PAIA manual

This is the manual section 51 of the Promotion of Access to Information Act, 2000 (PAIA) requires every private body to publish. It is written to be used rather than filed: if you want a record we hold, everything you need in order to ask for it is on this page.

Who we are

• Legal name: Bonang M Investments (Pty) Ltd, trading as Bonang Technologies.
• Registration number: printed on every quotation and invoice we issue, and available on request.
• Physical and postal address: Sunninghill, Sandton, Johannesburg, 2196, South Africa.
• Telephone: +27 72 823 2999. Email: info@bonangtech.com. Website: bonangtech.com.
• Head of the private body and information officer: the managing director, contactable on the details above.

The Regulator's guide

The Information Regulator has published a guide, in terms of section 10, on how to use this Act. It is written for the public rather than for lawyers and it is free. Ask the Regulator for it on enquiries@inforegulator.org.za or 010 023 5200, or take it from inforegulator.org.za.

Records we hold

We are a small company and the list is short. Records fall into the categories below, and naming a category here does not mean a record in it will be released: the grounds for refusal in chapter 4 of the Act still apply to every request.

• Company records: the memorandum of incorporation, statutory registers, minutes, and the records the Companies Act, 2008 requires us to keep.
• Financial records: invoices, statements, bank records, tax returns and the records the Tax Administration Act and the VAT Act require us to retain.
• Client records: signed agreements, scopes, quotations, correspondence, project files, designs and source material for work we have done.
• Operational records: hosting and infrastructure configuration, asset registers, support correspondence and system logs for the environments we manage.
• Employment records: contracts, payroll, leave and the records the Basic Conditions of Employment Act requires.
• Personal information records: enquiry and newsletter records, and the register of requests and objections this manual and the POPIA notice generate.

Records available without a request

Anything published on bonangtech.com is available to anybody, at any time, without asking us and without a fee. That includes this manual, the privacy policy, the POPIA notice, our terms and everything written on the blog. No record is currently available in terms of section 52(2).

How to request a record

• Use the prescribed request form (Form 2 of the PAIA regulations), or write to us setting out the same information. We will send you the form if you ask.
• Send it to the information officer at info@bonangtech.com, or to Sunninghill, Sandton, Johannesburg, 2196, South Africa.
• Give enough particulars for us to identify the record, and enough to identify and contact you.
• Say what form of access you want: a copy, an inspection, an extract or a transcription.
• Say which right you need the record in order to exercise or protect, and how the record helps you do it. Section 50 makes that the test for a request to a private body, so a request that does not answer it cannot succeed.
• If you are asking on somebody else's behalf, attach your proof of authority.

What it costs

A request fee is payable before we start, except by a personal requester asking for a record about themselves. If the search and preparation will take longer than the hours the regulations allow, a deposit is payable, and an access fee is payable before the record is handed over. The amounts are the ones prescribed in the PAIA regulations, we will put the current figures in writing before you commit to anything, and we do not add a charge of our own on top of them.

How long it takes

We decide within thirty days of receiving a complete request and tell you the outcome in writing. That period can be extended once, by up to a further thirty days, where the request covers a large number of records or a search through offices elsewhere. If we extend it, you get the reason in writing and the right to complain about the extension itself.

When we may say no

Chapter 4 of the Act sets out the grounds, and where one applies we are obliged to refuse rather than free to choose. The ones most likely to come up here are the privacy of a third party, the commercial information of a third party or of ours, information given to us in confidence, records privileged in legal proceedings, and a request that is manifestly frivolous or would divert our resources unreasonably. A refusal comes to you in writing, with the section relied on and the reason it applies.

Where a record contains something we must withhold and something we need not, you get the rest of it. We do not refuse a whole document because one paragraph in it is protected.

If you are not satisfied

There is no internal appeal against a private body, so you have two routes and you may use either. Complain to the Information Regulator on PAIAComplaints@inforegulator.org.za, or apply to a court with jurisdiction. Both are open to you within 180 days of our decision. The Regulator's full contact details are in the POPIA notice.

Keeping this current

This manual is reviewed annually, and whenever what we hold changes materially. The date at the top of this page is the last time it was changed, and superseded versions are available on request.