Prepared in terms of Section 51 of the
 Promotion of Access to Information Act 2 of 2000 (as amended)
 and aligned with the
 Protection of Personal Information Act 4 of 2013

Version 1.0 June 2026

 Review Date: June 2027
 Website: www.landosol.co.za

Table of Contents

List of Acronyms and Abbreviations

Section 1 — Introduction and Purpose of the Manual

1.1   Introduction

1.2   Purpose of the Manual

1.3   Availability of the Manual

Section 2 — Definitions and Interpretation

Section 3 — Contact Details of the Information Officer

3.1   Company Details

3.2   Information Officer

3.3   Deputy Information Officer

Section 4 — Guide on How to Use PAIA

Section 5 — Records Available Without Request (Automatic Disclosure)

Section 6 — Records Available in Terms of Other Legislation

Section 7 — Description of Categories of Records Held

7.1   Introduction

7.2   Human Resources and Employee Records

7.3   Financial and Accounting Records

7.4   Legal and Compliance Records

7.5   Operational and Administrative Records

7.6   Personal Information Records (POPIA)

Section 8 — Request Procedure for Access to Records

8.1   Who May Request Access

8.2   How to Submit a Request

8.3   How to Obtain Form 2

8.4   Completing the Form

8.5   Submitting the Form

8.6   Request Fee

8.7   Response Timeframes

8.8   Decision on the Request

Section 9 — Prescribed Fees

9.1   Request Fee

9.2   Deposit

9.3   Access Fees Schedule

9.4   Waiver of Fees

9.5   Payment Methods

Section 10 — Grounds for Refusal

10.1   Introduction

10.2   Mandatory Grounds for Refusal

10.3   Discretionary Grounds for Refusal

10.4   Severability

Section 11 — Remedies and Rights of Appeal

11.1   Internal Appeal

11.2   External Remedies

11.3   Information Regulator Contact Details

Section 12 — Processing of Personal Information (POPIA Compliance)

12.1   Introduction

12.2   Categories of Data Subjects

12.3   Purposes of Processing

12.4   Conditions for Lawful Processing

12.5   Retention and Destruction of Personal Information

12.6   Sharing of Personal Information

12.7   Transborder Flows of Personal Information

Section 13 — Information Security Measures

13.1   Security Safeguards

13.2   Security Measures

13.3   Data Breach Notification

Section 14 — Rights of Data Subjects

14.1   Rights Under POPIA

14.2   How to Exercise These Rights

Section 15 — Availability and Updating of This Manual

15.1   Availability

15.2   Language

15.3   Review and Update

Annexure A — Request for Access to Records — Form 2 (PPR 2)

Annexure B — Prescribed Fees Schedule

Annexure C — Information Regulator Contact Details

Disclaimer

List of Acronyms and Abbreviations

Acronym / Abbreviation	Full Description
CEO	Chief Executive Officer
DIO	Deputy Information Officer
DOJCD	Department of Justice and Constitutional Development
GNR	Government Notice Regulation
IO	Information Officer
IR	Information Regulator
PAIA	Promotion of Access to Information Act 2 of 2000 (as amended)
POPIA	Protection of Personal Information Act 4 of 2013
Pty Ltd	Proprietary Limited
Reg	Regulation / Regulations
SAHRC	South African Human Rights Commission

Section 1: Introduction and Purpose of the Manual

1.1 Introduction

This PAIA Manual ("the Manual") has been compiled by LandoSol (Pty) Ltd (Registration Number: 2010/018518/07) ("the Company") in compliance with Section 51 of the Promotion of Access to Information Act 2 of 2000 ("PAIA"), as amended by the Promotion of Access to Information Amendment Act 31 of 2023, and is aligned with the Protection of Personal Information Act 4 of 2013 ("POPIA").

PAIA gives effect to Section 32 of the Constitution of the Republic of South Africa, 1996, which guarantees every person the right of access to any information held by the State and to any information held by another person that is required for the exercise or protection of any right. POPIA gives effect to Section 14 of the Constitution, which guarantees the right to privacy, including the right to protection against the unlawful collection, retention, dissemination, and use of personal information.

LandoSol (Pty) Ltd is committed to the following principles in all its information management practices:

• Full transparency in the manner in which it manages and processes information;
• Protecting the personal information of all data subjects, including employees, clients, and suppliers;
• Facilitating lawful access to information in accordance with the provisions of PAIA and POPIA; and
• Upholding the constitutional rights of all persons who interact with the Company.

Legal Basis This Manual is a mandatory compliance document required of every private body in terms of Section 51 of PAIA. Failure to compile and publish this Manual may result in regulatory and legal consequences.

1.2 Purpose of the Manual

The purpose of this Manual is to:

1. Inform requesters of the categories of records held by LandoSol (Pty) Ltd;
2. Outline the procedure for requesting access to records held by the Company;
3. Describe the prescribed fees applicable to requests for access to records;
4. Explain how LandoSol (Pty) Ltd processes personal information in terms of POPIA;
5. Provide the contact details of the Information Officer and Deputy Information Officer;
6. Inform data subjects of their rights under PAIA and POPIA; and
7. Describe the remedies available to requesters who are aggrieved by any decision of the Information Officer.

1.3 Availability of the Manual

This Manual is available to any person upon request and has been made available in the following ways:

• On the Company's website: www.landosol.co.za (available for free download);
• In printed form at the Company's registered office upon request;
• From the Information Officer at the contact details provided in Section 3 of this Manual; and
• A copy of this Manual has been submitted to the Information Regulator as required in terms of PAIA.

