- 021 852 7692
- info@thelabcc.co.za
PREPARED IN TERMS OF SECTION 51 OF THE PROMOTION OF ACCESS TO INFORMATION ACT 2 OF 2000
(Registration number: 2017/414035/07)
Principal place of business: 8 Garvin Circle, Gants Plaza, Unit 2, Strand, Western Cape.
(Hereinafter referred to as “the Company” / “the Private Body”)
Date of compilation: 12/02/2026
Date of last revision: 12/02/2026
Version number: 1
CONTENTS
In this Manual, unless the context otherwise requires:
This Manual has been compiled in accordance with section 51 (1) of the Act and sets out the information as required of a private body.
The purpose of the Act is to give effect to the constitutional right of access to information held by a private body that is required for the exercise or protection of any rights, subject to justifiable limitations (section 1 of PAIA).
The Company is committed to transparency while balancing its rights to confidentiality, commercial protection and personal privacy.
This Manual also integrates required information in respect of the processing of personal information under POPIA.
The Company is a private body as defined in PAIA (section 1). Accordingly, the provisions applicable to private bodies in chapter 4 of PAIA apply.
This Manual is available for inspection at the Company’s principal place of business and on the Company’s website (during normal business hours (see section 51 (3) of PAIA).
Head of the Private Body:
Name: Stefan Ras
Designation: Director
Email address: stefan@thelabcc.co.za
Information Officer:
Name: Stefan Ras
Designation: Director
Email address: stefan@thelabcc.co.za
The Information Officer is authorized to receive and process requests under PAIA, to assist requesters, to decide on access to records and to correspond with requesters on behalf of the Company.
The Company may designate one or more Deputy Information Officers in terms of section 56 of POPIA.
In terms of section 10 (1) of the Act, the Information Regulator has prepared a Guide on how to use PAIA (“the Guide”).
The Guide:
The Guide is available free of charge in hard copy format at the Information Regulator’s offices and in electronic form on the Regulator’s website: https://www.justice.gov.za/inforeg/ or https://www.inforegulator.org.za.
The Guide is also available from the Information Officer of the Company on request (contact details above).
No notice has been published by the Company in terms of section 52 (2) available at the date of this Manual.
In terms of section 51(1)(d) of PAIA, the Manual must contain a description of the records of the Company which are available in terms of any legislation other than PAIA, with sufficient detail to enable a requester to decide whether to request those records.
For example:
In terms of section 51(1)(e) of the Act the Manual must contain a description of the subjects on which the Company holds records, and the categories of records held on each subject, in sufficient detail to enable a requester to decide whether to request access to a record.
Below is such list of subjects and categories.
Corporate and company records
Contracts and procurement
Finance and accounting
Human resources / employee records
Marketing, sales and customer relations
Legal, governance and compliance
Operations, health & safety and environmental
Information technology and communications
Customer / client service records
For each subject listed above, the Company holds records “regardless of form or medium” (see section 3 of PAIA).
A requester’s access will be subject to the right to access under section 50 of PAIA and the grounds for refusal in sections 62, 69 and 70 of PAIA.
The procedure to request access to a record of the Company is as follows (section 50 of PAIA):
8.1 A requester must complete the prescribed Form 2 (Request for access to record of private body) as set out in the Regulations (Regulation 6 and 7) and pay the prescribed request fee (section 54 of PAIA).
If a requester is unable to complete the prescribed form due to illiteracy or disability, the Company will accept an oral request and will assist the requester to complete the prescribed form.
8.2 The request must be submitted to the Information Officer via email (email address provided above) and must specify:
8.3 The Information Officer will consider the request and within 30 calendar days of receipt of the request (or such extended period as permitted under section 50 (2) and the Regulations) will notify the requester of the decision whether access is granted or refused; if access is refused wholly or partly, the notice will comply with section 50 (3) and (4) of PAIA and the Regulations.
The Company will, where applicable, communicate the outcome of a request using the prescribed Form 3 (Outcome of request).
