Legal
PAIA Manual
Prepared and compiled in accordance with Section 51 of the Promotion of Access to Information Act 02 of 2000 (as amended). Date of revision: 29 June 2026.
Lathodami Radiators
and Mining Supplies
77 Zendeling Street, Rustenburg, 0299
Index
- List of acronyms and abbreviations
- Purpose of the PAIA Manual
- Key contact details
- Guide on how to use PAIA
- Categories of records available without request
- Records available under other legislation
- Subjects on which the body holds records
- Processing of personal information
- Request procedure
- Availability of the Manual
- Updating of the Manual
- Annexure A: Applicable fees
- Annexure B: Form 2 — Request for Access
- Annexure C: Form 3 — Outcome of Request
1. List of Acronyms and Abbreviations
| Term | Definition |
|---|---|
| "Data Subject" | The person to whom Personal Information relates, as contemplated in terms of section 1 of POPIA. |
| "Deputy Information Officer" | A Deputy Information Officer designated in terms of section 56 of POPIA. |
| "Information Officer" | In the case of a juristic person: the chief executive officer or equivalent officer, or any person duly authorised by that officer, as contemplated in section 1 of the Act. |
| "Information Regulator" | The Information Regulator established in terms of section 39 of POPIA. |
| "Manual" | This manual compiled by Lathodami Radiators and Mining Supplies in terms of PAIA and POPIA. |
| "PAIA" | The Promotion of Access to Information Act, 2 of 2000, including the PAIA regulations, as amended from time to time. |
| "Personal Information" | Information relating to an identified, or identifiable, living natural person and, where applicable, an identifiable existing juristic person as contemplated in POPIA. |
| "Personnel" | All partners, directors, officers, employees, individual contractors and other personnel of Lathodami Radiators and Mining Supplies. |
| "POPIA" | The Protection of Personal Information Act, 4 of 2013, including the POPIA regulations, as amended from time to time. |
| "Processing" | Any operation, activity or set of operations, whether or not by automated means, concerning Personal Information as contemplated in POPIA. |
| "Private Body" | Any former or existing juristic person, as contemplated in the Act and POPIA. |
| "Record" | A record as contemplated in PAIA and includes Personal Information. |
| "Requester" | In relation to a Private Body: any person making a request for access to a Record of that Private Body, or a person acting on behalf of such person. |
| "Responsible Party" | A public or Private Body or any other person which, alone or in conjunction with others, determines the purpose of and means for Processing Personal Information as contemplated in POPIA. |
2. Purpose of the PAIA Manual
To promote effective governance of private bodies, it is necessary to ensure that everyone is empowered and educated to understand their rights in terms of PAIA, in order for them to exercise their rights in relation to public and private bodies. Wherever reference is made to “Private Body” in this manual, it will refer to Lathodami Radiators and Mining Supplies.
This PAIA Manual is useful for the public to:
- Check the categories of records held by a body which are available without a person having to submit a formal PAIA request.
- 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.
- Know the description of the records of the body which are available in accordance with any other legislation.
- Access all the relevant contact details of the Information Officer and Deputy Information Officer who will assist the public with the records they intend to access.
- Know the description of the guide on how to use PAIA, as updated by the Information Regulator and how to obtain access to it.
- 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.
- Know the description of the categories of data subjects and of the information or categories of information relating thereto.
- Know the recipients or categories of recipients to whom the personal information may be supplied.
- Know if the body has planned to transfer or process personal information outside the Republic of South Africa and the recipients or categories of recipients to whom the personal information may be supplied.
- Know whether the body has appropriate security measures to ensure the confidentiality, integrity and availability of the personal information which is to be processed.
3. Key Contact Details
Information Officer
Name: Gysbert Van Rooyen
Tel: 014 753 4890
Head Office
Physical: 77 Zendeling Street, Rustenburg, 0299
Postal: 77 Zendeling Street, Rustenburg, 0299
4. Guide on How to Use PAIA
The Information Regulator has, in terms of section 10(1) of PAIA, as amended, updated and made available a revised Guide on how to use PAIA, 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.
The Guide is available in each of the official languages and in braille. It can be obtained:
- Upon request to the Information Officer.
- From the website of the Information Regulator: inforegulator.org.za
The Guide contains descriptions of the objects of PAIA and POPIA, contact details for Information Officers, the manner and form of requests for access to records, assistance available from the Information Officer and the Information Regulator, all available legal remedies, and provisions regarding voluntary disclosure of records.
A copy of the Guide is also available in English and Afrikaans for public inspection during normal office hours.
