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Manual in Terms of Section 51 of the Promotion of Access to Information Act 2 of 2000

Prepared by: Elevate Tech Limited Registration Number: 2025/742289/10 In terms of: Section 51 of the Promotion of Access to Information Act 2 of 2000 ("PAIA"), read with the Protection of Personal Information Act 4 of 2013 ("POPIA")

Effective Date: 3 June 2026 Version: 1.0

1. Introduction

1.1 This manual ("Manual") is published by Elevate Tech Limited ("Elevate Tech", "we", "us" or "our"), a private body as defined in PAIA, in compliance with section 51 of PAIA.

1.2 PAIA gives effect to the constitutional right of access to information held by another person that is required for the exercise or protection of any right. This Manual is intended to assist a requester in determining whether to request access to records held by Elevate Tech, and how to do so.

1.3 This Manual has been updated to reflect the amendments to PAIA brought about by POPIA, which introduced provisions relating to requests for access to records containing personal information and the role of the Information Regulator.

1.4 This Manual is available free of charge on the Website at https://store.elevatetech.biz and on request from the Information Officer.

2. Particulars of Elevate Tech Limited (Section 51(1)(a))

  • Registered name: Elevate Tech Limited
  • Registration number: 2025/742289/10
  • VAT/Tax number: 9860279190
  • Nature of business: Specialist business-to-business distributor and eCommerce retailer of elevator and vertical transportation mechanical and electrical components, including safety-critical components.
  • Physical address: 24 Price Drive, Constantia, Cape Town, Western Cape, 7806, South Africa
  • Postal address: 24 Price Drive, Constantia, Cape Town, Western Cape, 7806, South Africa
  • Website: https://store.elevatetech.biz
  • Telephone: Not currently published; please contact us by email.

3. Particulars of the Information Officer and Deputy Information Officer

3.1 The Information Officer of Elevate Tech, to whom all requests for access to records and all enquiries under PAIA and POPIA must be directed, is:

  • Name: Wade Wareing
  • Designation: Information Officer
  • Email: wade@elevatetech.biz
  • Postal/physical address: 24 Price Drive, Constantia, Cape Town, Western Cape, 7806, South Africa

3.2 Any Deputy Information Officer(s) designated from time to time act under the authority and direction of the Information Officer. Enquiries regarding the current designation may be directed to the Information Officer.

4. The Information Regulator (Section 51(1)(a))

4.1 A requester may, in the circumstances set out in PAIA, lodge a complaint with, or an application to, the Information Regulator. The Information Regulator's details are:

5. The PAIA Guide of the Information Regulator (Section 51(1)(b))

5.1 The Information Regulator has compiled a guide, in terms of section 10 of PAIA, in an easily comprehensible form and manner, to assist a person who wishes to exercise any right contemplated in PAIA and POPIA.

5.2 The guide is available in each of the official languages and in Braille, and may be obtained from the Information Regulator at the contact details set out in clause 4, or on the Information Regulator's website at https://inforegulator.org.za.

6. Records Available in Terms of Other Legislation (Section 51(1)(d))

6.1 Records may be accessible without a request under PAIA in terms of other legislation. Categories of records held by Elevate Tech that are, or may be, available in terms of other legislation include those held under:

  • the Companies Act 71 of 2008;
  • the Income Tax Act 58 of 1962;
  • the Value-Added Tax Act 89 of 1991;
  • the Tax Administration Act 28 of 2011;
  • the Basic Conditions of Employment Act 75 of 1997;
  • the Labour Relations Act 66 of 1995;
  • the Employment Equity Act 55 of 1998 (where applicable);
  • the Unemployment Insurance Act 63 of 2001 and Unemployment Insurance Contributions Act 4 of 2002;
  • the Compensation for Occupational Injuries and Diseases Act 130 of 1993;
  • the Occupational Health and Safety Act 85 of 1993;
  • the Skills Development Act 97 of 1998 and Skills Development Levies Act 9 of 1999 (where applicable);
  • the Protection of Personal Information Act 4 of 2013;
  • the Electronic Communications and Transactions Act 25 of 2002; and
  • the Consumer Protection Act 68 of 2008.

