PAIA MANUAL
Promotion of Access to Information Act 2 of 2000
(As amended by PAIA Amendment Act 31 of 2014)
Published in terms of Section 51 of PAIA
For use by any person wishing to access information
Document Information
Body / Company | Gadas Holdings (Pty) Ltd t/a GADASWORX |
Registration No. | Undisclosed |
VAT No. | Undisclosed |
Physical Address | 140 West Street, Sandton, 2196 |
Postal Address | 140 West Street, Sandton, 2196 |
Website | www.gadasworx.co.za |
info@gadasworx.co.za | |
Telephone | +27 (0)87 265 6592 |
Information Officer | Ms. K.Lindt |
Deputy Info Officer | Mr.K.O.Mmbi |
IO Email | privacy@gadasworx.co.za |
IO Telephone | +27 (0)87 265 6592 |
Document Version | 1.0 |
Date of Publication | April 2025 |
Next Review Date | April 2026 |
Approved By | Mr. M. Magadagela |
Introduction
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 by private bodies, as enshrined in section 32 of the Constitution of the Republic of South Africa, 1996.
Section 51 of PAIA requires every private body to compile a manual setting out the information it holds, the categories of records available, how to submit requests, and the remedies available to requesters.
This manual is compiled by Gadas Holdings (Pty) Ltd t/a GADASWORX (GADASWORX) to enable any person to effectively exercise their rights in terms of PAIA. All South Africans and foreign nationals have the right to request access to information held by a private body, subject to the grounds for refusal provided in PAIA.
Contact Details of the Information Officer
In terms of section 51(1)(a) of PAIA, the following are the contact details of the Information Officer designated to deal with requests for access to records:
Information Officer | Ms. K. Lindt |
Deputy Info Officer | Mr.K.O. Mmbi |
Postal Address | 140 West Street, Sandton, 2196 |
Physical Address | 140 West Street, Sandton, 2196 |
Email Address | privacy@gadasworx.co.za |
Telephone | +27 (0)87 265 6592 |
Fax | Undisclosed |
Website | www.gadasworx.co.za |
The Information Officer’s responsibilities include:
- Receiving and processing PAIA requests
- Ensuring compliance with PAIA requirements
- Maintaining and updating this manual
- Liaising with the South African Human Rights Commission (SAHRC)
- Assisting requesters to identify the correct records and categories
Guide on the Use of PAIA (Section 10)
The South African Human Rights Commission (SAHRC) has compiled a guide as required by section 10 of PAIA to assist persons who wish to exercise any right in terms of PAIA. The guide is available from:
Organisation | South African Human Rights Commission (SAHRC) |
Website | www.sahrc.org.za |
paia@sahrc.org.za | |
Telephone | +27 11 877 3600 |
Address | 29 Princess of Wales Terrace, Parktown, Johannesburg, 2193 |
Records Available Without a Formal Request
In terms of section 52 of PAIA, the following records are automatically available to any person without the need to submit a formal request:
Records published on the GADASWORX website (www.gadasworx.co.za)
- PAIA Manual (this document)
- Privacy Terms & POPI Act Policy
- Terms and Conditions of Service
- Cookie Policy
- eSourcing / Career Opportunities
- Service offerings and company profile
Records disclosed in terms of other legislation
- CIPC registration documents (publicly available)
- BBBEE Certificate (on request or published on website)
- Tax clearance / Good standing certificate (on request)
Categories of Records Held by GADASWORX
The following categories of records are held by GADASWORX. A formal PAIA request is required to access records not listed in Section 4.
