PAIA Manual of Omnisient (RF) (Pty) Ltd

PROMOTION OF ACCESS TO INFORMATION ACT, 2000 (ACT NO. 2 OF 2000)

PAIA MANUAL OF OMNISIENT (RF) (PTY) LTD

Prepared in accordance with section 51 of the Promotion of Access to Information Act, 2000 (PAIA), as amended, and the Protection of Personal Information Act, 2013 (POPIA).

Last updated: 8 December 2025

1. Introduction

The Promotion of Access to Information Act, 2000 (“PAIA”) gives effect to the constitutional right of access to information held by public and private bodies where such access is required for the exercise or protection of any rights.

Section 51 of PAIA requires private bodies to compile a manual that explains:

• what records they hold
• how persons can request access to those records
• how such requests will be processed and what fees may be payable.

This manual is published by Omnisient (RF) (Pty) Ltd (“the Company”, “we”, “us”) to comply with PAIA and to promote a culture of transparency, accountability and effective governance, in line with the constitutional values of openness and participation. It should be read together with our Privacy Policy, prepared in terms of the Protection of Personal Information Act, 2013 (POPIA).

2. Company Details

Name of Private Body
Omnisient (RF) (Pty) Ltd
(Registration No: 2014/187691/07)

Physical Address (Registered Office – South Africa)
Great Westerford, Unit SG110
240 Main Road
Rondebosch, Cape Town, 7700
South Africa

Postal Address
Great Westerford, Unit SG110
240 Main Road
Rondebosch, Cape Town, 7700
South Africa

Telephone
+27 72 154 3311

Website
https://www.omnisient.com

Information Officer
In terms of POPIA, the “head” of the private body is deemed to be the Information Officer, responsible for compliance with PAIA and POPIA. The Information Officer may designate one or more Deputy Information Officers.

• Information Officer: Jonathan Jacobson, CEO Email: [email protected] Physical Address: Great Westerford, Unit SG110, 240 Main Road, Rondebosch, Cape Town, 7700, South Africa
• Deputy Information Officer(s) : Name: Rivashani van Niekerk, GPO Email: [email protected] and Zaheer Patel, Head of Risk Management, [email protected]

The Information Officer and any Deputy Information Officers are responsible for:

• receiving and co‑ordinating responses to information requests under PAIA
• facilitating data subject requests under POPIA
• ensuring internal awareness and compliance with PAIA and POPIA.

3. Guide of the Information Regulator

The Information Regulator (South Africa) has published (or will publish) a Guide on how to use PAIA as contemplated in section 10 of PAIA. The Guide describes:

• the purpose of PAIA
• how to submit a request for access to information
• remedies available if your request is refused
• how to lodge complaints with the Information Regulator.

You may obtain the Guide (and any updates) from the Information Regulator at:

Information Regulator (South Africa)
JD House, 27 Stiemens Street
Braamfontein, Johannesburg, 2001
PO Box 31533, Braamfontein, Johannesburg, 2017
Tel: 010 023 5200
Email: [email protected]
Website: https://inforegulator.org.za/

4. Applicable Legislation

Various laws require the Company to keep certain records and/or give certain persons access to them. Below is a non‑exhaustive list of legislation that may be relevant to records held by the Company:

• Companies Act, 71 of 2008
• Protection of Personal Information Act, 4 of 2013 (POPIA)
• Promotion of Access to Information Act, 2 of 2000 (PAIA)
• Electronic Communications and Transactions Act, 25 of 2002
• Basic Conditions of Employment Act, 75 of 1997
• Labour Relations Act, 66 of 1995
• Employment Equity Act, 55 of 1998
• Skills Development Act, 97 of 1998
• Unemployment Insurance Act, 63 of 2001
• Occupational Health and Safety Act, 85 of 1993
• Income Tax Act, 58 of 1962
• Value‑Added Tax Act, 89 of 1991
• Customs and Excise Act, 91 of 1964
• Financial Intelligence Centre Act, 38 of 2001 (if applicable)
• National Credit Act, 34 of 2005 (if applicable)
• Consumer Protection Act, 68 of 2008 (if applicable)
• Any other legislation specifically applicable to the Company’s industry or operations.

