PAIA Manual – INUKA
Prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 (as amended)
| Version Number | Version Date |
| 2.2 | July 2025 |
Introduction
This Manual has been prepared in accordance with section 51 of the Act and aims to facilitate a Request for access to a Record held by a private body that is required for the exercise or protection of any rights.
Definitions
Unless the context clearly indicates otherwise, the following terms shall have the meanings assigned to them hereunder, namely:
- “Act” or “PAIA” means the Promotion of Access to Information Act 2 of 2000, and any Regulations published thereunder, as amended from time to time;
- “Company” means INUKA as more fully described in the overview hereunder;
- “Information Officer” means the person acting on behalf of the Company and discharging the duties and responsibilities assigned to the head of the Company by the Act. The Information Officer is duly authorised to act as such, and such authorisation has been confirmed by the “head” of the Company in writing;
- “Deputy Information Officer” means a person duly authorised in writing by the Information Officer to assist in discharging the duties and responsibilities assigned to the Information Officer in terms of the Promotion of Access to Information Act (PAIA) and the Protection of Personal Information Act (POPIA);
- “Manual” means this Manual published in compliance with Section 51 of the Act;
- “private body” means a natural person, company or other type of juristic entity that carries on any trade, business or profession;
- “POPIA” means the Protection of Personal Information Act 4 of 2013, and any regulations, guidelines or codes of conduct published thereunder, as amended from time to time;
- “Record” means any recorded information, regardless of form or medium, which is in the possession or under the control of the Company, irrespective of whether or not it was created by the Company;
- “Request” means a request for access to a Record of the Company;
- “Requestor” means any person, including a public body or an official thereof, making a Request for access to a Record of the Company and includes any person acting on behalf of that person; and
- “SAHRC” means the South African Human Rights Commission.
- Unless a contrary intention clearly appears, words signifying:
-
- The singular includes the plural and vice versa;
- any one gender includes the other genders and vice versa; and
- natural persons include juristic persons
Unless otherwise stated, terms defined in the Act shall have the same meaning in this Manual.
Overview of the Company
INUKA is a company incorporated in accordance with the company laws of South Africa. The Founder is Alma Gericke, and the history of the Company involves our Founder’s vision to create rewarding and financially sustainable business opportunities for people from all walks of life. INUKA, meaning “surrounded by smell”, was established in June 2010. INUKA is a Network Marketing Company that sells luxury high quality cosmetic and fragranced products at wholesale prices to independent entrepreneurs.
PURPOSE OF THE PAIA MANUAL
This PAIA Manual is useful for the public to:
- Check the categories of records held by a body which are available without a person having to submit a formal PAIA request;
- Have a sufficient understanding of how to make a request for access to a record of the body, by providing a description of the subjects on which the body holds records, and the categories of records held on each subject;
- Know the description of the records of the body which are available in accordance with any other legislation;
- Access all the relevant contact details of the Information Officer and Deputy Information Officer who will assist the public with the records they intend to access;
- Know the description of the guide on how to use PAIA, as updated by the Regulator and how to obtain access to it;
- Know if the body will process personal information, the purpose of processing of personal information and the description of the categories of data subjects and of the information or categories of information relating thereto;
- Know the description of the categories of data subjects and of the information or categories of information relating thereto;
- Know the recipients or categories of recipients to whom the personal information may be supplied;
- Know if the body has planned to transfer or process personal information outside the Republic of South Africa and the recipients or categories of recipients to whom the personal information may be supplied; and
- Know whether the body has appropriate security measures to ensure the confidentiality, integrity and availability of the personal information which is to be processed.
KEY CONTACT DETAILS FOR ACCESS TO INFORMATION OF INUKA
- Information Officer
The Chief Executive of the Company, as head of the private body, has delegated his powers to the Chief Information Officer (CIO), as Information Officer, whose details appear hereunder for purposes of dealing with all matters in connection with Requests for information on the Company’s behalf and to ensure compliance with the Act. Any person seeking access to a record in the possession or under control of INUKA in terms of Section 53 of PAIA or a data subject requesting access to personal information in terms of Section 23 of POPIA may address the request to the Information Officer.
