Legal
PAIA manual
1. About this manual
This manual tells you what records Clements & Cox (Pty) Ltd holds, how to request access to them, and how we process personal information. It is available on this website and at our principal place of business, and a copy is available to the Information Regulator on request.
2. Company and Information Officer contact details
| hello@clementsandcox.com | |
| Physical address | 24 Tesla Crescent, Sunninghill, Sandton, 2157, Gauteng |
3. The Information Regulator’s guide
The Information Regulator has published a guide on how to use PAIA and POPIA to exercise your rights, in all official languages. It is available from the Information Regulator (South Africa) — inforegulator.org.za, POPIAComplaints@inforegulator.org.za, and from our Information Officer on request.
4. Records available without a request (s51(1)(b)(ii))
The information on this website, including our privacy policy, cookie policy, legal notice and this manual, is freely available. No other categories of records are automatically available at this time.
5. Records kept in terms of other legislation (s51(1)(b)(iii))
Where applicable to us, we keep records under the Companies Act 71 of 2008; Income Tax Act 58 of 1962; Value-Added Tax Act 89 of 1991; Tax Administration Act 28 of 2011; Basic Conditions of Employment Act 75 of 1997; Labour Relations Act 66 of 1995; Employment Equity Act 55 of 1998; Unemployment Insurance Act 63 of 2001; Skills Development Levies Act 9 of 1999; Compensation for Occupational Injuries and Diseases Act 130 of 1993; Electronic Communications and Transactions Act 25 of 2002; and the Protection of Personal Information Act 4 of 2013.
6. Subjects and categories of records held (s51(1)(b)(iv))
| Subject | Categories of records |
|---|---|
| Company and statutory | Incorporation documents, memorandum of incorporation, share register, director and shareholder records, minutes and resolutions |
| Finance and tax | Financial statements, accounting records, invoices, bank records, tax and VAT returns |
| Clients | Contracts, proposals, correspondence, project records, support tickets, contact details |
| Suppliers and operators | Contracts, service agreements, correspondence, invoices |
| Personnel | Employment and contractor agreements, payroll, leave, tax and statutory records |
| IT and security | System, access and security logs, website server logs, backups, policies |
| Marketing | Website content, enquiry records, marketing consents and opt-outs |
7. How to request access (s51(1)(b)(v))
- Complete the prescribed request form (Form 2 of the PAIA Regulations, 2021), available from the Information Regulator’s website or from our Information Officer.
- Send it to the Information Officer by email or post, using the details in section 2. Give enough detail to identify the records and say in what form you want access.
- If you are requesting on behalf of someone else, include proof of your authority.
- Pay the prescribed request fee (not payable for requests for your own personal information) and, if access is granted, any prescribed access fee, as published in the PAIA Regulations.
We will decide within 30 days of receiving a complete request (this may be extended by up to 30 days as PAIA allows) and tell you the outcome in writing. Access may be refused only on the grounds set out in Chapter 4 of Part 3 of PAIA — for example, to protect another person’s privacy, commercial information or legally privileged records. If you are not satisfied with our decision you may complain to the Information Regulator or apply to court within 180 days.
8. Processing of personal information (POPIA)
Purposes of processing
To provide and invoice our services; respond to enquiries; manage suppliers and staff; keep our systems secure; meet legal and regulatory obligations; and, with consent, market our services.
Categories of data subjects and their information
| Data subjects | Personal information processed |
|---|---|
| Clients and prospective clients (individuals and contact persons at organisations) | Names, contact details, job titles, correspondence, call records and voicemails, billing information |
| Website visitors | IP address and technical log data; analytics data only with consent |
| Suppliers and operators | Contact persons’ names and details, banking and contract information |
| Employees and contractors | Identity, contact, banking, tax, remuneration and employment records |
Recipients
Our operators (hosting, Microsoft 365, telephony, and Google Analytics where consented), professional advisers, our UK affiliate where needed to deliver a service, and regulators or authorities where the law requires.
Planned transfers outside South Africa
Some operators store information in the United Kingdom, the European Union and the United States. Transfers take place only as permitted by POPIA section 72.
Security measures
Encryption in transit (TLS), multi-factor authentication and role-based access to business systems, patching and backups, network access restrictions, and confidentiality agreements with staff and operators.
9. Availability of this manual
This manual is published at clementsandcox.co.za/paia-manual.html and is available for inspection at our principal place of business at no charge.