PAIA Manual

This manual is published in terms of Section 51 of the Promotion of Access to Information Act 2 of 2000 ("PAIA"), as amended by the Protection of Personal Information Act 4 of 2013 ("POPIA"). The purpose of this manual is to inform the public of the records held by Lebo Grass and the procedure to be followed when requesting access to such records.

PAIA gives effect to the constitutional right of access to information held by private and public bodies, as enshrined in Section 32 of the Constitution of the Republic of South Africa, 1996. This right is subject to justifiable limitations, including but not limited to limitations aimed at the reasonable protection of privacy, commercial confidentiality, and the effective, efficient, and good governance of public and private bodies.

This manual is available for inspection at our offices at Sandton Corporate Woods, Johannesburg, 2196, during normal business hours, and on our website at no charge.

The Information Officer of Lebo Grass is responsible for facilitating requests for access to information in terms of PAIA and for ensuring compliance with POPIA.

Information Officer: Lebo Grass Physical Address: Sandton Corporate Woods, Johannesburg, 2196 Postal Address: Sandton Corporate Woods, Johannesburg, 2196 Telephone: +27 11 000 0000 Email: advisory@lebogrss.co.za

All requests for access to records or information, as well as complaints or enquiries relating to the processing of personal information, should be directed to the Information Officer at the contact details provided above.

The South African Human Rights Commission ("SAHRC") has compiled a guide in terms of Section 10 of PAIA to assist persons who wish to exercise their right of access to information. This guide is available from the SAHRC and contains information on:

(a) The objects of PAIA.

(b) The postal and street address, phone and fax number, and electronic mail address of the Information Officer of every public body.

(c) The manner and form of a request for access to a record of a public or private body.

(d) The assistance available from the Information Officer of a public body.

(e) The assistance available from the SAHRC.

(f) All remedies in law regarding acts or failures to act in respect of a right or duty conferred or imposed by PAIA.

(g) The regulations made in terms of Section 92 of PAIA.

The SAHRC can be contacted at: South African Human Rights Commission Forum 3, Braampark Office Park, 33 Hoofd Street, Braamfontein, 2017 Telephone: 011 877 3600 Website: www.sahrc.org.za

Lebo Grass holds records in the following categories. Note that the inclusion of a category does not imply that all records falling within that category will be made available upon request. Each request will be assessed on its merits in terms of PAIA.

(a) Company Records: Registration documents, memorandum of incorporation, shareholder records, minutes of meetings, annual financial statements, and regulatory filings.

(b) Financial Records: Accounting records, banking records, tax returns, VAT records, invoicing records, and audit reports.

(c) Client Records: Client agreements, coaching engagement records, session notes, client correspondence, booking records, payment records, and client personal information collected in the course of providing Services.

(d) Financial Coaching Records: Records relating to financial coaching engagements, including coaching plans, progress notes, assessment records, and recommendations made to clients.

(e) Employment and Human Resources Records: Employment contracts, personnel files, payroll records, disciplinary records, performance reviews, and training records.

(f) Intellectual Property Records: Copyright registrations, trademark registrations, licensing agreements, and records relating to the KPIPA Masterclass curriculum and educational publications.

(g) Website and Technology Records: Website analytics, server logs, database records, user account information, and records relating to electronic communications.

(h) Marketing and Communications Records: Marketing materials, advertising records, subscriber lists, and consent records.

(i) Regulatory and Compliance Records: FSCA filings, FAIS compliance records, FICA records, POPIA compliance records, and records relating to regulatory inspections or investigations.

Lebo Grass processes personal information of the following categories of data subjects:

(a) Clients: Individuals who have engaged our financial coaching services, attended masterclass sessions, or purchased educational materials.

(b) Prospective Clients: Individuals who have enquired about our services or expressed interest in our offerings.

(c) Website Users: Individuals who visit our website or use our online platform.

(d) Employees and Contractors: Current and former employees, independent contractors, and service providers engaged by Lebo Grass.

(e) Business Partners: Representatives of organisations with which we have business relationships, including payment processors, technology providers, and marketing partners.

(f) Suppliers: Individuals and representatives of organisations that supply goods or services to Lebo Grass.

(g) Complainants and Correspondents: Individuals who have lodged complaints with or directed correspondence to Lebo Grass.

A request for access to a record held by Lebo Grass must be made in accordance with the prescribed procedures under PAIA. The requester must complete the prescribed form (Form C, as set out in Annexure B of the Regulations Relating to the Promotion of Access to Information, Government Notice R223 in Government Gazette 23119, published on 9 March 2002, as amended) and submit it to the Information Officer at the contact details provided in Section 2 of this manual.

