PAIA MANUAL

Last Updated: July 2025

2. INTRODUCTION

2.1 This Promotion of Access to Information Act “PAIA” Manual is in respect of Tecroveer, which is registered and incorporated in the Republic, registration number 2012/140908/07

2.2 PAIA was enacted on 3 February 2000 and gives effect to the constitutional rights of access to information held by another person and that is required for the exercise or protection of any rights. If a public body is the requester, the public body must be acting in the public interest. If a request is made in terms of PAIA, the body to whom the request is made is obliged to release the information, except where PAIA provides that the information may or must not be released. Requests in terms of PAIA must be made in accordance with the prescribed procedures, at the rates provided.

3 PURPOSE OF PAIA MANUAL

3.1 This PAIA Manual is intended to ensure that Tecroveer complies with PAIA and to foster a culture of transparency and accountability within the Company by giving effect to the right to information that is required for the exercise or protection of any right and to actively promote a society in which the people of the Republic have effective access to information to enable them to exercise and protect their rights.

3.3 PAIA gives effect to the constitutional right of any person’s access to information held by private sector bodies (companies) or public bodies (government institutions) that is required for the exercise and/or protection of the requester’s rights.

3.3 This PAIA Manual is useful for the public to:

3.3.1 Check the categories of records held by a body which are available without a person having to submit a formal PAIA request
3.3.2 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
3.3.3 Know the description of the records of the body which are available in accordance with any other legislation
3.3.4 Access all the relevant contact details of the IO and DIO who will assist the public with the records they intend to access
3.3.5 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
3.3.6 Know the recipients or categories of recipients to whom the personal information may be supplied
3.3.7 Know whether the body has appropriate security measures to ensure the confidentiality, integrity and availability of the personal information which is to be processed.

4 KEY CONTACT DETAILS FOR ACCESS TO INFORMATION OF TECROVEER

Information Officer:
Name: Izak Cronje
Tel: +27 11 752 1191
Email: izak@tecroveer.co.za

Deputy Information Officer:
Name: Adéle Grey
Tel: +27 63 206 0067
Email: adele@tecroveer.co.za

Website: www.tecroveer.co.za

Address:
9 Cooperskloof Road, Glen Harvie 1786

5. HOW TO USE PAIA AND HOW TO OBTAIN ACCESS TO THE REGULATOR’S GUIDE

5.1 The Regulator has, in terms of section 10(1) of P

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.

5.2 The Guide is available in each of the official languages and in Braille.

5.3 In order to assist those who are not familiar with PAIA or POPIA, a Guide that contains information to assist you in understanding how to exercise your rights under PAIA (“the Guide”) is available in all the South African official languages. The Guide is currently available on the following sites:

https://www.sahrc.org.za/index.php/understanding-paia

https://inforegulator.org.za/wp-content/uploads/2020/07/PAIA-GuideEnglish20210905.pdf

5.4 If you have any queries, or need a copy of the Guide, please contact the Information Regulator directly at:

The Information Regulator (South Africa) JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001, P.O Box 31533, Braamfontein, Johannesburg, 2017

Complaints email: complaints.IR@justice.gov.za

General enquiries email: inforeg@justice.gov.za

6. CATEGORIES OF RECORDS OF TECROVEER GROUP OF COMPANIES WHICH ARE AVAILABLE WITHOUT A PERSON HAVING TO REQUEST ACCESS

Below are the categories of records held by Tecroveer Group of Companies which are available without a person having to request access. These records are available on the website and a person may download or request telephonically or by sending an email or a letter.

PAIA Manual, Privacy Policy, Cookie Policy

7. RECORDS OF TECROVEER GROUP OF COMPANIES WHICH ARE AVAILABLE IN ACCORDANCE WITH ANY OTHER LEGISLATION

The Tecroveer Group is subject to many laws and regulations, some of which require us to keep certain records. These laws are detailed below. Please note that this list is not exhaustive.

The following Acts include, but are not limited to:

  1. Basic Conditions of Employment Act 75 of 1997
  2. Consumer Protection Act 68 of 2008
  3. Companies Act 61 of 1973
  4. Compensation for Occupational Injuries and Health Diseases Act 130 of 1993
  5. Employment Equity Act 55 of 1998
  6. Income Tax Act 58 of 1962
  7. Labour Relations Act 66 of 1995
  8. Occupational Health & Safety Act 85 of 1993
  9. Pension Funds Act 24 of 1956
  10. Skills Development Act 97 of 1998
  11. Skills Development Levies Act 9 of 1999
  12. Unemployment Contributions Act 4 of 2002
  13. Unemployment Insurance Act 30 of 1966
  14. Value Added Tax Act 89 of 1991

8. DESCRIPTION OF SUBJECTS TECROVEER GROUP HOLDS RECORDS ON AND CATEGORIES OF RECORDS

Tecroveer Group maintains records on the categories and subject matters listed below. Please note that recording a category or subject matter in this Manual does not imply that a request for access to such records would be granted. All requests for access will be evaluated on a case-by-case basis in accordance with the provisions of PAIA.

Please note that many of the records held by Tecroveer Group are those of third parties, such as clients and employees, and Tecroveer Group takes the protection of third-party confidential information very seriously. Requests for access to these records will be considered very carefully.