5. Categories of Records Available Without Request
This table details records that are generally made public by the private body and can be accessed on the website or by simple request, without needing to follow the formal PAIA request procedure.
| Category | Types of Record | On Website | On Request |
|---|---|---|---|
| Corporate Information and Business Profile | General information, corporate profile, areas of service and product information | ✓ | ✓ |
| Publications and Communications | Communications, newsletters, and various publications | ✓ | ✓ |
| Marketing Materials | Brochures, pamphlets, posters and other marketing or promotional material | ✓ | ✓ |
| Privacy Compliance Records | PAIA Manual and Privacy Notices | ✓ | ✓ |
| Terms of the Private Body | Terms and conditions | — | ✓ |
6. Records Available Under Other Legislation
This table lists the types of records the private body is required to keep by various South African laws, along with the relevant legislation that mandates their retention.
| Category | Types of Records | Applicable Legislation |
|---|---|---|
| Governance Records | Memorandum of Incorporation, Registration documents, Information on directors and shareholders, Share registers, Minutes of meetings, Other corporate governance information | Companies Act 71 of 2008 |
| Employment Related Records | Personal information and employee details, Employment contracts and conditions of service, Payroll, leave and remuneration records, Pension and/or Provident Fund records, Disciplinary, grievance and other labour related records, Employment Equity and skills development plans and reports, Health and safety records, Workmen's compensation records | Basic Conditions of Employment Act 75 of 1997; Labour Relations Act 66 of 1995; Employment Equity Act 55 of 1998; Occupational Health and Safety Act 85 of 1993; Compensation for Occupational Injuries and Diseases Act 130 of 1993; Immigration Act 13 of 2002; Income Tax Act 58 of 1962; Skills Development Act 97 of 1998; Skills Development Levies Act 9 of 1999; Pension Funds Act 24 of 1956; Unemployment Insurance Act 63 of 2001 |
| Financial and Tax Records | Financial statements and accounting records, Tax records (Income Tax, VAT, PAYE, SDL, UIF) | Income Tax Act 58 of 1962; Value Added Tax Act 89 of 1991 |
| Privacy Related Records | PAIA Manual, Privacy Notice, Records relating to electronic communications and transactions | Promotion of Access to Information Act 02 of 2000; Protection of Personal Information Act 04 of 2013; Electronic Communications and Transactions Act 25 of 2002 |
| Other Records | B-BBEE status and supplier information, Records of consumer transactions and complaints | Broad-Based Black Economic Empowerment Act 53 of 2003; Consumer Protection Act 68 of 2008 |
While every reasonable effort has been made to compile a comprehensive list, it remains possible that the list may be incomplete. If a requester believes that a right of access to a record exists under any legislation, whether listed or not, they are required to clearly indicate the specific legislative provision upon which the request is based.
7. Subjects and Categories of Records Held
| Subject | Categories of Records |
|---|---|
| Corporate and Company Secretarial Records | Memorandum of Incorporation / Partnership agreement, Company registration documents, Minutes, resolutions, share registers, Records related to trademarks and other intellectual property, Insurance records |
| Financial and Accounting Records | Annual financial statements, accounting records, audit reports, tax records, bank statements, asset registers, budgets, Invoices, receipts, and source documents for creditors and debtors |
| Human Resources / Employee Records | Personnel files, employment contracts and conditions of service, Payroll, remuneration, leave, employee benefits records (pension and/or provident fund, medical aid), Performance evaluations, disciplinary records, grievance procedures, Employment equity plans, skills development reports, training records |
| Client-Related Records | Client engagement letters and agreements, Correspondence with clients and third parties, Files related to clients |
| Administration, Operations, and Property | Agreements with suppliers and service providers, Lease agreements for property, Internal and external correspondence, tender documentation, security records |
| Information Technology | Computer software, licensing and maintenance agreements, Records regarding computer systems, IT usage policies |
8. Processing of Personal Information
8.1 Purpose of Processing Personal Information
| Categories of Data Subjects | Purpose for Processing |
|---|---|
| Clients (prospective, new, and existing) | To provide services and perform actions under the services contract; To manage the commercial relationship, including billing and accounting; To comply with regulatory obligations; For marketing communications (where requested) and responding to correspondence |
| Employees (permanent, temporary, part-time) and Job Applicants | To conclude and perform actions under the employment contract; For recruitment, administering payroll, benefits, and other general HR functions; To comply with legal obligations under employment legislation; To assess credit and criminal history where relevant for employment |
| Suppliers, Service Providers, Contractors, and Business Partners | To perform actions under the services contract and manage the supplier relationship; For the execution of payment processing functions and managing invoices; To comply with legal and regulatory obligations |
| Visitors to Premises | To monitor access for safety and security reasons, including processing CCTV footage; For health and safety purposes |
| Website Interaction | For improving and monitoring the performance of digital platforms; To allow for the proper functioning of the website |
8.2 Categories of Data Subjects and Information Processed
| Data Subject | Personal Information that May Be Processed |
|---|---|
| Clients (and related parties) | Identifying information (entity/individual name, registration/identity number); Contact information (email, postal/physical address, contact numbers); Transaction information (contact person details and designation, VAT numbers, service delivery addresses); Financial information (banking and account details) |
