PAIA MANUAL

1.LIST OF ACRONYMS AND ABBREVIATIONS

1.1 “MD”Managing Director

1.2 “DIO”Deputy Information Officer;

1.3 “IO”Information Officer;

1.4 “Minister”Minister of Justice and Correctional Services;

1.5 “PAIA”Promotion of Access to Information Act No. 2 of 2000( as Amended;

1.6 “POPIA”Protection of Personal Information Act No.4 of 2013;

1.7 “Regulator”Information Regulator; and

1.8 “Republic”Republic of South Africa

2. PURPOSE OF PAIA MANUAL

This PAIA Manual is useful for the public to-

2.1 check the categories of records held by a body which are available without a person having to submit a formal PAIA request;

2.2 have a sufficient understanding of how to make a request for access to a record of the body, by providing a description of the subjects on which the body holds records, and the categories of records held on each subject;

2.3 know the description of the records of the body which are available in accordance with any other legislation;

2.4 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;

2.5 know the description of the guide on how to use PAIA, as updated by the Regulator and how to obtain access to it;

2.6 know if the body 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;

2.7 know the description of the categories of data subjects and of the information or categories of information relating thereto;

2.8 know the recipients or categories of recipients to whom the personal information may be supplied;

2.9 know if the body 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

2.10 know whether the body has appropriate security measures to ensure the confidentiality, integrity and availability of the personal information which is to be processed.

3. KEY CONTACT DETAILS FOR ACCESS TO INFORMATION OF THE AFRICA COSMOS CONSULTING AND TRAINING SERVICES (PTY) LTD

3.1. Chief Information Officer

Name: Anooradha Parsard

Tel: 011 283 2107

Email: anoop@africacosmos.co.za

3.2. Deputy Information Officer

Name: Ivan Du Plooy

Tel: 011 283 2148

Email: ivand@africacosmos.co.za

3.3 Access to information general contacts

Email: info@africacosmos.co.za

3.4 National or Head Office

Postal Address: PN Suite 48, Private Bag x1, Melrose Arch, Johannesburg, 2076 Gauteng

Physical Address: 17, 8th Street, Houghton Estate, Johannesburg 2198 Gauteng

Telephone: +27 11283 2000

Email:info@africacosmos.co.za

Website:www.africacosmos.co.za

4. GUIDE ON HOW TO USE PAIA AND HOW TO OBTAIN ACCESS TO THE GUIDE

4.1. 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.

4.2. The aforesaid Guide contains the description of-

4.2.1. the objects of PAIA and POPIA;

4.2.2. the postal and street address, phone and fax number and, if available, electronic mail address of-

4.2.2.1. the Information Officer, and

4.2.2.2. the Deputy Information Officer of the private body designated in terms of section 17(1) of PAIA1 and section 56 of POPIA2;

4.2.3. the manner and form of a request for-

4.2.3.1. access to a record of a private body contemplated in section 504;

4.2.4. the assistance available from the IO of a private body in terms of PAIA and POPIA;

4.2.5. the assistance available from the Regulator in terms of PAIA and POPIA;

4.2.6. 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-

4.2.6.1. an internal appeal;

4.2.6.2. a complaint to the Regulator; and

4.2.6.3. 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;

4.2.7. the provisions of sections 145 and 516 requiring a public body and private body, respectively, to compile a manual, and how to obtain access to a manual;

4.2.8. the provisions of sections 157 and 528 providing for the voluntary disclosure of categories of records by a public body and private body, respectively;

4.2.9. the notices issued in terms of sections 229 and 5410 regarding fees to be paid in relation to requests for access; and

4.2.10. the regulations made in terms of section 9211.

4.3. 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.

4.4. The Guide can also be obtained-

4.4.1. upon request to the Information Officer;

4.4.2. from the website of the Regulator (https://www.justice.gov.za/inforeg/).

