PAIA Manual

Prepared in terms of section 51 of the Promotion of Access to Information Act, 2000 (Act No. 2 of 2000), as amended
Date of compilation: 01/06/2024
Date of revision: 07/04/2026

1. Introduction

This manual is prepared in terms of section 51 of the Promotion of Access to Information Act, 2000 (“PAIA”).

Its purpose is to help anyone who wants to request access to records held by Virtual Focus, and to explain the categories of records we hold, the process for requesting access, and related information required under PAIA.

2. Details of the Private Body

Name of private body: Virtual Focus
Registration number (if applicable): Not applicable
Physical address: 8 Athens Road, Table View, Cape Town, 7441
Postal address: 8 Athens Road, Table View, Cape Town, 7441
Email address: Contact Virtual Focus
Website: www.virtualfocus.co.za

3. Information Officer

Information Officer: Charlene da Silva
Email address: Contact Virtual Focus

4. Guide on How to Use PAIA

The Information Regulator has published a guide on how to use PAIA. The guide explains how to request access to records, how to access the manuals of public and private bodies, and what remedies are available under PAIA.

The guide can be obtained from the Information Regulator.

Information Regulator (South Africa)
Website: https://inforegulator.org.za/
PAIA forms: https://inforegulator.org.za/paia-forms/
PAIA guide and templates: https://inforegulator.org.za/paia-guidelines/

5. Records Automatically Available

The following records may be available without a formal PAIA request, where published or otherwise made publicly accessible:

website pages
service information
pricing information published on the website
contact details published on the website
Privacy Policy
Terms and Conditions
Refund, Cancellation and Delivery Policy
this PAIA Manual

6. Records Available in Terms of Other Legislation

Where applicable, records may also be available in terms of legislation including:

Promotion of Access to Information Act, 2000
Protection of Personal Information Act, 2013
Electronic Communications and Transactions Act, 2002
Consumer Protection Act, 2008
Companies Act, 2008, where applicable
Income Tax Act, 1962
Value-Added Tax Act, 1991, where applicable
Basic Conditions of Employment Act, 1997, where applicable
Labour Relations Act, 1995, where applicable

7. Categories of Records Held

Virtual Focus may hold records in the following categories:

7.1 Corporate and administrative records

business registration documents, where applicable
internal policies and procedures
supplier and contractor agreements
business correspondence
compliance records

7.2 Financial records

quotations
invoices
payment records
accounting records
tax records

7.3 Client and service records

client enquiry records
contact details
CVs or resumes provided by clients
cover letter content
LinkedIn-related information provided by clients
client instructions and correspondence
project drafts and final deliverables
delivery records
revision records

7.4 Website and marketing records

website content
website enquiry submissions
analytics and reporting records
advertising performance records
cookie and tracking-related records, where applicable

7.5 Human resources records, if applicable

employment contracts
leave records
payroll records
disciplinary records
contractor records

8. Processing of Personal Information

Virtual Focus may process personal information in the course of operating its website and providing services.

8.1 Purpose of processing

Personal information may be processed for purposes including:

responding to enquiries
communicating with clients
delivering services
storing and managing documents
processing payments
maintaining records
improving website and marketing performance
complying with legal obligations

8.2 Categories of data subjects

Personal information may relate to:

website visitors
prospective clients
clients
suppliers
contractors
employees, if applicable

8.3 Categories of personal information

This may include:

names and contact details
billing and transaction information
career and profile information supplied by clients
CVs, cover letters, and related content
communications and correspondence
technical website usage data

8.4 Categories of recipients

Where reasonably necessary, personal information may be shared with:

hosting providers
email and communication providers
payment service providers
cloud storage providers
analytics and advertising providers
Canva
Google Drive
professional advisers
regulatory or legal authorities where required by law

8.5 Cross-border transfers

Some service providers may store or process information outside South Africa.

8.6 Security measures

Virtual Focus takes reasonable technical and organisational steps to protect the confidentiality and integrity of personal information.

9. How to Request Access to Records

To request access to a record held by Virtual Focus, the requester must complete the prescribed PAIA request form and submit it to the Information Officer using the contact details set out in this manual.

The request must provide enough detail to allow Virtual Focus to identify:

the record requested
the requester
the form of access required
the right the requester seeks to exercise or protect, where applicable
why the record is required

Proof of identity may be required before a request is processed.

10. Fees

Requesters may be required to pay the prescribed fees applicable under PAIA.

Any applicable fee requirements will be communicated to the requester in accordance with PAIA.

11. Grounds for Refusal of Access

Access to records may be refused where PAIA permits or requires refusal, including where disclosure would involve:

personal information of a third party
confidential commercial information
legally privileged records
records relating to legal proceedings
safety or security concerns
any other protected ground under PAIA

12. Remedies and Complaints

If a requester is dissatisfied with a response to a request, or with a failure to respond, the requester may lodge a complaint with the Information Regulator or pursue any other remedy available in law.

13. Availability of This Manual

This manual is available:

on the Virtual Focus website
from the Information Officer on request
in any other manner required by law

14. Updating of the Manual

This manual may be updated from time to time to reflect changes in the law, the business, or its record-keeping practices.