Name: Werner Kruger
Tel: 0219499850
Email: [email protected]
- Deputy Information Officer
The Information Officer has appointed the Deputy Information Officer to assist in discharging the duties and responsibilities imposed by the Promotion of Access to Information Act, 2000 (PAIA), and the Protection of Personal Information Act, 2013 (POPIA). The Deputy Information Officer acts under the direction and control of the Information Officer and is responsible for assisting in:
- Processing and responding to access to information requests made in terms of Section 53 of PAIA;
- Assisting data subjects with requests to access, correct, or delete their personal information in terms of Section 23 of POPIA;
- Ensuring that internal processes, training, and awareness are implemented to support compliance with the Acts.
The Deputy Information Officer’s contact details are set out below. All matters relating to PAIA and POPIA compliance may also be addressed to the Deputy Information Officer, who will assist under the guidance of the Information Officer.
Name: Viwe Mashalaba
Tel: 0219499850
Email: [email protected]
Name: Werner Kruger
Tel: 0219499850
Email: [email protected]
Access to information General Contacts
Tel: 0219499850
Email: [email protected]
- Head Office
Postal and Physical Address:
- Unit 5, Bellpark Building
Corner of Durban Road and De Lange Street - Bellville, Western Cape
- 7530, South Africa
- Telephone: 0219499850
- Email: [email protected]
- Website: inuka.co.za
GUIDE ON HOW TO USE PAIA AND HOW TO OBTAIN ACCESS TO THE GUIDE
- The Regulator has, in terms of section 10(1) of PAIA, as amended, updated and made available the revised Guide on how to use PAIA (“Guide”), in an easily comprehensible form and manner, as may reasonably be required by a person who wishes to exercise any right contemplated in PAIA and POPIA.
- The Guide is available from the Regulator in each of the official languages and in braille.
- The aforesaid Guide contains the description of:
- The objects of PAIA and POPIA;
- The postal and street address, phone and fax number and, if available, electronic mail address of:
The Information Officer of every public body, and
Every Deputy Information Officer of every public and private body designated in terms of section 17(1) of PAIA1 and section 56 of POPIA2; - The manner and form of a request for:
Access to a record of a public body contemplated in section 113; and
Access to a record of a private body contemplated in section 504; - The assistance available from the Information Officer of a public body in terms of PAIA and POPIA;
- The assistance available from the Regulator in terms of PAIA and POPIA;
- All remedies in law available regarding an act or failure to act in respect of a right or duty conferred or imposed by PAIA and POPIA, including the manner of lodging:
- 1 Section 17(1) of PAIA- For the purposes of PAIA, each public body must, subject to legislation governing the employment of personnel of the public body concerned, designate such number of persons as deputy information officers as are necessary to render the public body as accessible as reasonably possible for requesters of its records.
- 2 Section 56(a) of POPIA- Each public and private body must make provision, in the manner prescribed in section 17 of the Promotion of Access to Information Act, with the necessary changes, for the designation of such a number of persons, if any, as deputy information officers as is necessary to perform the duties and responsibilities as set out in section 55(1) of POPIA.
- 3 Section 11(1) of PAIA- A requester must be given access to a record of a public body if that requester complies with all the procedural requirements in PAIA relating to a request for access to that record; and access to that record is not refused in terms of any ground for refusal contemplated in Chapter 4 of this Part.