 

Section 2: Definitions and Interpretation

Unless the context indicates otherwise, the following definitions apply throughout this Manual. Definitions are sourced from PAIA and POPIA.

Term	Definition
Access Fee	The fee prescribed by the Minister of Justice and Constitutional Development, payable by a requester to whom access to a record has been granted, for the reproduction and/or search and preparation of the requested record.
Constitution	The Constitution of the Republic of South Africa, 1996.
Data Subject	The person to whom personal information relates. A data subject may be a natural person or, where applicable, a juristic person.
Deputy Information Officer (DIO)	A person designated by the Information Officer, in terms of Section 17 of POPIA, to perform the functions of the Information Officer and to assist with the fulfilment of PAIA and POPIA obligations.
Information Officer (IO)	In relation to a private body, the head of that private body, or any person duly authorised in writing by such head to act as Information Officer. The Information Officer is responsible for the functions described in Section 51 of PAIA.
PAIA	The Promotion of Access to Information Act 2 of 2000, as amended, which gives effect to the constitutional right of access to information.
Personal Information	As defined in Section 1 of POPIA: information relating to an identifiable, living, natural person, and where applicable, an identifiable, existing juristic person. This includes but is not limited to: name, identity number, contact details, financial information, employment history, biometric information, and opinions of or about the person.
POPIA	The Protection of Personal Information Act 4 of 2013, which gives effect to the constitutional right to privacy and governs the lawful processing of personal information.
Private Body	As defined in Section 1 of PAIA: (a) a natural person who carries on any trade, business, or profession; (b) a partnership; or (c) any former or existing juristic person, excluding a public body. LandoSol (Pty) Ltd is a private body.
Processing	As defined in Section 1 of POPIA: any operation or activity or any set of operations, whether or not by automatic means, concerning personal information, including the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation, use, dissemination, distribution, merging, linking, restriction, degradation, erasure, or destruction of information.
Record	Any recorded information regardless of form or medium, including written or printed materials, maps, drawings, photographs, computer printouts, data held in electronic or machine-readable form, video or sound recordings, in the possession or under the control of a private body, whether or not it was created by that private body.
Request for Access	A written request made by a requester to the Information Officer of a private body in the prescribed form (Form 2 — PPR 2) for access to a record held by that private body.
Requester	Any person, natural or juristic, making a request for access to a record of a private body. In the context of PAIA, the requester must demonstrate that the record is required for the exercise or protection of any right.
Responsible Party	As defined in Section 1 of POPIA: a public or private body or any other person which, alone or in conjunction with others, determines the purpose of and means for processing personal information. LandoSol (Pty) Ltd is a Responsible Party.
Third Party	In relation to a request for access to a record, any person other than the requester, whose interests may be affected by the disclosure of the requested record, including any person to whom the record relates.

 

Section 3: Contact Details of the Information Officer

3.1 Company Details

Detail	Information
Company Name	LandoSol (Pty) Ltd
Registration Number	2010/018518/07
Physical Address	134 Cascade Rd, Banners Rest, Port Edward, KZN, 4295
Postal Address	PO Box 50223, Banners Rest, Port Edward, KZN, 4295
Telephone Number	0646280011
Email Address	info@landosol.co.za
Website	www.landosol.co.za

3.2 Information Officer

In terms of Section 1 of PAIA, the head of a private body is automatically designated as the Information Officer of that private body. The head of LandoSol (Pty) Ltd, being the director(s) or such person as is duly authorised, is the Information Officer. The Information Officer has been registered with the Information Regulator as required under POPIA.

Detail	Information
Full Name	Marthinus Visser
Designation	Director
Physical Address	134 Cascade Rd, Port Edward, KZN 4295
Email Address	martin@landosol.co.za
Telephone Number	072-785-4303

3.3 Deputy Information Officer

In terms of Section 17 of POPIA, the Information Officer may designate one or more Deputy Information Officers to assist with the performance of PAIA and POPIA obligations. LandoSol (Pty) Ltd has designated the following Deputy Information Officer(s):

Detail	Information
Full Name	Rudolf De Noon
Designation	General Manager
Physical Address	134 Cascade Rd, Port Edward, KZN 4295
Email Address	rudolf@landosol.co.za
Telephone Number	082-578-3216

Note The Information Officer has been registered with the Information Regulator as required under POPIA. All PAIA requests and POPIA-related queries should be directed to the Information Officer or Deputy Information Officer at the contact details set out above.

 

Section 4: Guide on How to Use PAIA and How to Obtain the Guide

4.1 SAHRC Guide

The South African Human Rights Commission (SAHRC) is required by Section 10 of PAIA to compile a guide to assist persons who wish to exercise any right contemplated in PAIA. This guide is available in each of the official languages and is updated periodically.

The guide describes, in plain language, the objects of PAIA, the manner in which records may be requested, the fees applicable, and the procedure to be followed if a request is refused. Any person who wishes to exercise rights under PAIA should consult the SAHRC guide before submitting a request.

