PAIA Manual

01 List of Acronyms and Abbreviations

02 Purpose of 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 Carlz Scrap Metal (Pty) Ltd.

This PAIA Manual is useful for the public to:

1. Check the categories of records held by the body which are available without a formal PAIA request;
2. Have a sufficient understanding of how to make a request for access to a record of the body;
3. Know the description of records available in accordance with any other legislation;
4. Access all relevant contact details of the Information Officer and Deputy Information Officer;
5. Know the description of the guide on how to use PAIA, as updated by the Regulator;
6. Know if the body processes personal information and the purpose thereof;
7. Know the categories of data subjects and categories of information relating thereto;
8. Know the recipients or categories of recipients to whom personal information may be supplied;
9. Know if the body plans to transfer personal information outside the Republic of South Africa; and
10. Know whether the body has appropriate security measures to ensure confidentiality, integrity and availability of personal information.

03 Key Contact Details for Access to Information

3.1 Information Officer

3.2 Deputy Information Officer

3.3 Access to Information General Contacts

3.4 Head Office

04 Guide on How to Use PAIA and How to Obtain Access to the Guide

The Regulator has, in terms of section 10(1) of PAIA, updated and made available the 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.

The Guide contains the description of:

• The objects of PAIA and POPIA;
• The postal and street address, phone number and electronic mail address of the Information Officer of every public body, and every Deputy Information Officer;
• The manner and form of a request for access to a record of a public body or private body;
• The assistance available from the Information Officer in terms of PAIA and POPIA;
• The assistance available from the Regulator in terms of PAIA and POPIA;
• All remedies in law available regarding an act or failure to act in respect of a right or duty conferred or imposed by PAIA and POPIA;
• The provisions requiring a public body and private body to compile a manual, and how to obtain access to it;
• The provisions providing for the voluntary disclosure of categories of records;
• The notices issued regarding fees to be paid in relation to requests for access; and
• The regulations made in terms of section 92.

Members of the public can inspect or make copies of the Guide from the offices of public and private bodies, including the office of the Regulator, during normal working hours.

The Guide can also be obtained upon request to the Information Officer, or from the website of the Regulator: https://inforegulator.org.za/

05 Categories of Records Available Without a Formal PAIA Request

• Private body profile and general information about services offered (e.g., metal recycling, scrap collection, buying and selling of ferrous and non-ferrous metals).
• Service brochure or information sheets outlining accepted materials, pricing guidelines, and operational procedures.
• Standard terms and conditions for the purchase, sale, collection, or drop-off of scrap materials.
• Company website information, including services offered, operating hours, and contact details.
• Publicly available compliance certificates or accreditations, such as environmental permits, waste management licenses, or health and safety certifications (where published).

06 Records Available in Accordance with Other Legislation

The private body is required to maintain certain records in accordance with, but not limited to, the following legislation:

• Companies Act 71 of 2008 — company registration records, shareholder information, director information.
• Labour Relations Act 66 of 1995 — employment contracts, disciplinary records, labour relations documentation.
• Basic Conditions of Employment Act 75 of 1997 — employee attendance registers, leave records, working hours.
• Employment Equity Act 55 of 1998 — employment equity plans and reports.
• Skills Development Act 97 of 1998 — training records, skills development plans.
• Unemployment Insurance Act 63 of 2001 — employee contribution records.
• Compensation for Occupational Injuries and Diseases Act 130 of 1993 — workplace injury reports.
• Tax Administration Act 28 of 2011 and Income Tax Act 58 of 1962 — financial and tax records.
• POPIA (Protection of Personal Information Act 4 of 2013) — records related to data subject information and processing activities.

07 Description of Subjects and Categories of Records Held

• Private Body Administration — incorporation documents, governance records, CIPC registration, business licenses.
• Financial Records — annual financial statements, tax records, supplier and customer invoices, receipts, bank statements, audit reports.
• Human Resources — employment contracts, employee personal files, training and induction records, payroll data, leave and attendance records.
• Operations — purchase and sales agreements for scrap metal, weighbridge slips, material acceptance/rejection forms, collection and drop-off logs, proof of payment.
• Yard Inventory & Storage — inventory of scrap types and volumes, goods received notes, stock movement reports, storage records for segregated materials.
• Health and Safety — risk assessments, PPE registers, workplace safety audits, incident and injury reports, environmental compliance records, health and safety training logs.
• Clients & Customers — client onboarding forms, transaction records, communication logs, pricing agreements, payment history.
• Suppliers and Service Providers — supplier agreements, material sourcing records, invoices, proof of compliance.
• Information Technology — system and software usage logs, access control records, surveillance system data (e.g., CCTV footage), software licenses.

08 Processing of Personal Information

8.1 Purpose of Processing Personal Information

• Facilitating the purchase, sale, collection, and processing of scrap metal and recyclable materials.
• Managing customer and supplier accounts, service agreements, billing, and communications.
• Scheduling and coordinating collections, deliveries, and walk-in transactions.
• Ensuring compliance with environmental, health & safety, labour, and tax legislation.
• Enhancing customer service by responding to queries, complaints, or transaction disputes.
• Conducting marketing, promotions, and business development activities.
• Maintaining physical security of the premises through access control systems, CCTV monitoring, and visitor logs.
• Preventing fraud, theft, and illegal trade by maintaining accurate transaction records and verification processes.

8.2 Categories of Data Subjects and Information

• Employees and Job Applicants — personal details, CVs, employment history, qualifications, criminal and background checks (where required), payroll and banking information, disciplinary records, medical records (where applicable), health & safety training logs.
• Customers/Sellers — contact details, identity documents (ID book/card, driver's license), vehicle registration details (where required), payment history, transaction records, and CCTV footage for security and compliance purposes.
• Suppliers/Buyers — business contact information, company registration and tax details, B-BBEE certificates (where applicable), banking information, signed agreements, and transaction history.
• Yard Workers and Drivers — identity documents, certifications or training records, time and attendance records, disciplinary records, job assignments, and health and safety compliance documentation.
• Visitors to the Yard or Offices — identification details, visitor log entries, vehicle details (if applicable), access control records, and CCTV footage.

8.3 Recipients of Personal Information

• Statutory bodies and regulators (e.g., SARS, Department of Labour, Department of Transport).
• External auditors, accountants and legal advisors.
• Financial institutions (for payment processing).
• Insurance companies and brokers.
• Industry regulators and compliance authorities.
• IT service providers and data storage providers (subject to confidentiality).
• Customers and suppliers where contractual obligations require disclosure.
• Law enforcement or other authorities where legally obliged.

8.4 Planned Transborder Flow of Personal Information

N/A — no transborder transfers are planned.

8.5 Information Security Measures

• Restricted access to personal information on a "need-to-know" basis.
• Password protection and user authentication for IT systems.
• Firewalls, anti-virus software, and intrusion detection systems.
• Encrypted communication and data storage where applicable.
• Secure physical storage for paper-based records.
• CCTV monitoring and controlled access to premises.
• Regular employee training on POPIA compliance and information handling.
• Contracts with third-party service providers ensuring POPIA compliance.
• Backup and disaster recovery systems to ensure data availability.

09 Availability of the Manual

A copy of this manual is available:

• At the Head Office of Carlz Scrap Metal (Pty) Ltd 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.
• On this website at carlzscrap.co.za/paia-manual.html.

10 Updating of the Manual

The head of Carlz Scrap Metal (Pty) Ltd will on a regular basis update this manual.

A Annexure A — Schedule of Fees

The table below sets out the fees applicable to any request for a record of information held by Carlz Scrap Metal (Pty) Ltd:

B Annexure B — How to Request Access to a Record