ACQUMIN

PAIA and POPIA Manual

The Acqumin Group (Pty) Ltd

Version 1.0 | Effective date: 8 June 2026 | Review date: 8 June 2027

1. Introduction and purpose

This document is the PAIA and POPIA Manual of The Acqumin Group (Pty) Ltd ("Acqumin", "we", "us" or "our") and is compiled in accordance with:

  • section 51 of the Promotion of Access to Information Act 2 of 2000, as amended ("PAIA"); and
  • the Protection of Personal Information Act 4 of 2013 ("POPIA"), including section 17 thereof.

The purpose of this Manual is to:

  • give effect to the constitutional right of access to information as provided for in section 32 of the Constitution of the Republic of South Africa, 1996;
  • explain the categories of records held by The Acqumin Group (Pty) Ltd;
  • describe how a requester may lawfully request access to such records; and
  • provide a high-level overview of how The Acqumin Group (Pty) Ltd processes personal information in terms of POPIA.

2. Company details

Name of private body: The Acqumin Group (Pty) Ltd
Registration number: 2025/544488/07
Registered office: 5 Heemskerk Avenue, Eastleigh Ridge, Edenvale, Johannesburg, 1609, South Africa
Telephone: +27 71 567 6502
Email: team@acqumin.com
Website: https://www.acqumin.com

3. Information Officer

The Information Officer is responsible for the promotion and protection of access to information held by The Acqumin Group (Pty) Ltd in terms of PAIA and POPIA.

Name: Phillip Mangiza
Position: Information Officer
Email: team@acqumin.com
Telephone: +27 71 567 6502
Postal / physical address: 5 Heemskerk Avenue, Eastleigh Ridge, Edenvale, Johannesburg, 1609, South Africa

If Deputy Information Officers are appointed in future, their names, roles and contact details will be added to this Manual and the Information Regulator will be notified accordingly.

4. PAIA Guide (section 10 reference)

The Information Regulator has compiled a Guide in terms of section 10 of PAIA to assist persons who wish to exercise any right under PAIA or POPIA. The Guide contains information about the operation of PAIA, including how to make requests and what remedies are available.

The current PAIA Guide is available on the Information Regulator's website at: https://inforegulator.org.za/

All PAIA prescribed forms, including the request form, are available at: https://inforegulator.org.za/paia-forms/

5. Records automatically available without a formal PAIA request

The following categories of records are generally available without a formal PAIA request and may be accessed through our website at https://www.acqumin.com or on request to the Information Officer:

  • General website content and information about our services
  • Marketing, thought-leadership and informational content published on the website
  • Privacy Policy
  • Cookie Policy
  • Terms of Use
  • This PAIA and POPIA Manual
  • Job advertisements and recruitment-related public notices (where applicable)

We reserve the right to review and update this list at any time.

6. Records held in terms of other legislation

Where applicable, The Acqumin Group (Pty) Ltd may hold records in terms of, or be subject to, the following legislation:

  • Companies Act 71 of 2008
  • Income Tax Act 58 of 1962 and related South African Revenue Service legislation
  • Value-Added Tax Act 89 of 1991
  • Basic Conditions of Employment Act 75 of 1997
  • Labour Relations Act 66 of 1995
  • Skills Development Act 97 of 1998
  • Electronic Communications and Transactions Act 25 of 2002
  • Consumer Protection Act 68 of 2008
  • Protection of Personal Information Act 4 of 2013
  • Promotion of Access to Information Act 2 of 2000

The availability of records held under specific legislation is subject to the provisions and permissible grounds for access or refusal under those laws.

7. Categories of records held

The Acqumin Group (Pty) Ltd holds, or may hold, records in the following broad subject categories. Not all of these records are automatically available, and access to them remains subject to PAIA's provisions.

7.1 Corporate and governance records

Certificate of incorporation, Memorandum of Incorporation (MOI) and CIPC filings; directors' resolutions and minutes; share registers and ownership records.

7.2 Finance, tax and billing records

Financial statements and management accounts; invoices, purchase orders and payment records; tax records, VAT returns and SARS correspondence; banking records.

7.3 Client and project records

Client proposals, scopes of work and statements of work; client contracts and service agreements; project documentation, deliverables and meeting records; client correspondence.

7.4 Human resources and employment records

Employment contracts and personnel files; remuneration and payroll records; leave, disciplinary and performance records; training and skills development records; candidate and recruitment records.

7.5 Marketing, CRM and website records

Marketing contact databases and campaign records; website analytics and usage data; consent and opt-in records; social media and digital advertising records.