- 4 Section 50(1) of PAIA- A requester must be given access to any record of a private body if-
a) that record is required for the exercise or protection of any rights;
b) that person complies with the procedural requirements in PAIA relating to a request for access to that record; and
c) access to that record is not refused in terms of any ground for refusal contemplated in Chapter 4 of this Part. - An internal appeal;
- A complaint to the Regulator; and
- An application with a court against a decision by the information officer of a public body, a decision on internal appeal or a decision by the Regulator or a decision of the head of a private body;
- The provisions of sections 145 and 516 requiring a public body and private body, respectively, to compile a Manual, and how to obtain access to a Manual;
- The provisions of sections 157 and 528 providing for the voluntary disclosure of categories of records by a public body and private body, respectively;
- The notices issued in terms of sections 229 and 5410 regarding fees to be paid in relation to requests for access; and
- The regulations made in terms of section 9211.
5 Section 14(1) of PAIA- The information officer of a public body must, in at least three official languages, make available a Manual containing information listed in paragraph 4 above. - 6 Section 51(1) of PAIA- The head of a private body must make available a Manual containing the description of the information listed in paragraph 4 above.
- 7 Section 15(1) of PAIA- The information officer of a public body, must make available in the prescribed manner a description of the categories of records of the public body that are automatically available without a person having to request access
- 8 Section 52(1) of PAIA- The head of a private body may, on a voluntary basis, make available in the prescribed manner a description of the categories of records of the private body that are automatically available without a person having to request access
- 9 Section 22(1) of PAIA- The information officer of a public body to whom a request for access is made, must by notice require the requester to pay the prescribed request fee (if any), before further processing the request.
10 Section 54(1) of PAIA- The head of a private body to whom a request for access is made must by notice require the requester to pay the prescribed request fee (if any), before further processing the request. - 11 Section 92(1) of PAIA provides that –“The Minister may, by notice in the Gazette, make regulations regarding-
(a) any matter which is required or permitted by this Act to be prescribed;
(b) any matter relating to the fees contemplated in sections 22 and 54;
(c) any notice required by this Act;
(d) uniform criteria to be applied by the information officer of a public body when deciding which categories of records are to be made available in terms of section 15; and
(e) any administrative or procedural matter necessary to give effect to the provisions of this Act.” - Members of the public can inspect or make copies of the Regulator’s Guide from the offices of the public and private bodies, including the office of the Regulator, during normal working hours.
- The Guide can also be obtained:
- upon request to INUKA’s Information Officer using Form 1 – Request for a Copy of the Guide from an Information Officer;
- The Regulator has, in terms of section 10(1) of PAIA, as amended, updated and made available the revised Guide on how to use PAIA (“Guide”), in an easily comprehensible form and manner, as may reasonably be required by a person who wishes to exercise any right contemplated in PAIA and POPIA. For further guidance, contact the Information Regulator. They have compiled a PAIA guide in each official language of South Africa on how to exercise your rights under PAIA. More information can be found at https://inforegulator.org.za/
- A copy of the Guide is also available in the following two official languages, for public inspection at our Head Office location during our normal office hours:
- English
- isiXhosa
CATEGORIES OF RECORDS OF INUKA WHICH ARE AVAILABLE WITHOUT AS PERSON HAVING TO REQUEST ACCESS
- We make some records automatically available to you without you needing to request access to them by completing Form 2. These are mostly records that maybe available on the website and a person may download or request telephonically or by sending an email or a letter.
| Category of Records | Types of Records | Available on Website | Available on Request |
| Company Profile | About Us; Mission | Yes | Yes |
| Product Information | Products Brochure; Product Knowledge |
Yes | Yes |
| News and Marketing | Events and Recognition | Yes | Yes |
| Customer Support Resources | FAQ; Contact Us | Yes | Yes |
| Legal and Compliance Notices | Terms of Use; Privacy Policy; | Yes | Yes |
CATEGORIES OR RECORDS OF INUKA WHICH ARE AVAILABLE IN ACCORDANCE WITH ANY OTHER LEGISLATION
- Below are all the records which are created and available by INUKA in accordance with any of the South African legislation.
