PAIA Manual

1. Introduction

This manual is prepared in accordance with Section 51 of the Promotion of Access to Information Act, 2000 ("PAIA") and the Protection of Personal Information Act, 2013 ("POPIA").

The purpose of this manual is to foster a culture of transparency and accountability within BlackNet (Pty) Ltd ("BlackNet") by providing information on how to request access to records held by the company.

2. Company Details

3. Information Officer

The Information Officer is responsible for ensuring compliance with PAIA and POPIA, and for processing requests for access to records.

4. Guide on How to Use PAIA and How to Obtain Access to the Guide

The South African Human Rights Commission (SAHRC) has compiled a guide on how to use PAIA ("the Guide"). The Guide is available in all official languages and contains information to assist you in exercising your rights under PAIA.

The Guide can be obtained from:

5. Categories of Records Held

BlackNet holds various categories of records, including but not limited to:

5.1 Company Records

• Company registration documents
• Memorandum and Articles of Association
• Minutes of Board and shareholder meetings
• Share registers and certificates
• Annual financial statements

5.2 Customer Records

• Customer registration and application forms
• Service agreements and contracts
• Billing and payment records
• Service usage data
• Customer correspondence and support records
• Credit information

5.3 Employee Records

• Employment contracts and applications
• Personnel files
• Payroll and benefits information
• Performance evaluations
• Training records
• Disciplinary records

5.4 Financial Records

• Banking records and statements
• Tax records and returns
• Accounting records
• Invoices and receipts
• Budget and financial projections

5.5 Operational Records

• Network infrastructure documentation
• Service level agreements
• Supplier and vendor contracts
• Equipment and asset registers
• Policies and procedures

5.6 Legal and Compliance Records

• Licenses and permits
• Legal opinions and correspondence
• Litigation files
• Compliance documentation
• Insurance policies

6. How to Request Access to Records

6.1 Requesting Procedure

To request access to records held by BlackNet, you must:

1. Complete the prescribed request form (Form A or Form C as appropriate)
2. Provide sufficient detail to enable us to identify the record(s) requested
3. Specify the form in which you wish to access the record
4. Provide proof of your identity
5. Pay the applicable request fee (if any)

6.2 Request Forms

Request forms are available:

• From the Information Officer at the contact details provided above
• From the SAHRC website: www.sahrc.org.za

6.3 Where to Submit Requests

Completed request forms should be submitted to:

7. Fees

7.1 Request Fee

A request fee of R50.00 is payable when submitting a request (except for personal information requests). This fee is not refundable.

7.2 Access Fees

Additional fees may apply for searching, preparing, reproduction, and delivery of records. These fees are prescribed in the PAIA Regulations and will be communicated to you before processing your request.

7.3 Payment Methods

Fees may be paid via electronic funds transfer to BlackNet's designated bank account. Payment details will be provided upon request.

8. Processing of Requests

8.1 Timeline

BlackNet will respond to your request within 30 days of receiving the completed request form and applicable fees. This period may be extended by a further 30 days if necessary, and you will be notified of any extension.

8.2 Grounds for Refusal

BlackNet may refuse a request for access to a record on the grounds set out in Chapter 4 of PAIA, including:

• Protection of personal information of third parties
• Commercial information of a third party or BlackNet
• Protection of confidential information
• Legal privilege
• The record does not exist or cannot be found

If your request is refused, you will be provided with written reasons and informed of your right to appeal.

9. Remedies Available if Request is Refused

9.1 Internal Appeal

You may lodge an internal appeal with the head of BlackNet within 60 days of being notified of the refusal.

9.2 Court Application

You may apply to a court for relief within 180 days of being notified of the refusal.

9.3 Complaint to the Information Regulator

You may lodge a complaint with the Information Regulator:

10. Protection of Personal Information

BlackNet is committed to protecting the personal information of its customers, employees, and other data subjects in accordance with POPIA.

For more information on how we process and protect personal information, please refer to our Privacy Policy.

11. Availability of Manual

This manual is available:

• On our website: blacknet.co.za
• At our offices during business hours
• From the Information Officer upon request

12. Updates to This Manual

This manual may be updated from time to time to reflect changes in our operations or legal requirements. The latest version will always be available on our website.