PAIA Manual

Prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000
Namandla Consultants (Pty) Ltd — Registration number 2016/017981/07

Effective date: 7 September 2026

1. Introduction

1.1 The Promotion of Access to Information Act 2 of 2000 (“PAIA”) gives effect to the constitutional right of access to information held by the State, and to information held by another person where that information is required for the exercise or protection of any rights.
1.2 This manual is published in terms of section 51 of PAIA. It is intended to help you decide whether to request access to a record held by Namandla Consultants (Pty) Ltd, and to explain how to make that request.
1.3 Namandla Consultants (Pty) Ltd is a private body as defined in PAIA. A requester seeking access to a record we hold must identify the right they are seeking to exercise or protect, and explain why the record is required for that purpose.
1.4 This manual is available free of charge.

2. Particulars of the private body

Name of private body: Namandla Consultants (Pty) Ltd
Registration number: 2016/017981/07
Trading name: Namandla Consultants
Head of the private body: Juan Kaltwasser, Managing Director
Information Officer: Juan Kaltwasser
Physical address: 25 Massel Road, Beyerspark, Boksburg, Gauteng, 1459
Postal address: 25 Massel Road, Beyerspark, Boksburg, Gauteng, 1459
Telephone: 087 188 3388
Email: info@namandla.com
Website: https://namandla.com

All requests and enquiries under PAIA must be addressed to the Information Officer at info@namandla.com, marked “PAIA request”.

3. The guide published by the Information Regulator

3.1 The Information Regulator has published a guide, in terms of section 10 of PAIA, explaining how to use the Act. The guide sets out a requester’s rights and how to exercise them, and is available in each official language.
3.2 The guide may be obtained from the Information Regulator:

The Information Regulator (South Africa)
Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191
Toll free: 0800 017 160
Telephone: 010 023 5200
Email: enquiries@inforegulator.org.za
Website: https://inforegulator.org.za

4. Records available without a formal PAIA request

4.1 We have not published a notice in terms of section 52(1) of PAIA. As a matter of practice, the following are made available without a formal request:
(a) all content published on https://namandla.com, including service descriptions, insights articles, our terms and conditions and the privacy notice at section 10 of those terms;
(b) our company registration particulars and B-BBEE status, which are in any event available from public registers;
(c) marketing material, brochures, course outlines and proposals we have issued to you;
(d) any record we have already provided to you in the course of an engagement or a training programme.
4.2 Requesting any of the above does not require Form C or payment of a fee.

5. Records held, by subject and category

5.1 Company and statutory records — Memorandum of Incorporation, CIPC filings, share and director records, resolutions and minutes, B-BBEE verification records, insurance policies and licences.
5.2 Financial records — accounting records, invoices, quotations and statements, banking records, VAT and income tax returns and assessments, payroll records where applicable, and asset registers.
5.3 Client and engagement records — proposals, statements of work, contracts and service level agreements, project and technical documentation, system designs and configurations, correspondence, timesheets, deliverables and support records.
5.4 Namandla Academy records — programme and course material, assessment instruments, learner enrolment records, assessment responses and results, attendance records, certification records, and accreditation correspondence with CPD Quality Standards.
5.5 Personnel and contractor records — subcontractor and associate agreements, confidentiality undertakings, curricula vitae and qualification records, and employment records where employees are engaged.
5.6 Supplier and vendor records — supplier agreements, purchase orders, licensing and subscription records, and correspondence with service providers.
5.7 Marketing and business development records — enquiry records, customer relationship management data, campaign records and website analytics.
5.8 Information technology records — website and hosting records, system configurations, backups, access logs and security records.

The inclusion of a category in this list does not mean that every record in it will be released. Access is subject to the grounds for refusal summarised in section 9 below.

6. Records held in terms of other legislation

We hold records in terms of, among others, the Companies Act 71 of 2008; the Income Tax Act 58 of 1962; the Tax Administration Act 28 of 2011; the Value-Added Tax Act 89 of 1991; the Basic Conditions of Employment Act 75 of 1997; the Labour Relations Act 66 of 1995; the Employment Equity Act 55 of 1998; the Skills Development Act 97 of 1998 and the Skills Development Levies Act 9 of 1999; the Compensation for Occupational Injuries and Diseases Act 130 of 1993; the Unemployment Insurance Act 63 of 2001; the Broad-Based Black Economic Empowerment Act 53 of 2003; the Protection of Personal Information Act 4 of 2013; the Electronic Communications and Transactions Act 25 of 2002; and the Consumer Protection Act 68 of 2008.

The listing of an Act above does not mean that records held under it are automatically available for access under PAIA.

7. How to request access to a record

7.1 A request must be made on Form C (Request for Access to Record of Private Body), prescribed under the PAIA Regulations. Form C is available at https://inforegulator.org.za/paia-forms/ and from us on request, free of charge.
7.2 The completed Form C must be sent to the Information Officer at info@namandla.com, or delivered to our physical address.
7.3 The request must:
(a) provide enough particulars to enable us to identify the record and to identify you as the requester;
(b) state the form of access required;
(c) specify a postal address, email address or fax number in the Republic;
(d) identify the right you are seeking to exercise or protect, and explain why the record is required for that purpose;
(e) where the request is made on behalf of another person, include proof of the capacity in which you are making it.
7.4 We will respond within 30 days of receiving the request. That period may be extended by a further 30 days in the circumstances set out in section 57 of PAIA, and we will notify you in writing if it is extended.
7.5 We will notify you in writing of our decision, the fees payable, the form in which access will be given and, where access is refused, the reasons for the refusal and the remedies available to you.