4.2 How to Obtain the SAHRC Guide

The SAHRC guide is available from the following sources:

Contact Method	Details
Website	www.sahrc.org.za
Physical Address	Braampark Forum 2, 33 Hoofd Street, Braamfontein, 2017
Telephone	011 877 3600
Email	paia@sahrc.org.za

4.3 Information Regulator Resources

The Information Regulator of South Africa also maintains comprehensive resources and guidance for data subjects, requesters, and responsible parties regarding both PAIA and POPIA. These resources are available at:

• Website: www.inforegulator.org.za
• Email: inforeg@justice.gov.za
• Telephone: 010 023 5207

 

Section 5: Records Available Without Request (Automatic Disclosure)

5.1 Automatic Disclosure

In terms of Section 52 of PAIA, a private body must make certain categories of records available to the public automatically, without requiring a formal PAIA request. These records are made available in the public interest and to promote transparency.

LandoSol (Pty) Ltd makes the following categories of records available without requiring a formal request:

5.2 Categories of Automatically Available Records

Category	Description and Availability
This PAIA Manual	Available on the Company website (www.landosol.co.za) and in printed form at the Company's registered offices upon request. No fee is charged for access to this Manual.
Company Registration Details	Available from the Companies and Intellectual Property Commission (CIPC) at www.cipc.co.za, and upon request from the Company.
General Company Information	Available on the Company's website at www.landosol.co.za, including information about the Company's business activities, contact details, and services.
Marketing and Promotional Materials	Available on the Company's website and upon request from the Company free of charge.
Published Financial Statements (if applicable)	Where required to be filed or made public in terms of the Companies Act 71 of 2008, available in accordance with the requirements of that Act.

5.3 Guidance for Requesters

Please Note Requesters are encouraged to first consult the Company's website at www.landosol.co.za and to contact the Information Officer before submitting a formal PAIA request, as the information sought may already be publicly available. This may save time and the cost of request fees.

Section 6: Records Available in Terms of Other Legislation

6.1 Legislation-Based Access to Records

Certain records held by LandoSol (Pty) Ltd are accessible in terms of legislation other than PAIA. In such cases, a formal PAIA request is not required, and the requester should approach the relevant regulatory body or utilise the mechanism prescribed by the applicable legislation. The table below sets out relevant legislation and the corresponding categories of records.

6.2 Table of Applicable Legislation

Legislation		Categories of Records
Companies Act 71 of 2008	Memorandum of Incorporation (MOI), company records, share register, financial statements, minutes of shareholder and director meetings, director details
Income Tax Act 58 of 1962	Tax returns and assessments (subject to confidentiality provisions and the authority of SARS)
Value-Added Tax Act 89 of 1991	VAT records, VAT returns, and supporting documentation
Labour Relations Act 66 of 1995	Employment records, disciplinary records, collective agreements, union recognition records
Basic Conditions of Employment Act 75 of 1997	Employment contracts, wage records, leave records, written particulars of employment
Employment Equity Act 55 of 1998	Employment equity plans, employment equity reports submitted to the Department of Employment and Labour
Skills Development Act 97 of 1998	Workplace skills plans, annual training reports, skills development levy records
Occupational Health and Safety Act 85 of 1993	Safety inspection records, incident and accident reports, risk assessments, health and safety committee records
Protection of Personal Information Act 4 of 2013	Personal information processing records, data subject consent records, POPIA compliance documentation
Electronic Communications and Transactions Act 25 of 2002	Electronic transaction records, electronic contract records, website-related records
Consumer Protection Act 68 of 2008	Consumer-related records, warranty records, complaint and dispute records
Financial Intelligence Centre Act 38 of 2001	Compliance records, customer due diligence records, FICA-related documentation (subject to applicable confidentiality requirements)

 

Section 7: Description of Categories of Records Held

7.1 Introduction

In terms of Section 51(1)(e) of PAIA, LandoSol (Pty) Ltd is required to describe the categories of records it holds. The categories set out below are intended to provide sufficient guidance to potential requesters to enable them to identify the records that may be relevant to their request. This is not an exhaustive list and should be read as a general guide.

Access to these records is subject to the provisions of PAIA and POPIA, and access may be refused on grounds set out in Section 10 of this Manual.

7.2 Human Resources and Employee Records

Sub-Category	Examples of Records
Employment Records	Employment contracts, offer letters, employee personal files, job descriptions
Payroll Records	Salary records, payslips, income tax certificates (IRP5s), payroll registers, remuneration schedules
Leave Records	Leave applications, approved leave records, leave balances, attendance registers
Performance Records	Performance reviews, key performance indicators (KPIs), performance improvement plans, disciplinary records, warnings
Recruitment Records	Job advertisements, curriculum vitae, employment applications, interview notes, background check records
Training and Development	Training records, skills development plans, training certificates, bursary agreements
Termination Records	Resignation letters, retrenchment records, retirement records, UIF records (UI-19), separation agreements

 7.3 Financial and Accounting Records

Sub-Category	Examples of Records
Financial Statements	Annual financial statements, management accounts, trial balances, general ledgers
Banking Records	Bank statements, payment records, electronic funds transfer records, bank reconciliations
Tax Records	Income tax returns, VAT returns, tax assessments, provisional tax records, PAYE records
Invoices and Receipts	Purchase and sales invoices, receipts, credit notes, delivery notes
Contracts and Agreements	Supplier contracts, service level agreements, purchase orders, quotes and tenders
Asset Registers	Fixed asset registers, depreciation schedules, insurance schedules for assets
Budget Records	Annual budgets, financial forecasts, variance reports, expenditure reports