Internal records

Articles of Association
Financial records
Operational records;
Intellectual property;
Marketing records;
Internal correspondence;
Service records;
Statutory records;
Internal policies and procedures;
Minutes of meetings.

Personnel records

For the purposes of this section, “personnel” means any person who works for or provides services to or on behalf of Tecroveer Group and receives or is entitled to receive any remuneration and any other person who assists in carrying out or conducting the business of Tecroveer Group. This includes partners, directors, all permanent, temporary and part-time staff as well as consultants and contract workers.

Any personal records provided to us by our personnel
Any records a third party has provided to us about any of their personnel
Conditions of employment and other personnel-related contractual and quasi legal records
Employment policies and procedures
Internal evaluation and disciplinary records and Other internal records and correspondence.

Client-related records

Contracts with clients and between clients and other persons

Other third-party records

Personnel, client, or Tecroveer Group records which are held by another party as opposed to being held by Tecroveer Group and records held by Tecroveer Group pertaining to other parties, including financial records, correspondence, contractual records, records provided by the other party, and records third parties have provided about the contractors or suppliers.

9. INFORMATION RELATED TO POPIA

POPIA requires Tecroveer Group to provide certain information relating to how personal information that the Company process is, amongst others, used, disclosed and destroyed.

9.1 Tecroveer Group may collect personal information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, including, but not limited to:

 
9.1.1 Information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of the person
9.1.2 information relating to the education or the medical, financial, criminal or employment history of the person;
9.1.3 any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier or other particular assignment to the person
9.1.4 the biometric information of the person
9.1.5 correspondence sent by the person that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence;
9.1.6 the name of the person if it appears with other personal information relating to the person or if the disclosure of the name itself would reveal information about the person
 
8.2 The purpose of processing the above personal information by Tecroveer Group will depend on the nature of the personal information and the particular data subject. This purpose is ordinarily disclosed, explicitly or implicitly, at the time that the personal information is collected. The recipients or categories of recipients to whom the personal information may be shared or supplied to depends on the nature of the personal information, and the purpose or reason why it is being processed.
 
8.3 If a data subject visits Tecroveer’s website from a country other than South Africa, the various communications will necessarily result in the transfer of information across international boundaries.
 
8.4 Tecroveer Group takes extensive information security measures to ensure the confidentiality, integrity and availability of personal information in our possession and secured against unauthorised or unlawful processing and against accidental loss, destruction or damage.
These measures include firewalls, virus protection software and update protocols, logical and physical access control, secure set-up of hardware and software making up our information technology infrastructure and outsourced service providers who are contracted to implement security controls

10. GROUNDS FOR REFUSAL OF ACCESS AND PROTECTION OF INFORMATION

There are various grounds upon which a request for access to a record may be refused, including but not limited to:

10.1 The protection of personal information of a third person (who is a natural person) from unreasonable disclosure.

10.2 The protection of commercial information of a third party (for example: trade secrets; financial, commercial, scientific or technical information that may harm the commercial or financial interests of a third party).

10.3 If disclosure would result in the breach of a duty of confidence owed to a third party.

10.4 If disclosure would jeopardise the safety of an individual or prejudice or impair certain legal interests.

10.5 If the record was produced during legal proceedings, unless that legal privilege has been waived.

10.6 If the record contains trade secrets, financial or sensitive information or any information that would put Tecroveer Group at a disadvantage in negotiations or prejudice it in commercial competition.

10.7 If the record contains information about research being carried out or about to be carried out on behalf of a third party or by Tecroveer Group.

10.8 Disclosure of a record is compulsory if it would reveal:
 (i) a substantial contravention of, or failure to comply with the law; or
 (ii) there is an imminent and serious public safety or environmental risk; and
 (iii) the public interest in the disclosure of the record in question clearly outweighs the harm contemplated by its disclosure.

10.9 If the request for access to information affects a third party, then such third party must first be informed within 21 (twenty one) days of receipt of the request. The third party would then have a further 21 (twenty one) days to make representations and/or submissions regarding the granting of access to the record.

11. REMEDIES AVAILABLE TO A REQUESTER ON REFUSAL OF ACCESS

11.1 If the Information Officer decides to grant a requester access to the particular record, such access must be granted within 30 (thirty) days of being informed of the decision.

11.2 The decision made by the Information Officer is final.

11.3 In the event that the requester is not satisfied with the outcome of the request, an application may be made to the Information Regulator or a court of competent jurisdiction to take the matter further.

12. AVAILABILITY OF THE MANUAL

A copy of the Manual is available:

12.1 On the Tecroveer website. www.tecroveer.co.za

12.2 At Tecroveer Head Office during normal business hours.

12.3 To any person upon request and upon the payment of a reasonable prescribed fee.

12.4 To the Information Regulator upon request.

Request for Access to Record

To obtain access to any records held by us in terms of the Promotion of Access to Information Act (PAIA), please download and complete the official Request for Access to Record form. This form is required to formally submit your request and should include sufficient detail to enable us to identify the record you seek.

Once completed, submit the form to our Information Officer using the contact details provided below. For your convenience, the form is available for download here:

Please ensure to attach proof of your identity as required by PAIA. Our Information Officer will guide you through the next steps following receipt of your request.

Information Officer:

Table of Contents

© 2025 All rights Reserved