Corporate & Legal Records
- Certificate of Incorporation and Memorandum of Incorporation (MOI)
- Shareholder and director registers
- Board resolutions and minutes
- Annual financial statements and audit reports
- Tax returns and VAT registration documents
- Insurance policies and certificates
- Contracts and service level agreements
- Tender documents and bid submissions
- CIDB, CSD, and BBBEE registration documents
Human Resources Records
- Employee contracts of employment
- Personal records of employees (CV, ID, qualifications)
- Payroll records and remuneration schedules
- Leave records and attendance registers
- Disciplinary and grievance records
- Training and development records
- Employment Equity records and plans
- UIF, SDL, and PAYE records
Financial Records
- Bank statements and financial account records
- Invoices, purchase orders, and payment records
- Asset registers
- Budget and cash flow records
- Creditor and debtor records
Client & Customer Records
- Client contracts and service agreements
- Client contact and communication records
- Project records, work orders, and delivery notes
- Quotations and proposals
- Service level agreement reports
Supplier & Vendor Records
- Supplier contracts and purchase orders
- Supplier registration and BBBEE records
- Procurement and tender records
Information Technology & Security Records
- IT infrastructure and network records
- Software licences and maintenance records
- Data backup and disaster recovery records
- Security audit and vulnerability assessment reports
- User access control and administration records
- CCTV footage (retained for 30 days)
Statutory Records
- Records required under the Companies Act 71 of 2008
- Records required under the Basic Conditions of Employment Act 75 of 1997
- Records required under the Labour Relations Act 66 of 1995
- Records required under the Income Tax Act 58 of 1962
- Records required under the Value Added Tax Act 89 of 1991
- Records required under POPIA (Protection of Personal Information Act 4 of 2013)
How to Submit a Request for Access to Records
Any person wishing to access records held by GADASWORX must submit a written request in terms of section 53 of PAIA. All requests must be submitted using the prescribed Form C, available from:
- The SAHRC website: www.sahrc.org.za
- The Department of Justice website: www.justice.gov.za
- GADASWORX Information Officer upon request
Information required in a PAIA request (Form C)
The request must include the following:
- Full name and contact details of the requester
- Capacity in which the request is made (e.g., personal capacity, on behalf of another person)
- Description of the record(s) requested, sufficient to identify them
- The form in which access is required (e.g., copy, inspection, electronic format)
- If the requester is acting for another person, proof of authority
- If seeking grounds other than personal interest, the reason and circumstances
Where to submit requests
By email | privacy@gadasworx.co.za |
By post | 140 West Street, Sandton, 2196 |
By hand | 140 West Street, Sandton, 2196 |
Telephone | +27 (0)87 265 6592 (to enquire only — requests must be in writing) |
Request fee
A requester who is not seeking access to their own personal records may be required to pay a request fee of R50.00 before the request is processed, as prescribed by regulation.
No fee is charged for a requester seeking access to their own personal records.
Access fee
If the request is approved, an access fee may be charged for the cost of reproduction and/or searching for the records, as determined by the regulations to PAIA. The Information Officer will notify the requester of any applicable fees prior to providing access.
Processing of Requests & Response Timelines
Upon receipt of a properly completed Form C request, the Information Officer will:
Acknowledge receipt | Within 5 business days of receiving the request |
Notify of request fee | Within 5 business days (where applicable) |
Decision notice | Within 30 days of receipt of the request |
Extended period | Up to 30 additional days if volume or complexity requires (notice must be given) |
The Information Officer will inform the requester in writing whether the request is granted or refused, and if refused, provide the reasons for refusal.
Grounds for Refusing Access (Sections 62–70 of PAIA)
Access to records may be refused on the following mandatory or discretionary grounds:
Mandatory grounds for refusal
- Records that are already publicly available and accessible (s67)
- Records of the South African Revenue Service (s35)
- Records relating to ongoing criminal or civil proceedings (s37)
- Records containing personal information of a third party where the third party has not consented (s63)
- Records that would endanger the life or physical safety of an individual (s62)
Discretionary grounds for refusal
- Commercial information of a third party (trade secrets, financial, commercial, technical information) (s64)
- Confidential information of a third party (s65)
- Research information (s66)
- Information that would be privileged in legal proceedings (s67)
- Records where disclosure would prejudice the protection of legitimate commercial activities of GADASWORX (s68)
Remedies Available to Requesters
If a requester is aggrieved by a decision of the Information Officer, the following remedies are available:
Internal appeal
A requester may apply for the decision to be reconsidered by a more senior representative of GADASWORX within 60 days of receiving the refusal notice. This is an informal internal escalation step.
