PAIA Manual for CareInvest (Pty) Ltd

PROMOTION OF ACCESS TO INFORMATION MANUAL
CareInvest (Pty) Ltd | FSP 54874

Prepared in terms of the requirements of the PROMOTION OF ACCESS TO INFORMATION ACT No. 2 of 2000
Reviewed October 2025

 

  1. INTRODUCTION

The Promotion of Access to Information Act 2 of 2000 (“PAIA” or “the Act”) gives effect to the constitutional right of access to any information held by the state and any information that is held by another person and that is required for the exercise or protection of any rights. The Protection of Personal Information Act 2013 has amended the PAIA and also requires from private bodies to disclose certain information through the relevant organisation’s PAIA Manual.

Specifically, section 51(1) of the Act, read with the Protection of Personal Information Act of 2013, requires a private body to compile a manual that must contain information as specified and required by both PAIA and POPI. In addition, the PAIA manual must set out the formal procedure that a person must follow in order to request to view, update or delete personal information held by the private body.

In this context, a “private body” is defined as any natural person who carries or has carried on any trade, business or profession, but only in such capacity or any partnership which carries or has carried on any trade, business or profession or any former or existing juristic person (e.g. any company, close corporation or business trust).

This organisation falls within the definition of a “private body” and this Manual has been compiled in accordance with the said provisions and to fulfil the requirements of the Act.

In terms of the Act, where a request for information is made to a body, there is an obligation to provide the information, except where the Act expressly provides that the information may not be released. In this context, Section 9 of the Act recognises that access to information can be limited. In general, the limitations relate to circumstances where such release would pose a threat to the protection of privacy, commercial confidentiality, and the exercising of efficient governance.

Accordingly, this manual provides a reference to the records held and the process that needs to be adopted to access such records.

All requests for access to information (other than information that is available to the public) must be addressed to the Head of the organisation named in section 2 of this Manual.

 

  1. BUSINESS AND CONTACT DETAILS

Name of Business: CareInvest (Pty) Ltd
Head of Business: Jared van Dam
Position: Director / Key Individual
Postal Address: 25 Mozart Road, 28 Alabama, Honeydew Ridge Residential Estate, Roodepoort, 2170
Physical Address: 25 Mozart Road, 28 Alabama, Honeydew Ridge Residential Estate, Roodepoort, 2170
Email Address: jared@finbofs.com
Phone Number: 083 649 4960
Website: www.finbofs.com

 

  1. SECTION 51(1) OF THE PROMOTION OF ACCESS TO INFORMATION ACT (THE ACT)

3.1 The Act grants a requester access to records of a private body, if the record is required for the exercise or protection of any rights. If a public body lodges a request, the public body must be acting in the public interest.

3.2 Requests in terms of the Act must be made in accordance with the prescribed procedures, at the rates provided. The forms and tariff are dealt with in regulations 6 and 7 of the Act.

3.3 Requesters are referred to the Guide which, in terms of Section 10 as amended, has been compiled by the Information Regulator established in terms of section 39 of the Protection of Personal Information Act, 2013, and which contains information for the purposes of exercising Constitutional Rights.

A “Request for a copy of the Guide (Form 2)” is available at: https://www.justice.gov.za/inforeg/docs2-f.html

Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
Postal Address: P.O. Box 31533, Braamfontein, Johannesburg, 2017
Tel: 010 023 5200
Email: PAIACompliance@infoRegulator.org.za

 

  1. RECORDS AVAILABLE IN TERMS OF SECTION 52(2) OF THE ACT

Not applicable.

 

  1. RECORDS THAT ARE HELD AT THE OFFICES OF THE BUSINESS

The following is a list of records that are held at the business’s office:

Administration

  • Attendance registers
  • Correspondence
  • Founding Documents
  • Licences (categories)
  • Minutes of Management Meetings
  • Shareholder Register
  • Statutory Returns

Human Resources

  • Conditions of Service
  • Employee Records
  • Employment Contracts
  • General Correspondence
  • Health and Safety information
  • Personnel Guidelines, Policies and Procedures
  • Remuneration Records and Policies
  • Skills Requirements
  • Statutory Records
  • Training Records

Operations

  • Client and Customer Registry
  • Contracts
  • Client Policy documentation
  • General Correspondence
  • Marketing Records
  • Production Records
  • Policy contracts and wordings
  • Policies required in terms of the FAIS Act
  • Sales Records
  • Suppliers’ Registry

Finances

  • Annual Financial Statements
  • Asset Register
  • Banking Records
  • Contracts
  • Financial Transactions
  • Insurance Information
  • Management Accounts
  • Tax Records (company and employee)

Information Technology

  • IT Policies and Procedures

Statutory Records

Include records held in terms of all relevant Acts, including but not limited to:

  • Basic Conditions of Employment Act, 1997
  • Companies Act, 2008
  • FAIS Act, 2002
  • FIC Act, 2001
  • Long Term Insurance Act, 1998
  • Pension Funds Act, 1956
  • Short Term Insurance Act, 1998
  • POPIA, 2013
  • and other listed legislation in your original manual.

 

  1. PROCESSING OF PERSONAL INFORMATION

Purpose of Processing

  • Fulfilling statutory obligations
  • Historical record keeping and research
  • Maintaining contractual obligations
  • Providing services to clients
  • Marketing and advertising
  • Resolving complaints
  • Staff administration
  • Verification of information

Categories of Data Subjects

  • Clients, employees, suppliers, and stakeholders

Categories of Personal Information Processed
Includes: names, addresses, ID numbers, financial data, tax info, contact details, health data (where applicable), and company registration details.

Possible Recipients of Personal Information
Auditors, regulators, insurers, banks, suppliers, service providers, and other authorised parties as required by law.

Trans-Border Flows
Personal information may be shared cross-border only where adequate protection is ensured, or with consent.

Information Security Measures
CareInvest employs reasonable technical and organisational measures to protect personal information, including:

  • Access controls
  • Data encryption
  • Secure communication channels
  • Confidentiality clauses
  • Firewalls and antivirus software
  • Regular training and audits

 

  1. INFORMATION REQUEST PROCEDURE

Requests must be made in writing using the prescribed form available at:
https://inforegulator.org.za/wp-content/uploads/2020/07/InfoRegSA-PAIA-Form02-Reg7.pdf

Send completed requests to the Head of Business listed in Section 2.

Access will be granted only if:

  • The record is required for the exercise or protection of a right;
  • The requester complies with procedural requirements; and
  • Access is not refused in terms of Chapter 4, Part 3 of the Act.

 

  1. DENIAL OF ACCESS

Access to records may be refused in limited cases, including:

  • Protection of personal information
  • Protection of trade secrets or confidential data
  • Financial or commercial harm
  • Breach of confidentiality
  • Security risks or public safety concerns
  • Privileged legal information

If access is denied, the response will include reasons and notice of the right to appeal to a court.

 

  1. FEES

Two types of fees may apply:

  • Request Fee: R50 (non-refundable) unless the request is for personal records.
  • Access Fee: Payable before access is granted, as prescribed in the PAIA Regulations.

 

  1. MANUAL AVAILABILITY

A copy of this Manual may be obtained from the Head of Business (Section 2).
Any postage or transmission costs for hard copies will be for the requester’s account.