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PAIA Manual



The Promotion of Access to Information Act No.2 of 2000 ("the Act"), gives effect to the constitutional right of access to information in records held by a private or public body, that is required for the exercise or protection of any rights.


SendSpend Holdings Pty Ltd is a private body as defined in the PAIA and will process any request made in terms thereof, except where the PAIA expressly provides that the information must not or need not to be released.

Overview of the Company


Registration Number:  2019/458818/07 

Physical address: 377 Rivonia Boulevard, Rivonia, Johannesburg, 2128, South Africa

In terms of Section 51(2) of the Act, the head of a Private Body may, on a regular basis, update this manual. Based on the provisions of this section, The Board of Directors has duly authorized this manual and is dedicated to ensuring that the requirements of the Act are administered in a fair, objective, and unbiased manner.

Details of Registered Owners


This information is recorded at the CIPC office in Pretoria.

Human Rights Commission Guideline


The South African Human Rights Commission (“SAHRC”) has compiled the guide contemplated in Section 10 of the Promotion of Access to Information Act (“PAIA”) which contains such information as may reasonably be required by a person who wishes to exercise any right contemplated in PAIA.


The Guide is available at the offices of the South African Human Rights Commission at Braampark Forum 3, 33 Hoofd Street, Braamfontein, and on its website at, e-mail address at

Postal address: Private Bag X2700, Houghton, 2041

1. Who may request for information?


In terms of section 50(1) of the PAIA any person may request information from SendSpend Holdings Pty Ltd provided that:

  • The record is required for the exercise or protection of any rights.

  •  The requestor complies with the procedural requirements as defined in the PAIA relating to a request for access to that record; and

  •  Access to the record is not refused in terms of any ground for refusal contemplated in the PAIA.

2. Categories of records held by SendSpend Holding (Pty) LTD

2.1. Personal Record​

  • Personal records provided by the employee.

  • Records a third party has provided about its employees.

  • Conditions of employment and other employee related contractual and quasi-legal records.

  • PAYE Records

  • Documents issued to employees for income tax purposes

  • Records of payments made to SARS on behalf of employees

  • All other statutory compliances

  • Employment contracts

  • Disciplinary records

  • Salary records

  • Disciplinary code

  • Leave records

2.2. Registration


  • Financial Records

  • Statutory Records

  • Asset Register

  • Sundry Agreements

  • Invoices

  • Databases

  • Information technology

  • Internal policies and procedures


2.3. Customer Related Records

Records generated by SendSpend Holdings Pty Ltd, including transactional records.

  • Banking information

  • Email addresses

  • Identity information

  • Nationalities

  • Registered names

  • Service addresses

  • Contact numbers

  • Device Information

  • Geolocation Information

3. How to Make a Request for Access?


The requester must complete the prescribed form fully and submit same together with a request fee, if applicable, to the Information Officer.


The form must:

  • Provide sufficient particulars to enable the Information Officer to identify the record/s requested and to identify the requester,

  • Indicate which form of access is required,

  • Provide full personal details and contact details of the requester,

  • Identify the right that the requester is seeking to exercise or protect,

  • Provide an explanation of why the requested record is required for the exercise or protection of that right.


If the request is made on behalf of another person, proof of the capacity in which the requester is making the request must be submitted, to the reasonable satisfaction of the Information Officer.


Where the individual is unable to complete the prescribed form due to literacy or disability, they may make an oral submission of the request.


The requester will be notified, in writing, of the decision to either grant or deny access.  


The requester must, if applicable, pay the prescribed fee, before any processing can take place.


4. Third Party Notification and Intervention


If the request is for a record pertaining to third parties, the Information Officer must take all reasonable steps to notify the relevant third party of the request.  This must be done within 21 days of receipt of the request.  The third party may within 21 days thereafter either make representation as to why the request should be refused or grant written consent to the disclosure of the record.

5. Decision on Request and Notice Thereof


In terms of section 56 of the PAIA, the Private Body will notify the requester as soon as is reasonably possible, within 30 days of receipt of the correctly completed request, of the decision as to whether or not to grant the request.

The 30-day period within which the Information Officer has to decide whether to grant or refuse the request, may be extended for a further period of not more than 30 days if the request is made for a large amount of information or the request requires a search of information, and the information cannot reasonably be obtained within the original 30-day period.

6. Refusal of Access to Records According to Chapter 4 of the PAIA

The main grounds of refusal of a request for information relates to:

  • Mandatory protection of the privacy of a third party who is a natural/juristic, which would involve the unreasonable disclosure of personal information.

  • Mandatory protection of the safety of individuals and the protection of property.

  • Mandatory protection of records which would be regarded as privileged in legal proceedings.

  • Mandatory protection of confidential information of third parties, if it is protection in terms of any agreement.

  • Mandatory protection of a third party and of SendSpend Holdings Pty Ltd which may include: Trade secrets, Financial, commercial, scientific, or technical information.


Information which, if disclosed could cause a disadvantage in negotiations or commercial competition.

Computer programs and related information technology software used.

7. Remedies Available when a Request is Refused

A requestor that is dissatisfied with the Information Officer’s refusal to grant access to any information may within 30 days of notification of the decision, apply to court for relief.

8. Fees

Fees provided by the PAIA:

  • A request fee, which will be a standard fee

  • An access fee, which must be calculated by considering the reproduction costs, search and preparation time cost and postal costs.


When the request is received by the Information Officer, the requester will be required to pay the prescribed request fee, (if any) before the processing of the request.


The Information Officer shall withhold a record until the requester has paid the fees.


A requester whose request for access to a record has been granted, must pay an access fee for reproduction and for search and preparation, and for any time reasonably required in excess of the prescribed hours to search for and prepare the record for disclosure including making arrangements to make it available in the request form.

9. Availability of the Manual

Copies of this manual, prescribed forms and fees payable can be obtained from the office of SendSpend Holdings Pty Ltd.


Information Officer details

Head of Compliants

Physical Address: 377 Rivonia Boulevard, Rivonia, Johannesburg, 2128, South Africa



The following documents are included with this manual:


  • Fees in Respect of Private Bodies

  • Request for Access to Records of a Private Body

Table of Fees in respect of Private Bodies

Prescribed Form to be Completed by a Requestor

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