| Employees and Job Applicants | Identifying information (full name, identity/passport/work visa/asylum numbers, employee number, date of birth, gender); Contact information (contact numbers, email, physical and/or postal address); Emergency contact information; Remuneration information (banking and account details); HR and employment information (employment contracts, personnel files, leave records, disciplinary records); Background information (CV, qualifications, criminal history, trade information, work experience); Legislation-required information (race/ethnicity, disability, employment and skills information, tax-related information); Other information (dietary preference, religious holidays, medical aid/provident fund/pension fund information) |
| Suppliers, Service Providers, and Business Partners | Identifying information (entity/individual name, registration/identity number); Contact information (email, postal/physical address, contact numbers); Transaction information (contact person details and designation, VAT numbers, invoicing details); Financial information (banking and account details) |
| Visitors to Premises | CCTV footage and other personal information for security and access monitoring |
8.3 Recipients to Whom Personal Information May Be Supplied
| Category of Personal Information | Recipients |
|---|---|
| Identity number and names, for criminal checks | South African Police Services; Criminal Background Verification Agencies |
| Qualifications, for qualification verifications | South African Qualifications Authority; Qualification Verification Agencies |
| Credit and payment history, for creditworthy verification | Credit Bureaus; Credit Verification Agencies |
| Tax and VAT information | South African Revenue Services |
| Employee information, for legislative compliance and payroll | Department of Labour; Payroll service providers |
| Personal information of clients, service providers, suppliers and/or employees | Cloud storage and/or productivity solution providers like Microsoft 365 and/or Google Business; Other service providers or third-party suppliers, should the transaction/service require information sharing |
8.4 Planned Transborder Flow of Personal Information
Generally, we do not transfer your personal information to another country. However, in certain cases this may be necessary, for example, when our suppliers are based outside South Africa or when the service we provide involves a foreign party. Such transfers will only take place if:
- They are essential to the nature of the transaction, and
- They comply with the requirements of POPIA and/or other applicable South African laws.
When we do transfer your information across South African borders, we will take steps to ensure that the country or organisation receiving it has strong safeguards in place. This includes ensuring the destination country’s laws offer similar protection to POPIA, confirming that binding corporate rules are in place, or relying on legal agreements that guarantee your information is handled securely and respectfully.
Use of cloud-based software: We use trusted software tools such as Microsoft 365 and Google Business to support our business operations and store personal information. These tools may store data on servers located outside South Africa. We believe these providers offer adequate protection for the personal information we entrust to them.
8.5 Information Security Measures
Lathodami Radiators and Mining Supplies has implemented a range of reasonable technical and organisational security measures to protect personal information against unauthorised access, unlawful processing, loss, destruction, or damage. These measures are reviewed and updated on a regular basis.
Technical Measures
- Network and System Security: Utilisation of firewalls, malware and anti-virus protection, software patching, and data loss prevention technologies.
- Data Protection: Encryption of sensitive data and regular data backups with testing to ensure recoverability.
- Access Control: Use of unique user IDs and strong passwords, with access to information restricted on a "need-to-know" basis.
- Monitoring and Testing: Regular system monitoring, vulnerability scanning, and penetration testing to identify and mitigate threats.
Organisational Measures
- Policies and Procedures: Implementation of documented information security policies, business continuity plans, and risk assessments.
- Employee Awareness: Regular training for employees on security and privacy practices.
- Third-Party Management: Ensuring third-party operators and service providers apply adequate security safeguards through contractual agreements.
Physical Security
- Access Control: Restricting physical access to offices and sensitive areas.
- Secure Disposal: Implementing procedures for the appropriate disposal of assets containing personal information.
9. Request Procedure
To access records held by Lathodami Radiators and Mining Supplies, the requester must complete Form 2 (Annexure B) and submit it, along with the required request fee and any applicable deposit (as set out in Annexure A), to the Information Officer using the contact details in Section 3.
The form must include enough detail to identify:
- The record;
- The requester’s identity;
- The preferred method of access, and the reason the information is needed to exercise or protect a specific right.
Requests submitted on behalf of another person must be accompanied by proof of authority. Where the requester is unable to complete the form due to illiteracy or disability, the request may be made orally at the address of Lathodami Radiators and Mining Supplies and assistance will be provided.
Upon receipt of the request, the Information Officer will notify the requester of any fees due and will only proceed once payment has been received. If access is granted, additional fees may apply for reproduction or preparation. In cases where access is denied, any deposit paid will be refunded. The requester will be informed of the outcome within 30 days using Form 3 (Annexure C).