6.2 Access to records under other legislation is subject to the requirements and procedures of the relevant legislation and the body administering it.

7. Categories of Records Held by Elevate Tech (Section 51(1)(e))

7.1 The following categories of records are held by Elevate Tech. The fact that a category is listed does not mean that access will be granted; access is subject to the grounds for refusal in PAIA.

(a) Company and statutory records:

  • founding and registration documents;
  • memorandum of incorporation and related governance records;
  • statutory registers and resolutions;
  • licences, registrations and authorisations.

(b) Financial records:

  • financial statements and management accounts;
  • accounting and bookkeeping records;
  • tax records (income tax, VAT, PAYE where applicable);
  • banking records;
  • invoices, receipts and payment records.

(c) Customer and transaction records:

  • customer account information (name, surname, company name, email, telephone, physical address);
  • business information (VAT number, company registration number);
  • orders, invoices and payment references;
  • credit account records and credit assessments (where applicable);
  • correspondence and support records.

(d) Supplier and contractor records:

  • supplier and Manufacturer agreements and correspondence;
  • delivery and logistics partner agreements;
  • payment-gateway and service-provider agreements.

(e) Employee and human-resources records (where applicable):

  • employment contracts and personnel records;
  • payroll and statutory deduction records;
  • health and safety records.

(f) Operational and product records:

  • product catalogues, specifications and Technical Data;
  • engineering documentation;
  • inventory and warehouse records (Cape Town, Johannesburg, Durban);
  • quality, returns, warranty and complaint records.

(g) Information technology and data records:

  • website and systems records;
  • technical information (IP addresses, device and browser information, login records, website activity);
  • security, access and audit logs;
  • data-processing and operator agreements.

(h) Marketing records:

  • newsletter subscriptions, product interests and communication preferences;
  • marketing and campaign materials.

(i) Legal and compliance records:

  • policies, including this Manual and the Privacy Policy;
  • contracts and agreements;
  • correspondence with regulators and advisers;
  • records relating to litigation, disputes and insurance.

8. Processing of Personal Information under POPIA (Section 51(1)(e) read with POPIA)

8.1 Elevate Tech processes personal information as a responsible party under POPIA. The categories of data subjects and personal information, the purposes of processing, the recipients of personal information, and the planned cross-border transfers are described in our Privacy Policy and, where required, may be reflected in a notification to the Information Regulator.

8.2 Categories of data subjects include customers and prospective customers, suppliers and service providers, employees and contractors, and website users.

8.3 Categories of personal information include the categories listed in clause 4 of the Privacy Policy (account, business, transaction, technical and marketing information).

8.4 Purpose of processing is set out in the Privacy Policy and includes account administration, order fulfilment, payment processing, credit management, fraud prevention, customer support, marketing (with consent), legal compliance and security.

8.5 Recipients include payment, logistics, technology, hosting, credit-verification and professional service providers, and authorities where required by law, as described in the Privacy Policy.

8.6 Security measures to protect personal information are described in the Privacy Policy and the Website Security and Fraud Prevention Policy.

9. How to Request Access to a Record (Sections 51(1)(c) and 53)

9.1 A requester who wishes to request access to a record held by Elevate Tech must complete the prescribed Form 2 (Request for Access to Record) and submit it to the Information Officer.

9.2 The request must:

(a) be made on the prescribed form; (b) provide sufficient particulars to enable the Information Officer to identify the record and the requester; (c) indicate the form of access required; (d) specify a postal address, email address, fax number or other means within the Republic by which the requester may be informed of the decision; (e) identify the right that the requester seeks to exercise or protect, and explain why the requested record is required for the exercise or protection of that right; and (f) if the request is made on behalf of another person, include proof of the capacity in which the requester is making the request.