8. Fees

8.1 A request fee of R140.00 is payable by every requester before the request is processed. This fee is not refundable, including where the request is later refused.
8.2 Where a request is granted, an access fee is payable before access is given:
(a) a photocopy or printed black and white copy of an A4 page — R2.00 per page or part of a page;
(b) a copy in computer-readable form on a flash drive provided by the requester — R40.00;
(c) a copy in computer-readable form on a compact disc provided by the requester — R40.00;
(d) a copy in computer-readable form on a compact disc provided by us — R60.00;
(e) a transcription of an audio record, per A4 page or part of a page — R24.00;
(f) a copy of an audio record on a flash drive provided by the requester — R40.00;
(g) a copy of an audio record on a compact disc provided by the requester — R40.00;
(h) a copy of an audio record on a compact disc provided by us — R60.00;
(i) a transcription of visual images, or a copy of visual images — this service is outsourced and the fee is the amount quoted by the service provider;
(j) search and preparation time — R145.00 for each hour or part of an hour, excluding the first hour, reasonably required to search for and prepare the record for disclosure, subject to a maximum of R435.00;
(k) postage, email or other electronic transfer — the actual expense, if any.
8.3 Where we reasonably believe that the search and preparation will exceed six hours, we will require a deposit of one third of the access fee before processing the request.
8.4 Value-added tax is payable in addition to the prescribed fees where applicable.
8.5 These are the fees prescribed by the PAIA Regulations. We may not charge more than the prescribed amounts.

9. Grounds on which a request may be refused

We may, and in some cases must, refuse a request where the record falls within a ground for refusal in Chapter 4 of Part 3 of PAIA. These include:
(a) mandatory protection of the privacy of a third party who is a natural person (section 63);
(b) mandatory protection of the commercial information of a third party (section 64);
(c) mandatory protection of confidential information of a third party where disclosure would breach a duty of confidence (section 65);
(d) mandatory protection of the safety of individuals and the protection of property (section 66);
(e) mandatory protection of records privileged from production in legal proceedings (section 67);
(f) protection of our own commercial activities, including trade secrets and financial, commercial, scientific or technical information the disclosure of which would be likely to harm our commercial or financial interests (section 68);
(g) protection of research information (section 69);
(h) requests that are manifestly frivolous or vexatious, or where the work involved would substantially and unreasonably divert our resources (section 45).

Access may nevertheless be granted where disclosure is required in the public interest as contemplated in section 70 of PAIA.

10. Remedies available to a requester

10.1 PAIA does not provide for an internal appeal against a decision taken by a private body.
10.2 A requester who is dissatisfied with our decision may:
(a) lodge a complaint with the Information Regulator on the prescribed Form 5; or
(b) apply to a court with jurisdiction for appropriate relief, within 180 days of being notified of the decision.
10.3 Complaints to the Information Regulator may be lodged at:
PAIA complaints: PAIAComplaints@inforegulator.org.za
POPIA complaints: POPIAComplaints@inforegulator.org.za
Telephone: 010 023 5200

11. Processing of personal information

11.1 Purpose of processing. We process personal information to respond to enquiries and prepare proposals; to deliver our consulting, managed services and support engagements; to deliver Academy training, assess learners and issue certificates; to invoice and to meet our accounting and tax obligations; to operate and secure our website; to communicate with clients about our services; and to meet reporting obligations including B-BBEE verification.

11.2 Categories of data subjects and of personal information:
(a) prospective clients and website enquirers — name, contact details, organisation and the content of the enquiry;
(b) clients and their personnel — name, role, contact details, correspondence and engagement records;
(c) Academy learners — name, contact details, employer and job role, programme enrolled in, attendance and progress, assessment responses and results, and certification records;
(d) suppliers, subcontractors and associates — name, contact details, contracting and payment details, and qualification records;
(e) website visitors — truncated IP address, browser and device information, pages viewed and cookie identifiers;
(f) employees and applicants, where applicable — personnel and payroll records.

11.3 Recipients or categories of recipients:
(a) service providers processing on our instruction, including our hosting, email, cloud storage and analytics providers;
(b) associates and subcontractors engaged on a specific engagement, under written confidentiality obligations;
(c) CPD Quality Standards (CPDQS), which accredits our Academy programmes, for accreditation, quality assurance and certification;
(d) an employer who has sponsored, nominated or funded a learner;
(e) our professional advisers, auditors and insurers;
(f) regulators, courts and law enforcement authorities where we are legally obliged to disclose.

11.4 Planned transborder flows of personal information. Personal information may be transferred to CPD Quality Standards in the United Kingdom for accreditation and certification purposes, and to Google, which operates internationally, for website analytics. Our hosting, email and cloud storage providers may store or process information outside the Republic. Transfers take place only on a basis permitted by section 72 of POPIA. In the case of the United Kingdom, the UK General Data Protection Regulation and the Data Protection Act 2018 provide a level of protection substantially similar to POPIA.

11.5 General description of information security measures. We encrypt traffic to and from our website using TLS; apply access controls and multi-factor authentication to systems holding personal information; keep software and plugins patched; restrict access to those who require it for their role; and maintain backups. Security compromises are notified to affected data subjects and to the Information Regulator in accordance with section 22 of POPIA.

12. Availability of this manual

12.1 This manual is available:
(a) on our website at https://namandla.com/paia-manual/;
(b) at our physical address during ordinary business hours;
(c) by email, on request to info@namandla.com;
(d) to the Information Regulator on request.
12.2 It is provided free of charge.

13. Review of this manual

We will update this manual whenever there is a material change to the records we hold, to our structure, or to the applicable law, and will review it at least annually.

Approved by: Juan Kaltwasser, Managing Director and Information Officer
Namandla Consultants (Pty) Ltd
Date: 7 September 2026