PAIA manual
South African statuteWhat records Wingman holds, how to ask us for access to them, what that costs, and what you can do if we say no.
Your right of access
PAIA gives effect to the constitutional right of access to information held by another person, where that information is required to exercise or protect a right. This manual is Wingman’s statutory response to that right: a public statement of what records we hold, how to request access to them, and who to contact.
The manual also reflects the Company’s obligations under the Protection of Personal Information Act 4 of 2013 (POPIA), which amended PAIA and is administered by the same regulator. How we handle personal information day to day is set out in our privacy policy.
Wingman and the Information Officer
Private body: Wingman (Pty) Ltd, Registration No. 2026/491842/07
Information Officer: Luke Tollman
- Email: privacy@onwingman.com
- Registered address: 222 Bowling Avenue, Woodmead, Johannesburg, 2191
- Postal and physical address: 2 Sunbird Lane, Sandton Country Club Estate, Bowling Avenue, Woodmead, Johannesburg, 2191
The head of the Company is the Information Officer for PAIA and POPIA purposes. No Deputy Information Officer is currently designated.
Categories of records we hold
The manual lists categories of records. Listing a category does not mean access to a particular record will be granted: the grounds for refusal below still apply.
- Corporate and statutory: MOI, registers, minutes, resolutions.
- Financial and tax: management accounts, annual financial statements, banking, invoices, SARS, PAYE and VAT records.
- Employee and HR: employment agreements, payroll and leave records, disciplinary and grievance records, employee personal information.
- Candidate: platform registrations, candidate profiles and CVs, candidate personal information, placement records.
- Client and supplier: contracts, correspondence, invoices, service records.
- Marketing: prospect and lead lists, campaign and communication records.
- Policies and compliance: Company policies, POPIA and PAIA records, contracts and templates.
- IT and systems: system, access and security records.
Some information is available without a PAIA request, for example our website content and marketing material. Other records may be accessible under separate legislation: the Companies Act, Tax Administration Act, BCEA, LRA, POPIA and VAT Act.
How to request access
Use Form 2: Request for Access to Record of Private Body (Regulation 7 of the PAIA Regulations). Send it to the Information Officer at the address or email above.
The request must:
- Give enough detail to identify the record and the requester.
- Identify the right you are seeking to exercise or protect, and explain why the record is required.
- State the form of access you need, and how you wish to be notified of the decision.
- Include proof of identity, and proof of authority to act where the request is made on someone else’s behalf.
The Information Officer decides the request within 30 days, extendable by a further 30 days in the circumstances PAIA allows. You are told of the decision and, where access is granted, of any access fee payable and the form the access will take.
Fees
Two types of fee can apply, as prescribed in Annexure B to the PAIA Regulations (GN R.757 of 27 August 2021).
| Fee | When it applies | Amount |
|---|---|---|
| Request fee | Payable before the request is processed. | R140.00 |
| Access fee | Payable where access is granted, for reproducing the record and for any search and preparation time beyond the prescribed hours. | On calculation |
| Deposit | Where search and preparation are likely to exceed the prescribed hours. Refunded if the request is refused. | Up to one third of the access fee |
The Company may require the request fee or deposit to be paid up front, and may withhold a record until fees are paid.
Grounds for refusal
Access may be refused on the grounds in Chapter 4 of Part 3 of PAIA, including mandatory protection of:
- A third party’s privacy, where that party is a natural person.
- Commercial information of a third party, or of the Company.
- Information held in confidence, and information that is legally privileged.
- The safety of individuals, and the protection of property.
- Third-party or Company research information.
Public-interest override. Access will be granted despite a ground for refusal where disclosure would reveal a substantial contravention of the law, or an imminent and serious risk to public safety or the environment, and the public interest in disclosure clearly outweighs the harm.
The Regulator and the courts
PAIA does not provide for an internal appeal against a private body’s decision. If the Company refuses a request, fails to respond, or you are dissatisfied with a fee or a decision, your remedies are:
- Lodge a complaint with the Information Regulator on Form 5, ordinarily within 180 days, through the eServices Portal at eservices.inforegulator.org.za.
- Apply to a court for appropriate relief within 180 days of being notified of the decision.
Information Regulator (South Africa): JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001 · Tel 010 023 5200 · enquiries@inforegulator.org.za · inforegulator.org.za
Availability and updates
The manual is available free of charge:
- On this website.
- For public inspection at the Company’s principal place of business during normal business hours.
- On request to the Information Officer.
The Company updates the manual regularly, and whenever there is a material change to its particulars, the records it holds, or the applicable law.
The full manual
The complete manual, in the prescribed form, is available as a PDF.
Talk to our Information Officer
Information Officer: Luke Tollman, privacy@onwingman.com
Post: Wingman (Pty) Ltd, 222 Bowling Avenue, Woodmead, Johannesburg, 2191, South Africa