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PAIA manual

Manual prepared in terms of section 51 of the Promotion of Access to Information Act, 2 of 2000, for TNT Telecoms.

Last updated: 2026-10-31

1. Introduction

The Promotion of Access to Information Act (PAIA) gives effect to the constitutional right of access to information held by private bodies, where that information is required to exercise or protect a right. This manual explains what records TNT Telecoms CC holds, how to request them, and — as required by section 51(1)(c) of PAIA, read with the Protection of Personal Information Act (POPIA) — how we process personal information.

2. Contact details (section 51(1)(a))

Private body
TNT Telecoms CC, trading as TNT Telecoms
Head of the private body
Tom Percy
Information officer
Tom Percy — tom@tnttelecoms.com
Telephone
+27 72 287 4554
Physical address
Provided on request to the information officer.
Postal address
Provided on request to the information officer.

3. The Information Regulator’s guide (section 51(1)(b))

The Information Regulator has published a guide, in terms of section 10 of PAIA, on how to use the Act. It is available in all official languages from the Regulator:

Information Regulator (South Africa)
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
P.O. Box 31533, Braamfontein, Johannesburg, 2017
inforegulator.org.za · inforeg@justice.gov.za

4. Records available without a request (section 51(1)(d))

No notice has been published in terms of section 52(2). The following are, however, available to anyone on this website: our service descriptions, service areas, this manual, the privacy notice and the website terms of use.

5. Records held in terms of other legislation (section 51(1)(e))

Where applicable, we hold records required by: the Close Corporations Act / Companies Act (registration and statutory records); the Income Tax Act, Value-Added Tax Act and Tax Administration Act (financial and tax records); the Basic Conditions of Employment Act, Labour Relations Act, Unemployment Insurance Act and Compensation for Occupational Injuries and Diseases Act (employment records); the Private Security Industry Regulation Act (registration records); the Consumer Protection Act; the Electronic Communications and Transactions Act; and POPIA.

6. Subjects and categories of records held (section 51(1)(f))

SubjectCategories of records
Customers and enquirersQuote requests and enquiries, site survey notes, quotations, service agreements, installation and handover documentation, invoices, correspondence, maintenance records.
Suppliers and contractorsSupplier agreements, invoices, warranty records, correspondence.
PersonnelEmployment contracts, payroll, leave, training and registration records.
Company and financialStatutory records, bank records, tax returns, accounting records, insurance.
Website and ITEnquiry database, web-server access logs, email, domain and hosting records.

Listing a category does not mean a record in it will be released. Each request is assessed under the Act, including the grounds for refusal in Chapter 4 of Part 3 (for example, the protection of another person’s privacy or of commercial information).

7. Processing of personal information (section 51(1)(c), POPIA)

Purpose of processing

To respond to enquiries and quote for work; to survey, install, maintain and support systems for customers; to manage supplier and contractor relationships; to employ staff; to meet legal and tax obligations; and to protect the website from automated abuse.

Categories of data subjects and of personal information

  • Enquirers and customers — name, company, contact details, site address and suburb, property type, details of the systems required or installed, correspondence, and (for customers) billing information.
  • Website visitors — a salted hash of the IP address stored with each enquiry, and the browser user agent. Raw IP addresses appear only in web-server access logs, kept for up to 30 days.
  • Suppliers and contractors — business and contact details, banking details for payment, registration numbers.
  • Employees — identity, contact, banking, tax, employment and registration details.

Recipients of personal information

Operators acting on our instructions: our email service provider (Google Workspace), which delivers enquiry notifications; our hosting provider (Oracle Cloud, Johannesburg region) on whose servers the website and enquiry database run; and, where you choose to contact us that way, WhatsApp (Meta Platforms), which processes messages under its own terms. Equipment manufacturers and suppliers receive only what a warranty claim needs. Professional advisers and public authorities receive information where the law requires it. We do not sell or share personal information for marketing.

Planned transborder flows

The website and enquiry database are hosted in South Africa. Email delivered through Google Workspace may be stored on Google’s infrastructure outside South Africa, and WhatsApp messages are processed by Meta outside South Africa. Both providers are subject to binding privacy rules that give substantially similar protection to POPIA, as section 72(1)(a) of the Act requires.

General description of security measures

The website is served only over HTTPS. The enquiry database is held on a server in South Africa that is reachable only through a reverse proxy, with the application bound to the local machine and the database file readable only by the service account. Visitor IP addresses are stored as one-way hashes. Submissions are validated and rate-limited to limit automated abuse. Administrative access is by SSH key. Email access is protected by two-factor authentication. Enquiry records are deleted after 24 months unless they relate to work carried out.

8. How to request access to a record

  1. Complete Form 2 (Request for Access to Record of Private Body), prescribed in the PAIA Regulations, 2021, available from the Regulator’s website or from our information officer.
  2. Provide enough detail for us to identify the record, state the form of access you want, and explain which right you need the record to exercise or protect. If you are acting for someone else, provide proof of your authority.
  3. Send the completed form to the information officer at tom@tnttelecoms.com. Pay the prescribed request fee (R100 for a private body) when asked. A fee for search, preparation and copying may also be charged at the rates in Annexure B of the Regulations, and a deposit may be requested where that work will take more than six hours.
  4. We will decide on the request within 30 days of receiving it, and may extend that by up to a further 30 days where the Act allows. You will be told in writing whether access is granted and, if it is refused, the reasons and your remedies.

Requests for your own personal information are free of the request fee. If you are unhappy with our decision you may apply to a court, or lodge a complaint with the Information Regulator using the prescribed complaint form.

9. Your rights under POPIA

Separately from PAIA, you may ask us to confirm whether we hold personal information about you and to provide it; ask us to correct or delete it (Form 2 under the POPIA Regulations); object to processing (Form 1); and withdraw consent. Send any of these to the information officer. The privacy notice explains how we use personal information in more detail.

10. Availability of this manual

This manual is published on this website and is available on request from the information officer. It will be updated whenever the information in it changes.