9.3 The prescribed forms are available from the Information Officer on request, on the Website, and on the Information Regulator's website at https://inforegulator.org.za.

10. Fees (Section 54)

10.1 Two types of fees may be payable by a requester (other than a personal requester requesting their own personal information, to the extent provided in PAIA):

(a) a request fee, which is a standard fee payable on submission of a request for access; and (b) an access fee, which is calculated by taking into account reproduction costs, search and preparation time, and (where applicable) postal and other costs of giving access.

10.2 The Information Officer will notify the requester of the access fee (if any) and may require a deposit where the preparation of the record is likely to take more than the prescribed number of hours.

10.3 The fees payable are those prescribed under PAIA from time to time. A requester may lodge an internal appeal or an application against the tender or payment of fees, as provided in PAIA.

10.4 Access to a record may be withheld until the applicable fees have been paid.

11. Grounds for Refusal of Access (Sections 62 to 69)

11.1 Elevate Tech may, or in certain cases must, refuse a request for access on the grounds set out in PAIA, including:

(a) the mandatory protection of the privacy of a third party who is a natural person (section 63); (b) the mandatory protection of the commercial information of a third party (section 64); (c) the mandatory protection of certain confidential information of a third party (section 65); (d) the mandatory protection of the safety of individuals and the protection of property (section 66); (e) the mandatory protection of records privileged from production in legal proceedings (section 67); (f) the protection of the commercial information of Elevate Tech, including trade secrets, financial, commercial, scientific or technical information that could harm Elevate Tech's commercial or financial interests (section 68); (g) the protection of research information of Elevate Tech or a third party (section 69); and (h) any other ground for refusal permitted under PAIA.

11.2 Access must be granted where required by section 70 (mandatory disclosure in the public interest), notwithstanding any other provision, in the circumstances described in that section.

11.3 If a record cannot be found or does not exist, the Information Officer will notify the requester accordingly, by way of an affidavit or affirmation where required.

12. Decision and Notification (Sections 56 and 57)

12.1 The Information Officer will, within 30 (thirty) days of receipt of a request (subject to any permitted extension), decide whether to grant or refuse the request and notify the requester of the decision.

12.2 The period may be extended in the circumstances permitted by PAIA, in which case the requester will be notified of the extension and the reasons for it.

12.3 Where access is refused, the notice will state adequate reasons for the refusal, the relevant provisions of PAIA relied upon, and the requester's right to lodge an application with a court (or a complaint with the Information Regulator) and the procedure for doing so.

13. Remedies (Complaint to the Information Regulator and Court Application)

13.1 A requester or third party who is dissatisfied with a decision of the Information Officer may, as provided in PAIA:

(a) lodge a complaint with the Information Regulator in the prescribed manner; and/or (b) apply to a court with jurisdiction for appropriate relief.

13.2 The Information Regulator's contact details are set out in clause 4.

14. Availability of this Manual (Section 51(3))

14.1 This Manual is available:

(a) on the Website at https://store.elevatetech.biz; (b) from the Information Officer, on request, at the contact details in clause 3; and (c) for inspection at the registered/physical address of Elevate Tech during normal business hours, free of charge.

14.2 Copies of this Manual may be requested from the Information Officer. A reasonable fee for reproduction may apply where a physical copy is requested.

15. Updates and Amendments

15.1 This Manual will be updated as and when necessary, including following changes to PAIA, POPIA, the structure or functions of Elevate Tech, or the categories of records held. The updated version will be published on the Website with a revised "Effective Date" and "Version".

16. Governing Law and Contact Details

16.1 This Manual is governed by the laws of the Republic of South Africa and must be read with PAIA and POPIA.

16.2 All PAIA and POPIA requests and enquiries must be directed to:

This PAIA Manual should be read together with the Privacy Policy and the POPIA Data Subject Rights Policy. Prescribed forms (Form 2 — Request for Access to Record, and related forms) are available from the Information Officer and from the Information Regulator at https://inforegulator.org.za.