8.4 If access is granted, the Company may recover access fees as permitted in section 54 of PAIA and the Regulations.
8.5 If the requester is not satisfied with the decision, the requester may lodge an internal appeal or apply to a court for relief as provided in sections 78 and 80 of PAIA.
The requester may also lodge a complaint with the Information Regulator in terms of PAIA and POPIA, as applicable.
8.6 Assistance may be requested from the Information Officer to obtain access (section 10 of PAIA).
8.7 The Company’s Internal PAIA Request Procedure is attached to the manual as Annexure “A”.
In terms of section 54 of the Act, the Company may recover from a requester the prescribed request fee and access fees as set out in the Regulations (see Regulations 11 and 12).
The Company’s fee schedule:
Request fee: R140.00 (payable on submission of Form 2).
Access fees: (copying, inspection, transcribing, electronic copy etc.):
The requester may apply to court for exemption or reduction of fees.
The Company retains the right to refuse to produce the record until the requester has paid the fees in full,
In terms of Regulation 2 and 3 of the POPIA Regulations and the obligations under POPIA, the Company sets out the following:
10.1 Purpose of processing personal information: employees, customers, suppliers, marketing, compliance, etc.
10.2 Categories of data subjects and the personal information processed:
10.3 Recipients or categories of recipients to whom personal information may be supplied: auditors, insurers, regulatory authorities, service providers, subsidiaries, etc.
10.4 Security measures to protect the integrity, confidentiality and availability of the information may include: physical access controls, locked filing cabinets, encryption of electronic records, firewalls, backups, access logs, user authentication, policy requiring periodic review, and staff training.
10.5 The Company does not currently transfer personal information outside the Republic of South Africa.
In terms of section 51 (3) of PAIA, this Manual is available:
In terms of section 51 (2) of PAIA, the Company shall update this Manual whenever there is a change to the information contained herein. The Company commits to reviewing this Manual at least annually or sooner if required by changes in legislation, business operations or structure. The version number and date of last revision appear at the beginning of this Manual.
The Company records will provide any additional information required by the PAIA.
The Company also confirms that it will provide reasonable assistance to requesters including helping to interpret and complete forms (section 10 (2) of PAIA). The Company will treat requests with due care, and maintain confidentiality and security of records except as required to be disclosed under the Act.
Approval:
Signed by the Head of the Private Body:
Name: Stefan Ras
Designation: Director
Date: 12/02/2026
(Registration Number: 2017/414035/07)
This procedure sets out how The Lab will receive, record, process, decide upon and communicate responses to requests for access to records under the Promotion of Access to Information Act No. 2 of 2000 (“PAIA”) (in respect of records held by such The Lab ).
It is intended to ensure compliance with all relevant provisions of the PAIA and the Regulations published pursuant thereto (“the Regulations”).
This procedure applies to all requests for access to records of The Lab made by any person (natural or juristic) under section 50 of PAIA.
2.1 “Act” means the Promotion of Access to Information Act, No. 2 of 2000.
2.2 “Requester” means the person (natural or juristic) who makes a request for access to a record of The Lab.
2.3 “Record” means any recorded information held by or under the control of the The Lab, regardless of form or medium, whether created by the The Lab or another, as defined in PAIA.
2.4 “Information Officer” means the person appointed by the The Lab in terms of PAIA to receive and process requests for access.
2.5 “Head” means the head of the The Lab (or the person designated for purposes of PAIA).
2.6 “Form 2” (or “Prescribed Form”) means the form prescribed for a request for access to a record of a Private Body in terms of section 53 of PAIA and the Regulations.
2.7 “Request fee” or “Access fee” have the meanings given in the Regulations under PAIA (including the request fee payable by nonperson requesters and the access fee for search, preparation, reproduction etc.).
3.1 The Lab will make Form 2 available on its website under the PAIA link or will make it available at its head office / registered address for collection or download.
3.2 The Lab will also inform requesters that a copy of the Form 2 may be obtained from the Information Regulator via its website (www.inforegulator.org.za) or by contacting the Information Officer of The Lab.
3.3 If a requester is unable to complete the form (for example due to illiteracy or disability) The Lab will accept an oral request and will assist the requester in completing the form.