5. DESCRIPTION OF THE RECORDS OF AFRICA COSMOS CONSULTING AND TRAINING SERVICES (PTY) LTD WHICH ARE AVAILABLE IN ACCORDANCE WITH ANY OTHER LEGISLATION

Category of Records	Applicable Legislation
Memorandum of incorporation	Companies Act 71 of 2008
PAIA Manual	Promotion of Access to Information Act 2 of 2000
Trust Deed	Companies Act 71 of 2008

6. GROUNDS FOR REFUSAL OF ACCESS TO RECORDS IN TERMS OF PAIA

The following ae the grounds on which the company may, subject to the exceptions contained in Chapter 4 of PAIA, refuse a Request for Access in accordance with Chapter 4 of PAIA:

6.1 Mandatory protection of the privacy of a third party who is a natural person, including a deceased person, where such disclosure of Personal Information would be unreasonable;

6.2 Mandatory protection of the commercial information of a third party, if the Records contain:

(1) trade secrets of that third party;

(2) financial, commercial, scientific or technical information of the third party, the disclosure of which could likely cause harm to the financial or commercial interests of that third party; and/or

6.3 Information disclosed in confidence by a third party to the Company, the disclosure of which could put that third party at a disadvantage in contractual or other negotiations or prejudice the third party in commercial competition;

6.4 Mandatory protection of confidential information of third parties if it is protected in terms of any agreement;

6.5 Mandatory protection of the safety of individuals and the protection of property;

6.6 Mandatory protection of Records that would be regarded as privileged in legal proceedings;

6.7 Protection of the commercial information of the Company, which may include:

(1) trade secrets;

(2) financial/commercial, scientific or technical information, the disclosure of which could likely cause harm to the financial or commercial interests of the Company;

(3) information which, if disclosed, could put the Company at a disadvantage in contractual or other negotiations or prejudice the Company in commercial competition; and/or

(4) computer programs which are owned by the Company, and which are protected by copyright and intellectual property laws;

(5) research information of the Company or a third party, if such disclosure would place the research or the researcher at a serious disadvantage; and

(6) requests for Records that are clearly frivolous or vexatious, or which involve an unreasonable diversion of resources.

7. INFORMATION OR RECORDS NOT FOUND

If the Company cannot find the records that the requester is looking for despite reasonable and diligent searches being conducted and it believes either that the records are lost or that the records are in its possession but unattainable, the Requester will receive a notice in this regard from the Information Officer in the form of an affidavit setting out the measures taken to locate the document and accordingly the inability to locate the document.

8. REMEDIES AVAILABLE TO THE REQUESTER UPON REFUSAL OF A REQUEST FOR ACCESS IN TERMS OF PAIA

The Company does not have internal appeal procedures. As such, the decision made by the Information Officer is final, and Requesters will have to exercise such external remedies at their disposal if the Request for Access is refused.

8.2 In accordance with sections 56(3) (c) and 78 of PAIA, a Requester may apply to a court for relief within 180 (one hundred and eighty) days of notification of the decision for appropriate relief.

9. DESCRIPTION OF THE SUBJECTS ON WHICH THE BODY HOLDS RECORDS AND CATEGORIES OF RECORDS HELD ON EACH SUBJECT BY AFRICA COSMOS CONSULTING AND TRAINING SERVICES (PTY) LTD

Subjects on which the body holds records

Categories of records

Strategic Documents, Plans, Proposals

Annual Reports, Performance Plan.

Strategic

Plan,

Annual

Human Resources

– HR policies and procedures

– Advertised posts

– Employees records

10. PROCESSING OF PERSONAL INFORMATION

10.1 Purpose of Processing Personal Information

a) Learner Enrolment and Registration

Purpose:
To collect and process personal data necessary to register learners for courses and ensure accurate records.

Typical Data Collected:
Name, contact details, date of birth, ID documents, previous qualifications, marriage certificates, SARs information, bank details,.

Reason for Processing:
To enter into and fulfil a training contract, comply with regulatory requirements, and ensure eligibility.

b) Course Delivery and Assessment

Purpose:
To support the effective delivery of training, monitor progress, and conduct assessments.

Typical Data Collected:
Attendance records, coursework, exam results, learning styles/preferences.