Access to records may be subject to the conditions and limitations set out in these laws, PAIA and POPIA.

5. Categories of Records held by the Company

The Company holds various categories of records in relation to its operations. Access to many of these records will only be granted in accordance with PAIA, POPIA and other applicable law, and subject to confidentiality and privacy obligations.

5.1 Records Automatically Available (Without a PAIA Request)

The following categories of records are, or may be, available without the need to submit a formal PAIA Request Form:

• Information available on our Website (https://www.omnisient.com), including:
• Company overview and contact details
• Products and services information
• Marketing materials, brochures, white papers and case studies
• News and media releases
• Published policies (e.g. Privacy Policy, Cookies Policy, Website Terms of Use, PAIA Manual)
• Information available in public registers and filings (e.g. CIPC records, published annual reports where applicable).

We may revise the list of automatically available records from time to time.

5.2 Company Records (Internal)

• Company incorporation documents and registration certificates
• Memorandum of Incorporation and shareholder agreements (where applicable)
• Shareholder registers and share certificates
• Minutes of board and shareholder meetings
• Resolutions, company policies and procedures
• Statutory records and compliance documentation
• Insurance policies and related records
• Material contracts and service agreements
• Intellectual property records (trademarks, domain names, licences)

5.3 Financial and Tax Records

• Accounting records and ledgers
• Annual financial statements and management accounts
• Budgets and forecasts
• Bank records and payment records
• Invoices, receipts and statements
• Tax returns and supporting documents
• VAT records and correspondence with tax authorities

5.4 Human Resources (HR) and Employment Records

• Employment contracts and addenda
• Employee personnel files and performance records
• Payroll records, remuneration and benefits information
• Leave records and time records
• Recruitment and selection documentation (CVs, interview notes)
• Disciplinary, grievance and incapacity records
• Training and development records
• Employment equity and skills development reports

5.5 Client / Customer Records

• Client/customer master data and account information
• Contracts, proposals and statements of work
• Project records, communications and deliverables
• Billing, invoicing and payment records
• Support, helpdesk and incident management records
• Marketing preferences, opt‑ins and unsubscribe records

5.6 Supplier and Service Provider Records

• Supplier and contractor information
• Procurement documentation (where applicable)
• Supplier contracts and service level agreements
• Performance records and correspondence
• Invoicing, billing and payment records

5.7 IT, Security and Operations Records

• System architecture, configurations and logs
• Access control records and authentication logs
• Security incident and breach records
• Software licences and maintenance agreements
• Business continuity and disaster recovery plans
• Data processing, data sharing and transfer documentation

5.8 Records Containing Personal Information

The Company processes personal information as defined in POPIA. Categories of data subjects may include:

• Employees and candidates
• Clients and their representatives
• Suppliers and service providers
• Website visitors and users of our online services
• Business partners and stakeholders
• Members of the public who contact us.

Categories of personal information may include:

• Identification and contact details
• Employment and professional details
• Financial and transactional information
• Usage data, logs and cookies (as explained in our Privacy Policy)
• Any other information reasonably required for our business activities and compliance with the law.

Access to records containing personal information will be handled in line with both PAIA and POPIA, including data subject rights and privacy protections.

6. Records that may be Refused

In terms of PAIA, access to certain records may be refused on grounds that include (but are not limited to):

• Mandatory protection of privacy of natural persons (section 63)
• Mandatory protection of commercial information of third parties (section 64)
• Mandatory protection of confidential information of third parties (section 65)
• Mandatory protection of safety of individuals and protection of property (section 66)
• Mandatory protection of records privileged from production in legal proceedings (section 67)
• Mandatory protection of research information (section 69)
• Protection of the Company’s own commercial and confidential information (section 68).

Where a request is refused, you will receive a written response with reasons for the refusal and information on your rights of internal appeal (if applicable) and external remedies.

7. How to Request Access to a Record

7.1 Who May Request Access

Any person (a “Requester”) who requires access to a record of the Company for the exercise or protection of any rights may request access to that record in terms of PAIA. A data subject may also request access to their personal information in terms of POPIA.