Access may be refused to records if disclosure would compromise another person’s privacy, reveal confidential third-party or company information, expose trade secrets, commercially sensitive information, or could harm the competitive position. Access may also be denied for legally privileged or contractually protected content, research that could be disadvantaged by disclosure, or requests that are frivolous or unduly burdensome.
10. Availability of the Manual
A copy of this manual is available:
- On the website of Lathodami Radiators and Mining Supplies.
- At the head office for public inspection during normal business hours.
- To any person upon request, upon payment of a reasonable prescribed fee.
- To the Information Regulator upon request.
A fee for a copy of the Manual, as contemplated in Annexure B of the PAIA Regulations, shall be payable per each A4-size photocopy made.
11. Updating of the Manual
The head of Lathodami Radiators and Mining Supplies will on a regular basis update this manual. Issued by: Gysbert Van Rooyen, Information Officer.
12. Annexure A — Applicable Fees
| # | Description | Amount |
|---|---|---|
| 1 | The request fee payable by every requester | R 140.00 |
| 2 | Photocopy/printed black & white copy of A4-size page | R 2.00 per page or part thereof |
| 3 | Printed copy of A4-size page | R 2.00 per page or part thereof |
| 4 | For a copy of computer-readable form on: (i) Flash drive (provided by requestor); (ii) Compact Disk — if provided by requester / if provided to the requester | R 40.00 / R 40.00 / R 60.00 |
| 5 | For a transcription of visual images per A4-size page | Service to be outsourced — will depend on quotation from service provider |
| 6 | For a copy of visual images | Service to be outsourced — will depend on quotation from service provider |
| 7 | Transcription of an audio record, per A4-size page | R 24.00 |
| 8 | For a copy of audio recording on: (i) Flash drive (provided by requestor); (ii) Compact Disk — if provided by requester / if provided to the requester | R 40.00 / R 40.00 / R 60.00 |
| 9 | To search for and prepare the record for disclosure, for each hour or part of an hour, excluding the first hour. Not to exceed a total cost of R 435.00 | R 145.00 per hour |
| 10 | Deposit: If search exceeds 6 hours | One third of the amount per request calculated in terms of items 2 to 8 |
| 11 | Postage, email or any other electronic transfer | Actual expense, if any |
13. Annexure B — Form 2: Request for Access to Record
REQUEST FOR ACCESS TO RECORD [Regulation 7]
To request access to a record held by Lathodami Radiators and Mining Supplies, submit Form 2 to the Information Officer at:
Email: ltdmradiators@ltdmradiators.co.za
The form requires the following information:
- Requester’s personal information: Full names, identity number, capacity, postal address, street address, email address, and contact numbers.
- If making a request on behalf of another person: Full names and identity number of that person, plus proof of authorisation.
- Particulars of the record requested: Description of the record or relevant part thereof, reference number (if available), and any further particulars.
- Type of record: Written/printed form; visual images; recorded words/sounds; or computer/electronic/machine-readable form.
- Form of access preferred: Printed copy; written/printed transcription of visual images; transcription of soundtrack; copy on flash drive; copy on compact disc; or copy saved on cloud storage.
- Manner of access preferred: Personal inspection; postal services; courier; facsimile; email; or cloud share/file transfer.
- Right to be exercised or protected: Indicate which right is to be exercised or protected and explain why the record is required for that purpose.
- Fee exemption (if applicable): State the reason for any claimed exemption from fees.
Note: Proof of identity must be attached. If the request is made on behalf of another person, proof of such authorisation must be attached. A request fee of R 140.00 must be paid before the request will be considered.
14. Annexure C — Form 3: Outcome of Request and Fees Payable
OUTCOME OF REQUEST AND FEES PAYABLE [Regulation 8]
Once your request has been processed, you will be notified using Form 3 whether your request has been approved or denied. The following should be noted:
- If your request is granted, the amount of the deposit (if any) is payable before your request is processed, and the requested record/portion of the record will only be released once proof of full payment is received.
- Personal inspection of information at the registered address is free of charge. You are required to make an appointment and bring this Form with you. If you then require any form of reproduction of the information, you will be liable for the fees prescribed in Annexure A.
- The outcome form will confirm the access fee payable, the form of access granted, and the manner of delivery.
- The fees payable are as per the schedule set out in Annexure A above.
- If a deposit is required (where search exceeds six hours), you will be notified of the amount, which is calculated as one third of the total estimated reproduction cost.
- If your request is denied, the reason for denial will be provided and any deposit paid will be refunded.
Please use the reference number provided in all future correspondence regarding your request.
Need Help?
Contact the Information Officer
For any PAIA-related queries or to submit a request for access to records, contact Gysbert Van Rooyen directly.
ltdmradiators@ltdmradiators.co.za