3.4 The Lab will keep a supply of printed copies of Form 2 at its head office and at the Information Officer’s office for inspection or collection.
4.1 A requester must complete Form 2 (or other acceptable request template if authorised by the Information Officer) and submit it to The Lab via email to the Information Officer.
4.2 The request must contain sufficient particulars to enable the Head / Information Officer to identify:
4.2.1 The record or records requested;
4.2.2 The requester (and if acting on behalf of another person, proof of the requester’s capacity to act);
4.2.3 The form of access required (inspection, copy, electronic copy, etc.);
4.2.4 The postal address or email address in South Africa at which the requester chooses to be contacted;
4.2.5 Which right the requester is seeking to exercise or protect and an explanation of why the record is required for the exercise or protection of that right.
4.3 If the request is made on behalf of another person, the requester must submit proof of the capacity in which the requester is making the request to the reasonable satisfaction of the Head / Information Officer.
4.4 The Lab will date stamp (or electronically record) the date of receipt of the request and log it in its central PAIA requests register (see paragraph 5 below).
4.5 The Lab may issue an acknowledgement of receipt to the requester, indicating that the request has been received, the date of receipt, and the request reference number in the PAIA register.
5.1 The Information Officer shall maintain a PAIA requests register.
5.2 Each request must be assigned a unique reference number and the following minimum information recorded:
5.2.1 Request reference number;
5.2.2 Date of receipt;
5.2.3 Name and contact details of requester;
5.2.4 Description of record(s) requested;
5.2.5 Whether request fee is required / paid;
5.2.6 Status of processing (e.g., under review, decision made, access granted/denied);
5.2.7 Date of decision;
5.2.8 Date of delivery of records (if applicable);
5.2.9 Any outstanding action (e.g., deposit required, clarification requested).
5.3 The register must be regularly updated so that the Head/ Information Officer can monitor compliance with the statutory time limits for decision-making (see paragraph 7 below).
5.4 The Lab shall ensure that all documentation relating to the request (including the request form, any correspondence, and proof of payment of fees/deposits, the decision, and any records released) is filed and retained in accordance with a recordkeeping policy and in a manner that preserves confidentiality and security.
5.5 If multiple parts of a request are handled separately (for example, where different business units hold different records) the Information Officer will coordinate and ensure a consolidated decision is made within the prescribed period.
6.1 If the request is for access to a record of the requester (personal requester), the requester is exempt from paying the request fee (but may still have to pay access fees).
6.2 For non-personal requesters, The Lab shall require the payment of the prescribed request fee before further processing of the request. The Lab will issue a notice to the requester informing of the fee amount and how to pay prior to processing.
6.3 If the search, preparation and reproduction of the record will exceed the prescribed number of hours (six hours under the Regulations) The Lab may require a deposit (up to one-third of the estimated access fee).
6.4 The Lab may withhold access to the record until all required fees/ deposits are paid.
6.5 If the requester contests the requirement to pay a fee or deposit, the requester may apply to a competent court for relief.
7.1 The Information Officer (or delegate) will consider the request and determine whether:
7.1.1 The Lab holds the record;
7.1.2 The requester has complied with the procedural requirements set out in this procedure and in the Act; and
7.1.3 The record is required for the exercise or protection of a right and the requester has provided sufficient explanation.
7.2 Where necessary, the Information Officer may request clarification from the requester (for example, to narrow the scope of the record requested, or to specify the form of access) or require the requester to pay the request fee or deposit. Such clarification or fee request must be obtained promptly to avoid unnecessary delay.
7.3 Within a maximum of 30 calendar days from the date the request is received (or from date of receipt of payment of any required request fee or other conditions) the Head must decide whether to grant or refuse access to all or part of the record.
7.4 The decision must be recorded in writing (which includes email) and must include:
7.4.1 Whether access is granted or refused;
7.4.2 If granted, the form in which access will be given and any conditions (including payment of access fee, method of delivery, etc.);
7.4.3 If refused (or partially refused), the reasons for the refusal, including the relevant ground(s) for refusal under Chapter 4 of PAIA and information on the requester’s right to lodge an internal appeal court application and where relevant the contact details of the Information Regulator.