7.4 Legal and Compliance Records

Sub-Category	Examples of Records
Company Statutory Records	Memorandum of Incorporation (MOI), share register, director records, CIPC filings, resolutions of directors and shareholders
Agreements and Contracts	All commercial contracts, legal agreements, non-disclosure agreements, joint venture agreements
Intellectual Property	Trademark registrations, patent records, copyright records, licensing agreements
Regulatory Compliance	Licences, permits, regulatory submissions, certificates of compliance
Insurance Records	Insurance policies, insurance schedules, claims records, broker correspondence
PAIA and POPIA Records	This PAIA Manual, personal information impact assessments, data processing agreements, consent records, data subject requests

7.5 Operational and Administrative Records

Sub-Category	Examples of Records
Customer Records	Client files, service agreements, client correspondence, quotations, project records
Supplier Records	Supplier files, vendor applications, purchase orders, supplier correspondence
Communication Records	Emails, letters, facsimiles, meeting minutes, board and committee minutes
IT Records	System configurations, IT infrastructure records, user access and permission records, software licence records
Marketing Records	Marketing materials, advertising campaigns, social media records, website analytics and content records
Property Records	Lease agreements, utility accounts, property maintenance records, occupation certificates

7.6 Personal Information Records (POPIA)

Sub-Category	Examples of Records
Employee Personal Information	Identity documents, passports, contact details, next-of-kin information, biometric data, medical information (where applicable)
Customer Personal Information	Names, contact details, identity numbers, transaction history, communication preferences
Supplier Personal Information	Contact details of sole proprietors and supplier representatives, banking details for payment
Visitor Records	Visitor logs, access control records, visitor identity records

Important Notice Regarding Personal Information Records Access to records containing personal information is subject to the provisions of both PAIA and POPIA. Records containing the personal information of third parties may be refused where disclosure would unreasonably infringe upon the right to privacy of that third party (Section 63 of PAIA). A data subject may access their own personal information without paying a request fee by submitting a request in the prescribed form.

Section 8: Request Procedure for Access to Records

8.1 Who May Request Access

Any person — whether a natural person or a juristic person (such as a company, close corporation, or trust) — may request access to records held by LandoSol (Pty) Ltd. Requests may be made in the following circumstances:

• Where the record is required for the exercise or protection of any right of the requester;
• By a data subject requesting access to their own personal information (no request fee is payable in this instance); or
• By an authorised representative acting on behalf of a requester, provided proof of authorisation is submitted with the request.

8.2 How to Submit a Request

All requests for access to records must be submitted using Form 2 (PPR 2) — the prescribed request form promulgated under the PAIA Regulations (GNR.757 of 2021). The completed form must be submitted to the Information Officer at the contact details provided in Section 3 of this Manual.

Requests submitted otherwise than on the prescribed Form 2 cannot be processed and will be returned to the requester with guidance on the correct procedure.

8.3 How to Obtain Form 2

The prescribed Form 2 (PPR 2) is available from the following sources:

• From the Information Officer of LandoSol (Pty) Ltd (contact details in Section 3);
• On the Company's website: www.landosol.co.za;
• From the Department of Justice and Constitutional Development: www.justice.gov.za; and
• From the Information Regulator: www.inforegulator.org.za.

8.4 Completing the Form

When completing Form 2, the requester must provide the following information:

• Full name and contact details of the requester;
• A description of the record(s) requested with sufficient detail to enable the Information Officer to identify the record;
• The form in which access is required (e.g., copy, inspection, transcription);
• The right being exercised or protected and an explanation of why access to the record is required for that purpose;
• If the requester is requesting access to personal information on behalf of another person: written proof of authority to act on that person's behalf; and
• If the requester is not the data subject: whether the request relates to the personal information of a third party, and if so, what steps the requester has taken to notify the third party.

8.5 Submitting the Form

The completed Form 2, together with proof of payment of the request fee (where applicable), must be submitted to the Information Officer by one of the following methods:

Method	Details
Email	rudolf@landosol.co.za or martin@landosol.co.za
Physical Delivery	134 Cascade Rd, Banners Rest, Port Edward, KZN, 4295

8.6 Request Fee

A non-refundable request fee of R140.00 must be paid before a request will be processed, unless the request relates to the requester's own personal information, in which case no request fee is payable. Proof of payment must accompany the submitted Form 2.

Note: Exemption from Request Fee No request fee is payable where a data subject requests access to their own personal information in terms of PAIA. However, access fees for reproduction and search may still apply.

 

8.7 Response Timeframes

LandoSol (Pty) Ltd will respond to a request within the following timeframes:

Timeframe	Description
30 days (standard)	The Information Officer will respond within 30 days from receipt of the complete request (and request fee where applicable).
30-day extension (Section 57)	An extension of a further 30 days may be claimed where the request requires a substantial amount of search and preparation work. The requester will be notified in writing if an extension is required and the reasons therefor.
Deemed refusal	If no decision is communicated within the prescribed timeframe, the request is deemed to have been refused and the requester may exercise their remedies as set out in Section 11 of this Manual.

8.8 Decision on the Request

Upon making a decision on the request, the Information Officer will notify the requester in writing using Form 3 (PPR 3), which will indicate:

• Whether access has been granted or refused;
• The access fee payable (if access is granted), and the manner of payment;
• The grounds for refusal (if access is refused) and the relevant section of PAIA under which the refusal is made; and
• The requester's right to seek external remedy, including the right to approach the Information Regulator or a court of law.