The request form must:

(a) Provide sufficient detail to enable the Information Officer to identify the record(s) requested.

(b) Indicate the form of access required (e.g., inspection, copies, or transcription).

(c) Specify a postal or email address to which the response should be sent.

(d) If the requester is acting on behalf of another person, provide proof of the capacity in which the requester is acting.

(e) If the request is made on behalf of a data subject in terms of POPIA, identify the data subject and provide proof of authorisation.

The Information Officer will respond to the request within thirty (30) days of receipt, as required by PAIA. This period may be extended by a further period of not more than thirty (30) days if the request is for a large number of records, or if the search for the records requires a search through a large number of records, and compliance within the original period would unreasonably interfere with the activities of Lebo Grass.

PAIA provides for two types of fees:

(a) Request Fee: A non-refundable request fee of R50.00 is payable by every requester, other than a personal requester (a person requesting access to their own personal information). The request fee must be paid before the request will be processed.

(b) Access Fee: An access fee is payable for the reproduction of the record and for the time reasonably required to search for and prepare the record for disclosure. The access fee is calculated in accordance with the fee schedule prescribed in the Regulations to PAIA (Government Notice R223, as amended). The access fee must be paid before access to the record is granted.

The Information Officer will notify the requester of the applicable fees and the manner of payment. A deposit may be required if the access fee is likely to exceed R100.00.

The fees prescribed under PAIA are subject to change as determined by the Minister from time to time by notice in the Government Gazette. Requesters are advised to confirm the current fee schedule with the Information Officer at the time of making a request.

A personal requester (requesting access to their own personal information) is not required to pay the request fee but may still be required to pay the access fee for the reproduction of records.

Lebo Grass may refuse a request for access to records in accordance with the grounds for refusal set out in Chapter 4 of Part 3 of PAIA. These grounds include, but are not limited to:

(a) Protection of Personal Information of Third Parties (Section 63): Access may be refused if the record contains personal information of a third party, unless that third party has consented to the disclosure or the information is already publicly available.

(b) Protection of Commercial Information of Third Parties (Section 64): Access may be refused if disclosure would cause harm to the commercial or financial interests of a third party.

(c) Protection of Confidential Information of Third Parties (Section 65): Access may be refused if the record contains information supplied in confidence by a third party, and disclosure could reasonably be expected to prejudice the future supply of such information.

(d) Protection of Safety of Individuals and Property (Section 66): Access may be refused if disclosure could reasonably be expected to endanger the life or physical safety of an individual.

(e) Protection of Records Privileged from Production in Legal Proceedings (Section 67): Access may be refused if the record is privileged from production in legal proceedings, including records subject to legal professional privilege.

(f) Protection of Commercial Information of Lebo Grass (Section 68): Access may be refused if disclosure could reasonably be expected to cause harm to the commercial or financial interests of Lebo Grass.

(g) Protection of Research Information (Section 69): Access may be refused if disclosure would expose research being conducted by or on behalf of Lebo Grass to serious disadvantage.

(h) Requests Deemed Frivolous or Vexatious (Section 45): The Information Officer may refuse a request that is manifestly frivolous or vexatious, or which involves an unreasonable diversion of the resources of Lebo Grass.

If a request for access to a record is refused, the requester may, within thirty (30) days of notification of the refusal, lodge an internal appeal (where applicable) or apply to a court of competent jurisdiction for appropriate relief.

The requester may also lodge a complaint with the Information Regulator:

Information Regulator (South Africa) JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001 P.O. Box 31533, Braamfontein, Johannesburg, 2017 Telephone: 010 023 5207 Email: enquiries@inforegulator.org.za

The Information Regulator has the power to investigate complaints, issue enforcement notices, and impose administrative fines for non-compliance with PAIA and POPIA.

This PAIA Manual is available:

(a) On our website for download and viewing at no charge.

(b) For inspection at our offices at Sandton Corporate Woods, Johannesburg, 2196, during normal business hours (Monday to Friday, 08:00 to 17:00), at no charge.

(c) Upon request, a copy may be obtained from the Information Officer. A reasonable fee may be charged for the reproduction of a physical copy.

(d) At the offices of the South African Human Rights Commission.

This manual will be updated from time to time as required by law or as necessitated by changes to our business operations, records, or data processing activities. The date of the most recent update is indicated at the top of this manual.