7.5 If access is granted, The Lab will take reasonable steps to provide the requested record in the form requested (if reasonable and available) and within the time-frame agreed or required by the Act.
7.6 If access is refused wholly or partly, The Lab will notify the requester of the decision, grounds for refusal
7.7 The Lab does not hold the record, the Information Officer will, if known; inform the requester of the body that does hold it (if any) and whether the request is being transferred.
8.1 Once all fees (request fee, deposit if applicable, and access fees) have been paid, The Lab will arrange delivery of the record in the form requested (subject to availability).
8.2 Forms of access may include: inspection of a record, copy in printed form, copy in electronic form (flash drive, email), transcription of audio/visual recordings, etc.
8.3 The Lab will notify the requester of the time, place and manner of delivery or inspection.
8.4 If inspection of the record is chosen, appointment will be arranged.
8.5 The Lab will provide the requester with an invoice or statement of fees paid and any outstanding fees (if applicable) before releasing the record.
8.6 The Lab will retain a record of the fact of access (who accessed, when, what record, in what form) in its log file in the register.
8.7 If the requester fails to collect or inspect the record within a reasonable period after being notified, The Lab may inform the requester that the request will be closed unless the requester indicates otherwise.
9.1 The Lab may refuse access (in whole or part) where one or more of the statutory grounds for refusal under Chapter 4 of PAIA apply. These include, inter alia:
9.1.1 Mandatory protection of the privacy of a third party (i.e., a natural person other than the requester) where disclosure would involve unreasonable disclosure of personal information;
9.1.2 Mandatory protection of safety of individuals/property; protection of privileged records; etc.
9.1.3 Discretionary grounds: trade secrets of The Lab; commercial information, research information of a third party/ The Lab, etc.
9.2 If refusal is based on a discretionary ground, The Lab must still consider whether the public interest in disclosure outweighs the harm.
9.3 The notice of refusal must clearly state the ground(s) relied upon and the requester’s right to court review.
9.4 If access is refused in part, The Lab will indicate which parts of the record are refused and provide access to the remainder, if any, and deliver or make available the accessible portions.
10.1 The Lab will ensure that records released are done so in a secure manner and that confidentiality of other persons’ data is preserved (particularly where records contain personal information relating to third parties).
10.2 The Lab’s internal register will record all requests, decisions, fees paid, records released or refused, and dates of release, etc., for audit and compliance purposes.
10.3 The Lab will ensure that staff involved in processing PAIA requests is trained and aware of relevant obligations (including time-limits, fees, forms, grounds for refusal, appeal rights).
10.4 The Lab will review this procedure and the PAIA Manual on a regular basis (at least annually) to ensure compliance with changes in the law and regulations.
Annexure – Sample wording for decision notice
Dear [Requester’s Name],
Reference: PAIA Request No. [INSERT]
Date of receipt: [INSERT]
We refer to your request dated [INSERT] made under the Promotion of Access to Information Act, 2000 (“PAIA”) for access to the following record(s): [describe].
Decision:
We have decided to grant / refuse your request for access to the record(s) described above.
If granted:
Access will be given in the form of [inspection / copy / electronic copy] at [place/manner] on [date].
Before release, you are required to pay the access fee of [R xxx] (invoice attached)/ or you have paid the access fee/ no access fee is payable (personal requester).
If refused or partially refused:
The reasons for refusal are as follows: [list grounds from Chapter 4 of PAIA e.g. section 63 trade secret; section 64 commercial information leading to harm; section 66 personal information third party; etc.].
You have the right to approach a court for relief or to lodge a complaint with the Information Regulator.
Thank you for your request.
Yours faithfully,
[Name]
The Lab – Information Officer
[Contact details]
All of the above must be read in conjunction with the General Terms and Conditions of The Lab Chemicals and Coatings (Pty) Ltd and The Lab George (Pty) Ltd which can be found at www.thelabcc.co.za or is available on request.