| Category of Records | Applicable Legislation |
| Anti-corruption and organised crime |
|
| Communications and IT |
|
| Compliance and Corporate Governance |
|
| Copyright, Intellectual Property and Trademarks |
|
| Finance |
|
| General |
|
| Human Resources |
|
DESCRIPTIONS OF THE SUBJECTS ON WHICH THE BODY HOLDS RECORDS, AND CATEGORIES OF RECORDS HELD ON EACH SUBJECT
- Below are all the records of the subjects in respect of which INUKA holds records, and the categories of records held on each subject:
| Subjects on which the body holds records | Categories of records |
| Statutory and Legal |
|
| Human Resources |
|
| Finance |
|
| Retirement Fund |
|
| Information technology |
|
| Sales and Marketing |
|
| Assets |
|
| Insurance |
|
| Operational Information |
This information can be defined as information needed in the day-to-day running of the organization. Internal telephone lists, address lists, company policies, company procedures, human resource Manuals, administration Manuals, industry related statistical data, management information reports, lease agreements, construction contracts and architectural drawings. |
PROCESSING OF PERSONAL INFORMATION
- Purpose of Processing Personal Information
The purpose for which personal information is processed by INUKA will depend on the nature of the information and the data subject. This purpose is ordinarily disclosed, explicitly or implicitly, at the time the data is collected. Please refer to our website for our Privacy Policy or ask our Information Officer for a copy.
- Description of the categories of Data Subjects and of the information or categories of information relating thereto
Below are the categories of data subjects in respect of whom INUKA processes personal information and the nature or categories of the personal information being processed.
| Categories of Data Subjects | Personal Information that may be processed |
| Members and Candidates |
Title and name; contact numbers and/or e-mail address; language; Identity or passport number; click patterns websites; bank details; postal and/or street address |
| Vendors / Suppliers / Other Businesses |
Name and contact details; address; Identity and/or company information and directors’ information; Banking and financial information; vat numbers; Information about products or services; other information not specified, reasonably required to be processed for business operations. |
| Employees |
Includes ID number; contact details; physical and postal address; date of birth; age; marital status; race; disability information; employment history; criminal / background checks; fingerprints; CVs; education history; banking details; income tax reference number; remuneration and benefit information (including medical aid, pension / provident fund information); details related to employee performance; disciplinary procedures. |
- The recipients or categories of recipients to whom the personal information may be supplied
INUKA may share the personal information of data subjects for various purposes with the following:
-
- Any operators who perform services on behalf of INUKA;
- Any applicable pension funds, provident funds, credit bureau, and/or recruitment companies;
- Any firm, organisation or person that/who provides INUKA with products or services;
- Any payment system that INUKA uses;
- Regulatory and governmental authorities or ombudsmen, or other authorities, including tax authorities, where the INUKA has a duty to share information;
- Third parties to whom payments are made on behalf of employees;
- Financial institutions from whom payments are received on behalf of data subjects;
- Any other operator not specified; and
- Employees, contractors and temporary staff.
- Planned transborder flows of personal information
INUKA may share with or receive personal information from parties as set out above, where these parties reside outside of the Republic of South Africa. Planned transborder flows of personal information may include:
-
- Storing information electronically; and
- Making use of third-party service providers to fulfil a business function on behalf of INUKA.
- General description of Information Security Measures to be implemented by the responsible party to ensure the confidentiality, integrity and availability of the information
INUKA has information security measures, technologies, and controls to ensure the security, confidentiality, integrity and availability of personal information in our possession. This is supported by appropriate technical and organisational measures designed to ensure that personal data remains confidential and secure against unauthorised or unlawful processing and against accidental loss, destruction or damage.
These measures include, but are not limited to:
-
- Secure access controls (e.g., user authentication and role-based permissions)
- Encrypted storage and secure backup procedures
- Firewall and anti-malware protection
- Secure communication protocols (e.g., HTTPS, VPN)
- Regular vulnerability assessments and system monitoring
- Physical access restrictions to data centres and offices
- Secure email communications (e.g.; DMARC)
These safeguards are aligned with industry best practices and are reviewed regularly to address evolving cybersecurity threats and ensure ongoing compliance.