Reason for Processing:
To fulfil contractual obligations and maintain academic standards and records.

c) Certification and Accreditation

Purpose:
To issue certifications or qualifications upon course completion.

Typical Data Collected:
Course completion status, grades, identification for certificate matching.

Reason for Processing:
To comply with awarding body requirements and provide proof of qualification.

d) Communication and Support

Purpose:
To stay in touch with learners, provide updates, and offer academic or pastoral support.

Typical Data Collected:
Email addresses, phone numbers, preferred contact methods, support needs.

Reason for Processing:
To deliver a good learner experience and support successful course completion.

e) Funding and Government Reporting

Purpose:
To apply for and report on government funding and comply with legal obligations and governing body requirements.

Typical Data Collected:
Demographic information, employment status, funding eligibility data, SDL numbers, supplier information, BBBEE certificates, equity and diversity information, accreditation letters.

Reason for Processing:
To meet requirements set by funding bodies (e.g., SETAs, QCTO, PSIRA, PFTC, SAPS)

f) Marketing and Business Development

Purpose:
To inform learners or potential clients about new courses, promotions, and events.

Typical Data Collected:
Email addresses, course interests, consent preferences.

Reason for Processing:
With consent, to promote business growth and learner engagement.

g) Health, Safety, and Welfare

Purpose:
To ensure the safety and well-being of learners and staff during training activities.

Typical Data Collected:
Medical conditions, emergency contacts, special needs disclosures.

Reason for Processing:
To comply with health and safety regulations and provide appropriate accommodations for learners and staff.

h) System Access and IT Management

Purpose:
To provide learners access to digital learning platforms and ensure secure system use.

Typical Data Collected:
Usernames, login records, IP addresses, device information, email addresses.

Reason for Processing:
To deliver online content and protect systems from misuse.

i) Compliance and Legal Obligations

Purpose:
To meet legal obligations, handle disputes, and respond to audits or inspections.

Typical Data Collected:
All relevant personal information as required for compliance checks and audits as mentioned above.

Reason for Processing:
To comply with legal, regulatory, or contractual requirements.

10.2 Description of the categories of Data Subjects and of the information or categories of information relating thereto

Categories of Data Subjects	Personal Information that may be processed
Customers / Clients	name, address, registration numbers or identity numbers, employment status and bank details
Service Providers	names, registration number, vat numbers, address, trade secrets and bank details
Employees	address, qualifications, gender and race
Students / learners	Name, ID number, email addresses, phone numbers, addresses, bank details, gender, race, qualifications

10.3 The recipients or categories of recipients to whom the personal information may be supplied

Recipients or Categories of Recipients to whom the personal information may be supplied
Identity number and names for criminal checks				South African Police Services
Qualifications, for qualification verifications				South African Qualifications Authority
Credit and payment history for credit information				Credit Bureaus
Learner Name, ID number, email addresses, phone numbers, home addresses, bank details, gender, race, qualifications				Sector Education and Training Authority & Quality Council for Trades and Occupations.
Learner list with: ID number, email addresses, phone numbers, home addresses, gender, race, qualifications				Supplier
Learner Lists and Reports with: ID number, email addresses, phone numbers, home addresses, gender, race				Client

10.4 General description of Information Security Measures to be implemented by the responsible party to ensure the confidentiality, integrity and availability of the information

The company employs up to date technology to ensure confidentiality, integrity and availability of Personal Information under its care. Measures include:

Firewalls
Virus protection software
Logical and physical access control
Secure setup of hardware and software making up the IT infrastructure

11. AVAILABILITY OF THE MANUAL

11.1 A copy of the Manual is available-

11.1.1 on www.africacosmos.co.za if any;

11.1.2 head office of the Africa Cosmos Consulting and Training Services (Pty) Ltd for public inspection during normal business hours;

11.1.3 to any person upon request and upon the payment of a reasonable prescribed fee; and

11.1.4 to the Information Regulator upon request.

11.2 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.

12. UPDATING OF THE MANUAL

The Head of Africa Cosmos Consulting and Training Services (Pty) Ltd will on a regular basis update this manual

Issued by Anooradha Parsard – Managing Director