If the Requester is acting on behalf of another person, proof of authority (e.g. power of attorney or mandate) must be provided.

7.2 Prescribed Form of Request

Requests must be made in writing on the prescribed Form C (Request for Access to Record of Private Body), which is available from:

• The Information Regulator website: https://inforegulator.org.za/
• The Department of Justice website: https://www.justice.gov.za/
• The Company, on request to the Information Officer.

7.3 Submission of Requests

Completed request forms, together with any applicable request fee and supporting documentation, must be submitted to the Information Officer at:

• Email: [email protected]
• Physical Delivery: Information Officer Omnisient (RF) (Pty) Ltd Great Westerford, Unit SG110 240 Main Road Rondebosch, Cape Town, 7700 South Africa

Please ensure that your request:

• is made on the prescribed form;
• provides sufficient detail to identify:
• the record(s) requested, and
• the right you wish to exercise or protect;
• explains why the requested record is required to exercise or protect that right;
• states the manner in which you wish to be informed of the decision (e.g. email, post); and
• provides full contact details (name, identity number / registration number, postal address, email, contact number).

If you request access on behalf of another person, attach the authorisation documents.

7.4 Assistance to Requesters

If you cannot read or write, are disabled, or need assistance for any other reason, the Information Officer or Deputy Information Officer will, as far as reasonably possible, help you complete the request form.

7.5 Processing of Requests and Time Period

Upon receipt of a valid request, the Company will:

• acknowledge receipt of the request;
• assess the request in terms of PAIA and POPIA;
• notify you if a request fee or deposit is payable;
• make a decision within 30 (thirty) calendar days, unless an extension is required.

The 30‑day period may be extended for a further period of up to 30 days in circumstances allowed by PAIA (for example, where the request is for a large volume of records or requires an extensive search). If an extension is required, we will notify you in writing of:

• the reason for the extension, and
• the extended period within which the decision will be made.

8. Fees Payable

PAIA allows a private body to charge certain fees for processing requests.

The fee structure is prescribed by the Regulations to PAIA and may be amended from time to time by the Minister. The most recent fee schedule published by the Minister and/or the Information Regulator will apply.

8.1 Request Fee (Non‑Personal Requests)

If you request access to a record that does not relate to you personally, you may be required to pay a request fee (as prescribed). The Information Officer will notify you of the applicable request fee. Processing will commence only after payment of the request fee.

8.2 Deposit

For large or complex requests, where the search and preparation of the record is likely to require more than the prescribed hours, the Company may require you to pay a deposit (up to one‑third of the estimated access fee) before processing continues.

8.3 Access Fee

If your request is granted, an access fee may be charged for:

• the time required to search for, retrieve and prepare the record;
• reproduction or copying costs (per page or per medium);
• postage or courier (if applicable).

You will be notified of the access fee before the records are provided. You may be required to pay the access fee in full prior to receiving the records.

8.4 Requests for Personal Information

If you are requesting access to records containing your own personal information, you will not be required to pay a request fee, but you may still be charged an access fee for copies, reproduction and postage.

8.5 Waiver or Reduction of Fees

In appropriate circumstances, and where provided for in PAIA or the Regulations, the Company may consider waiving or reducing the prescribed fees.

9. Availability of this Manual

• This PAIA Manual is available for inspection, free of charge, at the Company’s registered office: Omnisient (RF) (Pty) Ltd, Great Westerford, Unit SG110, 240 Main Road, Rondebosch, Cape Town, 7700, South Africa.
• A copy is also available on our Website: https://www.omnisient.com
• Copies may be obtained from the Information Regulator or, on request, from the Company. Where a copy is provided (other than for inspection at our office or via our Website), the prescribed fee (if any) may be charged.

10. Updates to this Manual

The Company may update or amend this PAIA Manual from time to time. Any material changes will be reflected in the “Last updated” date above and, where appropriate, communicated via our Website or other suitable channels.

For any questions regarding this Manual or requests for access to information, please contact the Information Officer at [email protected].