7.6 IT and information security records

System access logs and security records; software licences and vendor agreements; IT policies and security incident records.

7.7 Legal, compliance and regulatory records

Contracts, NDAs and legal correspondence; regulatory correspondence including PAIA, POPIA and Information Regulator records; insurance policies and related documentation.

8. PAIA request procedure

8.1 Who may request access

Any person, whether or not a South African citizen, may request access to records of The Acqumin Group (Pty) Ltd in terms of PAIA, provided that the requester is able to demonstrate that the record is required for the exercise or protection of a right.

8.2 How to submit a request

Requests for access must be made in writing on the prescribed Form 02: Request for Access to Record of a Private Body, available from the Information Regulator's PAIA Forms page at: https://inforegulator.org.za/paia-forms/

Completed requests should be addressed to the Information Officer and submitted by:

  • Email: team@acqumin.com (subject line: "PAIA Request – The Acqumin Group (Pty) Ltd")
  • Post or hand delivery: Information Officer, The Acqumin Group (Pty) Ltd, 5 Heemskerk Avenue, Eastleigh Ridge, Edenvale, Johannesburg, 1609, South Africa

8.3 Information to include

A request should include: full name and contact details of the requester; proof of identity; a description of the record(s) requested; the preferred form of access; a statement of the right the requester wishes to exercise or protect; and an explanation of why the requested record is necessary.

8.4 Request and access fees

A request fee and/or access fee may be charged as prescribed in the PAIA Regulations. The Information Officer will notify the requester of applicable fees before processing. Certain requesters may be exempt from fees.

8.5 Response timeframe

The Information Officer will respond to a valid request within 30 days of receipt, unless an extension is permitted and granted in terms of PAIA.

8.6 Grounds for refusal

Access may be refused on grounds permitted by PAIA, including protection of third-party personal information, commercially sensitive information, legally privileged information, or other grounds as provided for in PAIA.

8.7 Internal remedies and appeals

If a request is refused, the requester will be notified in writing with reasons. The requester may then seek internal remedy or approach the Information Regulator or a court, as provided for in PAIA.

9. POPIA information (section 17)

9.1 Purposes of processing

We process personal information for purposes including: providing and improving services to clients; communicating with clients, prospective clients and business contacts; operating and maintaining our website and digital platforms; marketing, CRM, campaign analytics and advertising; HR and employment administration; financial management and record-keeping; and legal, audit, risk and regulatory compliance.

9.2 Categories of data subjects

Clients and prospective clients; website visitors and marketing contacts; employees and candidates; suppliers and service providers; business partners and other stakeholders.

9.3 Categories of personal information processed

Identification and contact details (name, email, phone number, address); professional and business details; engagement and billing information; technical and usage data (IP address, browser type, analytics data); marketing and communications data (email engagement, consent records); HR and employment data.

Special personal information is only processed where lawful, necessary and consistent with POPIA.

9.4 Categories of recipients

Clients and counterparties in service engagements; IT, hosting, CRM and marketing platform providers (including Google Analytics, Meta Pixel, HubSpot, Brevo, Google Ads, Facebook, LinkedIn); professional advisers (legal, tax, accounting); regulators and public bodies where required by law; successor entities in the event of a corporate restructuring.

9.5 Planned transborder flows

Certain cloud-based service providers may process or store personal information outside South Africa. Where such transfers occur, we take reasonable steps to ensure that the recipient provides an adequate level of protection, in accordance with section 72 of POPIA.

9.6 Information security measures

Acqumin implements reasonable technical and organisational security measures including: role-based access controls and user authentication; contractual confidentiality obligations with service providers; regular review of access rights and data handling procedures; security monitoring and incident response procedures; and data retention and disposal policies.

10. Availability of this Manual

This PAIA and POPIA Manual is available: on the Acqumin website at https://www.acqumin.com; for inspection at the registered office during normal business hours; and from the Information Officer on written request. It will also be made available to the Information Regulator upon request.

11. Updates to this Manual

This Manual will be reviewed at least annually, or sooner where there are material changes to The Acqumin Group (Pty) Ltd's structure, records, processing activities, applicable legislation or Information Regulator guidance. The version number, effective date and review date will be updated accordingly.

Annexure A – Useful contacts and forms

Information Regulator (South Africa): https://inforegulator.org.za/
PAIA Forms (all prescribed forms): https://inforegulator.org.za/paia-forms/
PAIA Guide: Available via https://inforegulator.org.za/