Application to the Information Regulator
A requester may apply to the Information Regulator for intervention:
Name | Information Regulator of South Africa |
Website | www.inforegulator.org.za |
inforeg@justice.gov.za | |
Telephone | 010 023 5207 |
Address | JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001 |
Court application
A requester may approach the High Court of South Africa for a court order compelling access to the requested record, in terms of section 78 of PAIA, within 30 days after exhausting internal remedies.
Subjects of Records Held
The records held by GADASWORX relate to the following categories of subjects:
Category of Subject | Types of Records |
Current and former employees | Employment records, payroll, performance, disciplinary records |
Job applicants | CVs, application forms, interview notes, reference checks |
Clients and customers | Contracts, service records, contact details, communication history |
Suppliers and contractors | Contracts, registration documents, payment records |
Directors and shareholders | CIPC records, agreements, resolutions |
Website visitors | Cookie data, IP addresses, contact form submissions |
Members of the public | Any person who has contacted GADASWORX by any means |
Legislation Applicable to GADASWORX's Activities
GADASWORX holds records required or regulated under the following legislation:
Corporate & Governance
- Companies Act 71 of 2008
- Close Corporations Act 69 of 1984 (if applicable)
- King IV Report on Corporate Governance
Labour & Employment
- Labour Relations Act 66 of 1995
- Basic Conditions of Employment Act 75 of 1997
- Employment Equity Act 55 of 1998
- Skills Development Act 97 of 1998
- Compensation for Occupational Injuries and Diseases Act 130 of 1993 (COID)
Tax & Finance
- Income Tax Act 58 of 1962
- Value Added Tax Act 89 of 1991
- Tax Administration Act 28 of 2011
- Unemployment Insurance Act 63 of 2001 (UIF)
Data & Privacy
- Protection of Personal Information Act 4 of 2013 (POPIA)
- Promotion of Access to Information Act 2 of 2000 (PAIA)
- Electronic Communications and Transactions Act 25 of 2002 (ECTA)
ICT & Procurement
- Electronic Communications Act 36 of 2005
- Broad-Based Black Economic Empowerment Act 53 of 2003 (BBBEE)
- Preferential Procurement Policy Framework Act 5 of 2000 (PPPFA)
- Construction Industry Development Board Act 38 of 2000 (CIDB)
Consumer
- Consumer Protection Act 68 of 2008
- National Credit Act 34 of 2005 (where applicable)
Availability of This Manual
This PAIA Manual is available free of charge in the following formats and locations:
Website (PDF/Web) | www.gadasworx.co.za/paia-manual |
Email request | privacy@gadasworx.co.za |
Physical inspection | 140 West Street, Sandton, 2196 — by appointment during business hours |
Printed copy | Available on request (no charge for the first copy) |
SAHRC submission | A copy of this manual has been/will be submitted to the SAHRC |
This manual will be updated whenever there are material changes to GADASWORX’s structure, information held, or applicable legislation.
Contact Details & Closing Statement
GADASWORX is committed to transparency and the promotion of the constitutional right of access to information. We will make every effort to assist requesters in exercising their rights under PAIA.
For any queries regarding this manual or any PAIA request, please contact:
Company | Gadas Holdings (Pty) Ltd t/a GADASWORX |
Information Officer | Ms. K. Lindt |
Telephone | +27 (0)87 265 6592 |
privacy@gadasworx.co.za | |
Postal Address | 140 West Street, Sandton, 2196 |
Physical Address | 140 West Street, Sandton, 2196 |
Website | www.gadasworx.co.za |
This manual was compiled in terms of Section 51 of the Promotion of Access to Information Act 2 of 2000. It is the responsibility of all persons exercising their rights under PAIA to do so in good faith and in accordance with the Act.