person shall by notice, require the requester, other than a personal requester, to pay the prescribed request fee (if any), before further processing such a request.
If the search for the request has been made and the preparation of the record for disclosure, including arrangement to make it available in the requested form, requires more than the hours prescribed in the regulations for this purpose, the Information Officer shall notify the requester to pay as a deposit the prescribed portion (being not more than one third) of the access fees which would be payable if the request is granted.
The Information Officer is entitled to withhold access to a record until the requester has paid the applicable fees set out in Appendix B.
A requester whose request for access to a record has been granted must pay an access fee for reproduction and for search and preparation time, and for any time reasonably required in excess of the prescribed hours, including making arrangements to make it available in the requested format.
If a deposit has been paid in respect of a request for access, which is refused, the Information Officer must repay the deposit to the requester.

14. Request Procedure

14.1 Records held by the company may be accessed upon request once the requirements for access have been compiled with.

14.2 A requester is any person making a request for access to a record of the company. There are two types of requesters, namely, a personal requester and an "other requester". A personal requester is a requester who seeks access to a record containing personal information about the requester. An "other requester" is a requester who seeks access to information about third parties. The company is not obliged to automatically grant access to any information, and the requester (whether a personal or an "other requester") must comply with requirement for requesting access in terms of the Act excluding the payment of a fee. As described in the set regulations, a fee is only paid by the requester when:

The Information Officer has determined that the search for such a record will require more than six (6) hours to search. Annexure A is completed and the requester is required to pay as a deposit a portion of the access fee as set out in Annexure B of the PAIA Regulations.

14.3 The requester must comply with all the procedural requirements contained in the Act relating to the request for access to information.

14.4 The requester must complete the prescribed form attached as Annexure A and submit it.

14.5 The prescribed form must be completed with enough detail to enable the Information Officer to identify:

the record of records requested;
the identity of the requester;
what form of access is required, if the requester is granted; and
the postal address and/or fax number of the requester.

14.6 The requester must state that he requires the information in order to exercise or protect a right, and clearly state the nature of the right in question. In addition, the requester must clearly specify why the record is necessary to exercise or protect such right.

14.7 The requester will be informed in writing as to whether its request is granted or refused. If, in addition to a written reply, the requester wishes to be informed of the decision in any other manner, he must state the manner and necessary particulars to be so informed.

14.8 If a request is made on behalf of another person, the requester must submit proof of the capacity in which the requester is making the request to the reasonable satisfaction of the Information Officer.

14.9 If an individual is unable to complete the prescribed form because of illiteracy or disability, such a person may make the request orally. The Information Officer must complete Annexure A on behalf of the requester and provide a copy to the requester.

15. Updating of the Manual

The head of the company will on a regular basis update this manual.

Issued by: M Mouton, Director of PrintQ Xpress (Pty) Ltd

Annexure A – Request for Access to Record

[Regulation 7] Note: If requests made on behalf of another person, proof of the capacity in which the request is made, must be attached to this form.

TO: The Information Officer (Address) | E-mail address: | Fax number:

Mark with an "X": Request is made in my own name / Request is made on behalf of another person.

Particulars of Record Requested: Provide full particulars of the record to which access is requested, including the reference number if known, to enable the record to be located. Description of record or relevant part of the record | Reference number, if available | Any further particulars of record.

Types of Records: Record is in written or printed form | Record comprises virtual images | Record consists of recorded words or information which can be reproduced in sound | Record is held on a computer or in an electronic, or machine-readable form.

Form of Access: Printed copy of record | Written or printed transcription of virtual images | Transcription of soundtrack | Copy of record on flash drive | Copy of record on compact disc drive.

Manner of Access: Personal inspection of record at registered address | Postal services to postal address | Postal services to street address | Courier service to street address | Facsimile of information in written or printed format | E-mail of information. Preferred language: (Note that if the record is not available in the language you prefer, access may be granted in the language in which the record is available).

Particulars of Right to Be Exercised or Protected: Indicate which right is to be exercised or protected and explain why the record requested is required for the exercise or protection of the aforementioned right.

Fees: (a) A request for access to a record, other than a record containing personal information about yourself, will be processed only after a request fee has been paid. (b) You will be notified of the amount required to be paid as the request fee. (c) The fee payable for access to a record depends on the form in which access is required and the reasonable time required to search for and prepare a record. (d) If you qualify for exemption of the payment of any fee, please state the reason for exemption.

You will be notified in writing whether your request has been approved or denied and if approved the costs relating to your request, if any. Please indicate your preferred manner of correspondence: Postal Address | Post to street address | Facsimile | Email.

Signed at ____________ this ___ day of _________ 20__ | Signature of requester / person on whose behalf request is made.

Annexure B – Fees

Item	Description	Amount
1.	The request fee payable by every requester	R140.00
2.	Photocopy / printed black & white copy of A4-size page	R2.00 per page or part thereof
3.	Printed copy of A4-size page	R2.00 per page or part thereof
4.	For a copy in a computer-readable form on: (i) Flash drive (to be provided by requester) R40.00; (ii) Compact disc – If provided by requester R40.00; If provided to the requester R60.00	As listed
5.	For a transcription of visual images per A4-sized page	Service to be outsourced. Will depend on quotation from service provider
6.	Copy of visual images	To be quoted
7.	Transcription of an audio record per A4-sized page	R24.00
8.	Copy of an audio record on: (i) Flash drive (to be provided by requester) R40.00; (ii) Compact disc – If provided by requester R40.00; If provided to the requester R60.00	As listed
9.	To search for and prepare the record for disclosure for each hour or part of an hour, excluding the first hour, reasonably required for such search and preparation	To not exceed the total of: R435
10.	Deposit: If search exceeds six hours – One third of the amount per request calculated in terms of items 2 to 8	One third
11.	Postage, e-mail or any other electronic transfer	Actual expense, if any

Annexure C – Lodging of an Internal Appeal (Regulation 9)

Particulars of Public Body: Name of public body | Name and surname of information officer.

Particulars of Appellant Who Lodges the Internal Appeal: Full names | Identity number | Postal address | E-mail address | Contact numbers (Tel / Cell phone) | Is the internal appeal lodged on behalf of another person? Yes / No. If yes, capacity in which an internal appeal on behalf of another person is lodged (proof of capacity must be attached if applicable).

Particulars of Person on Whose Behalf the Internal Appeal Is Lodged (if lodged by a third party): Full names | ID Number | Postal Address | E-mail address | Contact numbers (Tel / Cell phone).

Decision Against Which the Internal Appeal Is Lodged (mark the appropriate box with an "X"): Refusal of request for access | Decision regarding fees prescribed in terms of section 22 of the Act | Decision regarding the extension of the period within which the request must be dealt with in terms of section 26(1) of the Act | Decision in terms of section 29(3) of the Act to refuse access in the form requested by the requester | Decision to grant request for access.

Grounds for Appeal: State the grounds on which the internal appeal is based and any other information that may be relevant in considering the appeal.

Signed at ____________ this ___ day of _________ 20__ | Signature of appellant / third party.

For Official Use: Appeal received by (state rank, name and surname of Information officer) | Date received | Appeal accompanied by the reasons for the information officer's decision and, where applicable, the particulars of any third party to whom or which the record relates, submitted by the information officer. Confirmation of: Refusal of request for access (Yes/No / New decision); Fees (Sec 22) (Confirmed? Yes/No / New decision); Extension (Sec 26(1)) (Confirmed? Yes/No / New decision); Access (Sec 29(3)) (Confirmed? Yes/No / New decision); Request for access granted (Confirmed? Yes/No / New decision). Signature of Information Officer.

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