paia-manual

Promotion of Access to Information Act 2 of 2000

ComplyPath (Pty) Ltd
Registration Number: 2026/429764/07
Compiled in accordance with Section 51 of the Promotion of Access to Information Act 2 of 2000 (“PAIA”)

Last updated: June 2026

PART 1: INTRODUCTION

1.1 Purpose of this Manual

This manual is compiled in terms of Section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA). The purpose of PAIA is to give effect to the constitutional right of access to information held by private bodies, where that information is required for the exercise or protection of any rights.

This manual is intended to provide sufficient information to enable any person to exercise the right of access to records held by ComplyPath (Pty) Ltd.

1.2 Availability of this Manual

This manual is available:

• On the ComplyPath website at complypath.co.za/paia-manual
• In printed form at the registered office of ComplyPath upon request
• From the South African Human Rights Commission (SAHRC) at sahrc.org.za

1.3 South African Human Rights Commission Guide

The SAHRC has published a guide on how to use PAIA. This guide is available at sahrc.org.za or by contacting the SAHRC at:

South African Human Rights Commission
Private Bag 2700
Houghton 2041
Tel: 011 877 3600
Email: paiarequest@sahrc.org.za

PART 2: CONTACT DETAILS OF THE INFORMATION OFFICER

In terms of PAIA, the head of a private body must designate an Information Officer to facilitate requests for access to information.

Information Officer
Name: Trevor Pascall
Designation: Director
Company: ComplyPath (Pty) Ltd
Registration Number: 2026/429764/07
Physical Address: Apartment 6, Farnham Court, 259 Main Road, Claremont, Western Cape, 7708
Postal Address: Apartment 6, Farnham Court, 259 Main Road, Claremont, Western Cape, 7708
Email: trevor@complypath.co.za
Website: complypath.co.za

PART 3: RECORDS HELD BY COMPLYPATH

3.1 Categories of Records

ComplyPath holds the following categories of records:

3.1.1 Corporate and Legal Records

• Certificate of Incorporation (COR14.3)
• Memorandum of Incorporation (MOI)
• Share register
• Minutes of directors’ meetings
• Statutory registers

3.1.2 Financial Records

• Annual financial statements
• Management accounts
• Bank statements
• Tax returns and records
• VAT records
• Invoices and receipts
• Payroll records

3.1.3 Human Resources Records

• Employment contracts
• Employee personal records
• Leave records
• Disciplinary records
• Training records
• UIF records

3.1.4 Customer and User Records

• User account information (name, email address)
• Subscription and billing records
• Compliance assessment responses and scores
• Communication records

3.1.5 Compliance Records

• POPIA registration certificate and correspondence with the Information Regulator
• Data Protection Impact Assessment (DPIA)
• Data Processing Agreements with third-party operators
• Privacy Policy and this PAIA Manual

3.1.6 Operational Records

• Supplier and service provider contracts
• Insurance policies
• IT system documentation
• Website and platform records

PART 4: RECORDS AVAILABLE WITHOUT A PAIA REQUEST

The following records are available to the public without a formal PAIA request:

• This PAIA Manual (available on our website)
• Privacy Policy (available on our website)
• Terms and Conditions (available on our website)
• Disclaimer (available on our website)
• Compliance assessment results (available to the registered user through their account)

PART 5: HOW TO REQUEST ACCESS TO RECORDS

5.1 Form to Use

Requests for access to records must be made using Form C as prescribed under PAIA. Form C is available from:

• The SAHRC at sahrc.org.za
• The Department of Justice at justice.gov.za

5.2 Where to Submit the Request

Completed Form C must be submitted to the Information Officer:

By email: trevor@complypath.co.za
By post: Apartment 6, Farnham Court, 259 Main Road, Claremont, Western Cape, 7708

5.3 Request Fee

A request fee of R50.00 (fifty rand) is payable before a request will be processed, unless the requester is a personal requester seeking access to their own personal information, in which case no request fee is payable.

Payment must be made by EFT to:

• Bank: Nedbank
• Account type: Current Account
• Account name: ComplyPath (Pty) Ltd
• Account number: 1343426189
• Branch code: 198765
• Reference: PAIA Request — [Your Full Name]

5.4 Access Fee

An access fee may be charged for the reproduction and search for records in accordance with the prescribed tariff under PAIA. ComplyPath will notify you of the access fee before processing your request.

5.5 Information Required in the Request

Your request must include:

• Your full name and contact details
• A description of the record(s) you are requesting
• The form in which you wish to receive the record (copy, inspection, etc.)
• If you are requesting on behalf of another person, proof of your authority to do so
• The right you are seeking to exercise or protect and why the record is required for this purpose
• Proof of identity (copy of ID document)

5.6 Response Timeframe

ComplyPath will respond to your request within 30 days of receipt of a complete request and payment of the request fee. This period may be extended by a further 30 days in exceptional circumstances, in which case you will be notified.

PART 6: GROUNDS FOR REFUSAL

ComplyPath may refuse access to records on the grounds set out in PAIA, including where:

• The record contains personal information about a third party who has not consented to disclosure
• Disclosure would constitute a breach of a duty of confidence
• The record is protected by legal privilege
• Disclosure would prejudice commercial interests or trade secrets
• Disclosure would be in contempt of a court order
• The record does not exist or cannot be found

If your request is refused, you will be notified in writing with reasons, and you will be informed of your right to appeal the decision.

PART 7: APPEAL AGAINST REFUSAL

If ComplyPath refuses your request, you may:

1. Apply to a court for relief in terms of Section 78 of PAIA
2. Lodge a complaint with the Information Regulator:

Information Regulator of South Africa
JD House, 27 Stiemens Street
Braamfontein, Johannesburg, 2001
Tel: 010 023 5207
Email: inforeg@justice.gov.za
Website: inforeg.org.za

PART 8: LEGISLATION APPLICABLE TO COMPLYPATH

ComplyPath’s activities are subject to the following legislation, among others:

• Companies Act 71 of 2008
• Income Tax Act 58 of 1962
• Value Added Tax Act 89 of 1991
• Protection of Personal Information Act 4 of 2013
• Promotion of Access to Information Act 2 of 2000
• Electronic Communications and Transactions Act 25 of 2002
• Consumer Protection Act 68 of 2008
• Basic Conditions of Employment Act 75 of 1997
• Labour Relations Act 66 of 1995
• Unemployment Insurance Act 63 of 2001
• Compensation for Occupational Injuries and Diseases Act 130 of 1993
• Occupational Health and Safety Act 85 of 1993

PART 9: UPDATING THIS MANUAL

This manual will be reviewed and updated annually or when material changes occur. The current version is always available at complypath.co.za/paia-manual.

ComplyPath (Pty) Ltd — Registration Number 2026/429764/07
Trevor Pascall, Information Officer — trevor@complypath.co.za
Apartment 6, Farnham Court, 259 Main Road, Claremont, Western Cape, 7708