 

Section 9: Prescribed Fees

9.1 Request Fee

A non-refundable request fee of R140.00 is payable by a requester before the Information Officer will commence processing the request. This fee is not payable where the request relates to the requester's own personal information.

9.2 Deposit

Where the search and preparation of records for access is estimated to require more than six (6) hours, the Information Officer may require a deposit of not more than one-third of the anticipated access fee before processing the request further. The requester will be informed of the estimated deposit amount in writing.

9.3 Access Fees Schedule

Once access to a record has been granted, the following access fees apply, as prescribed in Annexure B of the PAIA Regulations (GNR.757 of 2021):

Type of Reproduction / Service	Prescribed Fee
Photocopy of a record (per A4 page)	R2.10 per page
Printed copy of a computer-generated record (per A4 page)	R2.10 per page
Copy of a record in computer-readable form — stiffy/USB disc	R7.50 per disc/device
Copy of a record in computer-readable form — compact disc (CD)	R70.00 per disc
Transcription of visual images (per A4 page)	R40.00 per page
Copy of visual images (video recording)	R60.00 per copy
Transcription of an audio record (per A4 page)	R20.00 per page
Copy of an audio record	R30.00 per copy
Search and preparation of records for disclosure (per hour or part thereof)	R30.00 per hour
Note Regarding Fees Fees are prescribed by the PAIA Regulations and may be updated by the Minister of Justice and Constitutional Development from time to time. Requesters should confirm current fees with the Information Officer at the time of submitting a request.

9.4 Waiver of Fees

The Information Officer may, in appropriate circumstances, waive the prescribed fees if:

• The requester demonstrates that payment of the fee would cause undue financial hardship; or
• The disclosure of the record is clearly in the public interest.

Requests for a waiver of fees must be made in writing, setting out the grounds upon which the waiver is sought. The Information Officer will consider all relevant circumstances before making a decision on the waiver request.

9.5 Payment Methods

Payment of the request fee and access fees must be made by one of the following methods:

• Electronic funds transfer (EFT) to LandoSol (Pty) Ltd's nominated bank account (banking details will be provided upon request to the Information Officer); and
• The requester must include their request reference number as the payment reference to enable the Company to match the payment to the request.

 

Section 10: Grounds for Refusal

10.1 Introduction

LandoSol (Pty) Ltd may refuse access to records only on the grounds specifically provided for in Sections 62 to 70 of PAIA. The Information Officer will not refuse a request arbitrarily and will apply the grounds for refusal strictly and in good faith. Where grounds for refusal exist, the Information Officer will communicate these in writing to the requester, including the specific section of PAIA under which refusal is made.

10.2 Mandatory Grounds for Refusal

LandoSol (Pty) Ltd must refuse access to a record under the following circumstances:

Ground	PAIA Reference	Description
Unreasonable disclosure of personal information	Section 63	Where disclosure would involve the unreasonable disclosure of personal information of a third party, including information about their financial, medical, personal, or other affairs.
Information supplied in confidence	Section 64	Where the record contains information supplied in confidence and the disclosure could reasonably be expected to prejudice the continued supply of similar information that is in the public interest.

10.3 Discretionary Grounds for Refusal

LandoSol (Pty) Ltd may refuse access to a record where disclosure would:

Ground	PAIA Reference	Description
Endanger life or safety	Section 62	Endanger the life or physical safety of an individual.
Third party privacy	Section 63	Prejudice the protection of the privacy of a third party who is a natural person, including information about their personal circumstances.
Commercial interests	Section 64	Prejudice the commercial interests of LandoSol (Pty) Ltd or a third party, including trade secrets, financial information, or proprietary information.
Fair trial rights	Section 65	Jeopardise the right of any person to a fair trial or the right to an impartial inquiry.
Law enforcement	Section 66	Prejudice or impair the effectiveness of any method or source used by an investigating authority in the prevention or detection of an offence.
Economic interests of the Republic	Section 67	Cause serious harm to the economic interests of the Republic of South Africa.
International relations	Section 68	Cause prejudice to the Republic of South Africa in its relations with foreign governments or international organisations.
Defence and security	Section 69	Harm the defence, security, or intelligence activities of the Republic of South Africa.

10.4 Severability

Where a record contains information which may be refused in terms of PAIA together with information in respect of which there is no ground for refusal, the Information Officer will provide access to the portion of the record that is not subject to refusal, after redacting or severing the portions that may be refused. This is in accordance with Section 28 of PAIA.

 

Section 11: Remedies and Rights of Appeal

11.1 Internal Appeal

LandoSol (Pty) Ltd is a private body. In terms of PAIA, the internal appeal mechanism (Part 4 of PAIA) applies only to public bodies and is not available for requests made to private bodies. A requester who is aggrieved by a decision of the Information Officer of a private body cannot lodge an internal appeal and must instead pursue external remedies as set out below.

11.2 External Remedies

A requester who is aggrieved by any decision of the Information Officer of LandoSol (Pty) Ltd may pursue one or more of the following external remedies:

1. Approach the Information Regulator to lodge a complaint in terms of POPIA, particularly where the request relates to the requester's own personal information or alleges a contravention of POPIA;
2. Apply to a competent court for appropriate relief in terms of Section 78 of PAIA. The court may, amongst other things, review the decision of the Information Officer and grant an order requiring access to be given; and
3. Lodge a complaint with the South African Human Rights Commission (SAHRC) regarding the exercise of rights under PAIA.