ACCESS PROCEDURES AND PAYABLE FEES
Completion of the prescribed form
- Requests for access to records must be made to the Information Officer on the prescribed form, Form 2 – Request for Access to Record, at the address or email address referred to within. Failure to make use of the prescribed form could result in your Request being refused or delayed;
- The Requestor must indicate which form of access is required and if he/she wishes to be informed on the decision on the Request in any other manner, to state the necessary particulars to be so informed;
- Access is not automatic – the Requestor must therefore identify the right he/she is seeking to exercise or protect and provide an explanation as to why the requested Record is required for the exercise or protection of that right;
- The requestor must provide sufficient detail on the Request form to enable the Information Officer to clearly identify the Record as well as the Requestor’s identify, which is to be accompanied by positive proof of identification.
Proof of identity
- Proof of identity is required to authenticate your identity and the request. You will, in addition to the prescribed form, be required to submit acceptable proof of identity such as a certified copy of your identity document or other legal forms of identity;
- If a Request is made on behalf of a person, the Requestor must then submit proof, to the satisfaction of the Information Officer, of his/her authority to make the Request. Failure to do so will result in the Request being rejected.
- Payment of the prescribed fees
There are two categories of fees which are payable:
- The request fee: When submitting your Request, you must pay INUKA a request fee of a R140 (inclusive of VAT) as the law prescribes. You must pay INUKA the prescribed fees before we give you access. This fee is not applicable to personal Requests, i.e., individual seeking access to Records pertaining him/herself;
- The access fee: If INUKA grants the Request, the Requestor will have to pay a further access fee the law prescribes that includes a fee for the time it takes INUKA to manage your request, or if the time has exceeded the prescribed hours to search and prepare the record for disclosure. Access will be withheld until the Requestor has made payment of the applicable fee(s).
- These fees are detailed in Annexure 1 – Access to information fees for private bodies.
Timelines for consideration of a request for access
- The Requestor will be notified, within 30 days, in the manner indicated by him/her of the outcome of his/her Request, alternatively whether an extension not exceeding 30 days is required to deal with the Request.
Grounds for refusal of access and protection of information
- We may refuse you access to certain records in terms of PAIA to protect:
- Someone else’s privacy,
- Another company’s commercial information,
- Someone else’s confidential information,
- Research information,
- The safety of individuals and property, or
- Records privileged from production in legal proceedings.
Remedies available to a Requestor on refusal of access
- If the Request for access is refused, reasons for the refusal will be provided.
- There is no internal appeal procedure that may be followed after a request to access Information has been refused. The decision made by the Information Officer is final.
- If you are not satisfied with the outcome of the request, you are entitled to apply to a court of competent jurisdiction to take the matter further.
Annexure 1 - ACCESS TO INFORMATION FEES FOR PRIVATE BODIES
| Item | Description | Amount |
| 1. | Request fee, payable by every requester | R 140.00 |
| 2. | Photocopy or printed black & white copy for every A4 page | R 2.00 per pages or part of the page |
| 3. | Printed copy of A4-size page | R 2.00 per pages or part of the page |
| 4. | For a copy in a computer-readable form on:
|
|
| 5. | For a transcription of visual images, for an A4- size page or part of the page | This service will be outsourced. The fee will depend on the quotation from the service provider. |
| 6. | For a copy of visual images | This service will be outsourced. The fee will depend on the quotation from the service provider. |
| 7. | For a transcription of an audio record, per A4- size page | R 24.00 |
| 8. |
|
|
| 9. |
|
|
| 10. | Deposit: if the search exceeds 6 hours | One-third of the amount per request. It is calculated in terms of items 2 to 8 above.Request fee |
| 11. | Postage, email or any other electronic transfer | Actual expense, if any. |