11.3 Information Regulator Contact Details

Detail	Information
Name	Information Regulator of South Africa
Physical Address	JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
Postal Address	P.O. Box 31533, Braamfontein, Johannesburg, 2017
Email	inforeg@justice.gov.za
Website	www.inforegulator.org.za
Telephone	010 023 5207

Section 12: Processing of Personal Information (POPIA Compliance)

12.1 Introduction

In terms of Section 51 of PAIA (as amended) and the requirements of POPIA, LandoSol (Pty) Ltd is required to describe how it processes personal information. LandoSol (Pty) Ltd, acting as a Responsible Party as defined in POPIA, is committed to processing personal information lawfully, fairly, and in a transparent manner that respects the dignity and privacy of all data subjects.

LandoSol (Pty) Ltd has taken all reasonable steps to ensure that its personal information processing activities comply with the eight conditions for lawful processing as set out in Chapter 3 of POPIA.

12.2 Categories of Data Subjects

LandoSol (Pty) Ltd processes the personal information of the following categories of data subjects:

• Current, former, and prospective employees;
• Current, former, and prospective customers and clients;
• Suppliers and service providers, including sole proprietors and individual representatives of juristic persons;
• Contractors and consultants engaged by the Company;
• Website visitors and persons who submit online enquiries;
• Directors, officers, and shareholders of the Company; and
• Any other person whose personal information is collected in the course of the Company's ordinary business activities.

 

12.3 Purposes of Processing

LandoSol (Pty) Ltd processes personal information for the following specific, explicit, and legitimate purposes:

Purpose	Description
Human Resources Management	Recruitment, employment administration, payroll processing, employee benefits, performance management, and termination of employment
Contract Administration	Entering into, performing, and managing contracts with clients, customers, suppliers, and service providers
Legal and Regulatory Compliance	Meeting obligations under applicable legislation, including PAIA, POPIA, tax legislation, and labour legislation
Financial Management	Invoicing, accounting, financial reporting, and tax compliance
Communication	Responding to enquiries, providing customer service, marketing communications (subject to data subject consent where required)
Information and System Security	Protecting the Company's information, systems, premises, and assets from unauthorised access or harm
Website Administration	Managing the Company's website, monitoring website usage, and responding to online enquiries

12.4 Conditions for Lawful Processing

LandoSol (Pty) Ltd processes personal information in accordance with the eight conditions for lawful processing under Chapter 3 of POPIA, as described below:

1. Accountability: The Information Officer of LandoSol (Pty) Ltd is responsible for ensuring that all personal information processing activities comply with POPIA and for implementing and maintaining appropriate compliance measures.
2. Processing Limitation: Personal information is collected only for a specific, explicitly defined, and legitimate purpose related to the Company's business activities. The collection of personal information is adequate, relevant, and not excessive for the purpose for which it is collected.
3. Purpose Specification: Personal information is processed only for the specific purpose for which it was collected. Data subjects are informed of the purpose of collection at or before the time of collection.
4. Further Processing Limitation: Personal information is not processed further in a manner that is incompatible with the original purpose of collection. Any further processing must be compatible with the original purpose, or the data subject must consent to such further processing.
5. Information Quality: LandoSol (Pty) Ltd takes reasonable steps to ensure that all personal information it processes is accurate, complete, not misleading, and kept up to date. Data subjects are encouraged to notify the Company of any changes to their personal information.
6. Openness: LandoSol (Pty) Ltd maintains documentation of all processing activities and informs data subjects of the purpose and manner in which their personal information is processed, in accordance with Sections 18 and 19 of POPIA.
7. Security Safeguards: LandoSol (Pty) Ltd implements appropriate, reasonable technical and organisational measures to protect personal information against loss, damage, unauthorised destruction, and unlawful access or processing (see Section 13 of this Manual).
8. Data Subject Participation: Data subjects have the right to request access to, correction of, or deletion of their personal information. The procedure for exercising these rights is set out in Section 14 of this Manual.

12.5 Retention and Destruction of Personal Information

LandoSol (Pty) Ltd retains personal information for as long as necessary to fulfil the purpose for which it was collected, or for such longer period as may be required or permitted by applicable legislation (for example, the Companies Act, income tax legislation, or labour legislation). Once personal information is no longer required, it is destroyed or de-identified in a secure manner that prevents any subsequent processing, reconstruction, or recovery.

12.6 Sharing of Personal Information

LandoSol (Pty) Ltd may share personal information with the following categories of third parties, where lawful and necessary:

• Service providers acting as Operators under POPIA (for example, payroll service providers, IT support providers, cloud storage providers), provided that such operators are bound by written agreements requiring them to comply with POPIA;
• Government and regulatory authorities, where required or authorised by law (for example, SARS, the Department of Employment and Labour, or the Information Regulator);
• Professional advisors, including attorneys, auditors, and accountants, subject to applicable confidentiality obligations; and
• Third parties where the data subject has provided explicit consent to such sharing.

LandoSol (Pty) Ltd does not sell, rent, or trade personal information. All operators who process personal information on behalf of LandoSol (Pty) Ltd are required to comply with POPIA and are bound by appropriate data processing agreements.

12.7 Transborder Flows of Personal Information

LandoSol (Pty) Ltd will only transfer personal information to third parties located outside of the Republic of South Africa in compliance with Section 72 of POPIA. Such transfer will only occur where:

• The recipient country has adequate data protection laws that provide a comparable level of protection to POPIA;
• The data subject has provided informed and specific consent to the transfer;
• The transfer is necessary for the performance of a contract between the data subject and LandoSol (Pty) Ltd;
• The transfer is for the benefit of the data subject and it is not reasonably practicable to obtain consent, and the data subject would likely consent if asked; or
• All other applicable requirements of Section 72 of POPIA are satisfied.

Section 13: Information Security Measures

13.1 Security Safeguards

In compliance with Section 19 of POPIA, LandoSol (Pty) Ltd implements appropriate, reasonable technical and organisational measures to prevent the following in respect of personal information processed by or on behalf of the Company:

• Loss of, damage to, or unauthorised destruction of personal information; and
• Unlawful access to or processing of personal information.

The security measures implemented by LandoSol (Pty) Ltd take into account the nature of the personal information processed, reasonably foreseeable risks, the size of the organisation, and the cost and availability of appropriate security technologies.

 

13.2 Security Measures (Non-Exhaustive)

The following security measures are implemented by LandoSol (Pty) Ltd, amongst others:

Security Measure	Description
Access Controls	Role-based access controls and user authentication on all information systems to limit access to personal information to authorised personnel only
Password Policies	Password complexity requirements, regular password updates, and multi-factor authentication (MFA) where applicable
Physical Security	Physical access controls at Company premises to prevent unauthorised access to facilities where personal information is stored
Secure Storage	Secure storage and handling of physical records containing personal information, including locked cabinets and secure filing systems
Secure Disposal	Secure shredding and destruction of physical records and secure deletion of electronic records once no longer required
Staff Training	Regular training and awareness programmes for employees on data protection, information security, and POPIA compliance
Incident Response	Documented incident response procedures for detecting, reporting, and managing data breaches and security incidents
Operator Oversight	Contractual requirements for operators (service providers) to maintain appropriate security measures when processing personal information on behalf of LandoSol (Pty) Ltd

13.3 Data Breach Notification

In the event of a data breach or security compromise that may result in harm to a data subject, LandoSol (Pty) Ltd will, in compliance with Section 22 of POPIA:

• Notify the Information Regulator as soon as reasonably possible after becoming aware of the compromise; and
• Notify the affected data subjects where required, unless the Information Regulator directs otherwise.

Notification to data subjects will be made in writing and will include: a description of the possible consequences of the breach, a description of the measures taken or to be taken to address the breach, and a recommendation regarding steps that data subjects should take to mitigate any potential prejudice.

Section 14: Rights of Data Subjects

14.1 Rights Under POPIA

Data subjects whose personal information is processed by LandoSol (Pty) Ltd have the following rights in terms of POPIA and PAIA:

Right	Description	Applicable Form / Mechanism
Right of Access	The right to request confirmation of whether LandoSol (Pty) Ltd processes the data subject's personal information, and to request access to that information (Section 23 of POPIA)	Form 2 (PAIA PPR 2) — no request fee payable for own personal information
Right to Correction or Deletion	The right to request the correction or deletion of personal information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or unlawfully obtained (Section 24 of POPIA)	POPIA Prescribed Form 2 (Objection) or written request to the Information Officer
Right to Object	The right to object, on reasonable grounds, to the processing of personal information (Section 11(3) of POPIA)	POPIA Prescribed Form 1 (Objection to Processing)
Right to Lodge a Complaint	The right to lodge a complaint with the Information Regulator regarding any alleged interference with the protection of personal information by LandoSol (Pty) Ltd (Section 74 of POPIA)	Information Regulator Complaint Form (available at www.inforegulator.org.za)
Right to Withdraw Consent	The right to withdraw previously given consent to the processing of personal information at any time, subject to legal or contractual restrictions (Section 11(4) of POPIA)	Written request addressed to the Information Officer

 

14.2 How to Exercise These Rights

Data subjects may exercise any of the rights set out in this Section by contacting the Information Officer at the contact details provided in Section 3 of this Manual. Requests should be made in writing and should include:

• The full name and contact details of the data subject;
• A clear description of the right being exercised;
• Sufficient information to enable the Information Officer to identify the personal information in question; and
• Where the request is made by an authorised representative: proof of authority to act on behalf of the data subject.

The Information Officer will acknowledge receipt of the request and respond within a reasonable time, and in any event within the timeframes prescribed by PAIA and POPIA.

 

Section 15: Availability and Updating of This Manual

15.1 Availability

This Manual is made available to any person who requests it, free of charge, in the following ways:

• On the Company's website at www.landosol.co.za (available as a free download at all times);
• At the Company's registered office, available for inspection during normal business hours upon reasonable notice;
• From the Information Officer upon written request at the contact details provided in Section 3 of this Manual; and
• A copy of this Manual has been submitted to the Information Regulator in terms of PAIA.

15.2 Language

This Manual is currently available in English. LandoSol (Pty) Ltd endeavours to make this Manual available in other official languages of the Republic of South Africa upon reasonable request. Requests for this Manual in another official language should be directed to the Information Officer.

15.3 Review and Update

This Manual will be reviewed and updated in the following circumstances:

Trigger	Description
Annual Review	This Manual will be reviewed and updated annually, on or before June of each year. The next scheduled review date is June 2027.
Legislative Change	Where there is a material change in the provisions of PAIA, POPIA, or any other legislation that materially affects the content of this Manual, the Manual will be updated accordingly.
Operational Change	Where there is a material change in the Company's information management practices, record-keeping systems, or categories of records held, the Manual will be updated to reflect such changes.
Regulatory Instruction	Where the Information Regulator directs LandoSol (Pty) Ltd to update or amend this Manual, such instruction will be complied with promptly.

The current version of this Manual is Version 1.0, dated June 2026. All previous versions of this Manual are superseded by this version.

ANNEXURE A Request for Access to Records — Form 2 (PPR 2)

Incorporation by Reference The prescribed Form 2 (PPR 2 — Request for Access to a Record of a Private Body) as promulgated under the PAIA Regulations (GNR.757 of 2021) is incorporated by reference into this Manual. A copy of the official Form 2 is available from the Information Officer, on the Company's website at www.landosol.co.za, or from the Department of Justice and Constitutional Development at www.justice.gov.za. The template below sets out the required fields for reference purposes.

PROMOTION OF ACCESS TO INFORMATION ACT 2 OF 2000
 REQUEST FOR ACCESS TO A RECORD OF A PRIVATE BODY
 [SECTION 53(1) — REGULATION 10]
 

DOWNLOAD FORM 2 (PPR 2)

To be submitted to: The Information Officer/ Deputy Information Officer, LandoSol (Pty) Ltd

ANNEXURE B Prescribed Fees Schedule

The following fees are prescribed under Annexure B of the PAIA Regulations (GNR.757 of 2021). Fees are subject to amendment by the Minister of Justice and Constitutional Development. All amounts are in South African Rand (ZAR). Requesters are encouraged to confirm current fees with the Information Officer at the time of submitting a request.

B.1 Request Fee

Description	Amount
Non-refundable request fee payable before processing commences	R140.00
Request fee where request relates to requester's own personal information	NIL

B.2 Access Fees

Type of Reproduction / Service	Prescribed Fee
Photocopy of a record (per A4 page)	R2.10 per page
Printed copy of a computer-generated record (per A4 page)	R2.10 per page
Copy of a record in computer-readable form — stiffy/USB disc	R7.50 per disc/device
Copy of a record in computer-readable form — compact disc (CD)	R70.00 per disc
Transcription of visual images (per A4 page)	R40.00 per page
Copy of visual images (video recording)	R60.00 per copy
Transcription of an audio record (per A4 page)	R20.00 per page
Copy of an audio record	R30.00 per copy
Search and preparation of records for disclosure (per hour or part thereof)	R30.00 per hour

B.3 Deposit

Description	Amount
Deposit payable where search and preparation is estimated to exceed 6 hours (maximum one-third of anticipated access fee)	Not more than 1/3 of estimated access fee

Source: Promotion of Access to Information Act Regulations, Government Notice Regulation 757 of 9 July 2021 (GNR.757 of 2021), Annexure B.

ANNEXURE C Information Regulator Contact Details

The Information Regulator of South Africa is an independent body established in terms of Section 39 of POPIA to, amongst other things, monitor and enforce compliance with both POPIA and PAIA. Requesters and data subjects who are aggrieved by a decision of the Information Officer of LandoSol (Pty) Ltd may approach the Information Regulator for assistance.

Detail	Information
Full Name	Information Regulator of South Africa
Physical Address	JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
Postal Address	P.O. Box 31533, Braamfontein, Johannesburg, 2017
Complaints Email	inforeg@justice.gov.za
PAIA-Specific Email	PAIAComplaints@inforegulator.org.za
POPIA-Specific Email	POPIAComplaints@inforegulator.org.za
Website	www.inforegulator.org.za
Telephone	010 023 5207

SAHRC Contact Details

Detail	Information
Full Name	South African Human Rights Commission (SAHRC)
Physical Address	Braampark Forum 2, 33 Hoofd Street, Braamfontein, 2017
Website	www.sahrc.org.za
Telephone	011 877 3600
PAIA Guide Email	paia@sahrc.org.za

Disclaimer

Legal Disclaimer 1.  Good Faith Compliance: This PAIA Manual has been prepared by LandoSol (Pty) Ltd in good faith for compliance with the requirements of Section 51 of the Promotion of Access to Information Act 2 of 2000 and the Protection of Personal Information Act 4 of 2013. While every reasonable effort has been made to ensure the accuracy and completeness of the content of this Manual, LandoSol (Pty) Ltd does not warrant that this Manual is free from errors or omissions. 2.  Right to Update: LandoSol (Pty) Ltd reserves the right to amend, update, or replace this Manual at any time, without prior notice, to reflect changes in legislation, regulatory requirements, or the Company's information management practices. The latest version of this Manual will be published on the Company's website at www.landosol.co.za. 4.  Not Legal Advice: This Manual does not constitute legal advice and is not a substitute for professional legal counsel. The information contained herein is of a general nature and is intended for general compliance guidance purposes only. LandoSol (Pty) Ltd and any person involved in the preparation of this Manual accept no liability for any loss or damage arising from reliance upon the contents of this Manual. 5.  Legal Advice: Any person requiring specific legal advice regarding access to information, data protection, privacy rights, or any other legal matter should consult a qualified attorney or legal advisor. The Information Officer of LandoSol (Pty) Ltd is not in a position to provide legal advice to requesters or data subjects. 6.  Applicable Law: This Manual is governed by and must be interpreted in accordance with the laws of the Republic of South Africa, including PAIA and POPIA as amended from time to time.

Approved and adopted by:

MARTHINUS VISSER

Director — LandoSol (Pty) Ltd

Date: 1 June 2026 

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