PRIVACY POLICY

Pantheon Advisory (Pty) Ltd, hereinafter called Pantheon Advisory, acknowledge the importance of protecting your personal information and your right to keep it private.

This Privacy Policy illustrates how Pantheon Advisory protects the personal information that is provided to it by this website’s users.

Personal information

Our definition of “personal information” is as set out in the Protection of Personal Information Act, 2013 (POPIA)

Collecting of personal information

We may collect personal information in order to :

• identify you;
• provide the services and products you have requested for;
• process requests or instructions you give us;
• enhance the services we provide to you;
• follow the laws of South Africa;
• prevent fraud;
• for reasons permitted by POPIA or any other regulatory instrument;
• to improve our services and the user experience of our website.

We will keep your personal information only for as long as it’s necessary to perform the above actions or as permitted by law.

You may only give us personal information that is lawfully yours to give. By providing us with personal information, either to register or inquire about a service, you consent to us processing and using the information you provided. 

Sharing of Personal Information

We will not sell or rent any identifiable personal information of our users to third parties.

We may share your personal information with our business partners or service providers if necessary to provide you with the products or services you requested or inquired about.  

Pantheon Advisory may disclose aggregate information about our users. Aggregate information does not identify you personally but provides general information about our user population. 

Electronic Communications

By visiting this website and receiving electronic information or communication by electronic means from this website, you consent to its agreements, notices, and disclosures, which indicate that any legal requirements have been satisfied.

Electronically collected information

We may use cookies (small electronic text files stored in your browser) and other techniques to monitor your activities on our website. These tools collect information that enables the website to recognise you and inform us about your usage of our website and our web-related products and services. This, in turn, assists us in tailoring our website to suit your interests and needs better.

Additionally, cookies assist us in retrieving information once you have logged in or in linking your browsing information to you and your personal information, such as when you register for a service. We may employ a persistent cookie (a cookie that remains linked to your browser) to record your details, allowing us to recognise you upon your return to our website.

Cookies alone cannot be used to ascertain your identity and they do not harm your computer. You can configure your browser to notify you upon receiving a cookie, enabling you to decide whether to accept it. Opting not to accept cookies from our website may restrict its functionalities or performance.

Changes to the Privacy Policy

Pantheon Advisory reserves the right to change the Privacy Policy on an ad hoc basis at its sole discretion. We are not responsible for the content or privacy practices of non-Pantheon Advisory websites to which it refers.

Contact information

Should you not be satisfied with the information above or should any information or any of your personal information be found to be untrue or incorrect, please notify us at the following email address: info@pantheonlife.co.za

COMPLAINTS PROCESS

Should you have any complaint, please submit your complaint to Pantheon Advisory at:

Phone: 0850 101 038

E-mail: complaints@pantheonlife.co.za

Website: www.pantheonlife.co.za

Please provide us with as much information as possible, for instance

• Your ID number
• The Policy Number / Claim Number
• Your Contact Details
• All the details / dates and supporting documents that can help us resolve your complaint efficiently.

When you submit a complaint, we shall acknowledge receipt thereof within 1 working day and keep you informed of any progress we make (or any additional information we may need)

Should you not be satisfied with the response received, you may lodge a complaint with the National Financial Ombudsman at:

Phone: 0860 800 900

Whatsapp: 0660 473 157

E-mail: info@nfosa.co.za

Website: www.nfosa.co.za    

You may also contact the FAIS Ombudsman at:

Phone: 012 762 5000

Sharecall: 0860 066 3274

E-mail: info@faisombud.co.za

Website: www.faisombud.co.za        

CONFLICT OF INTEREST MANAGEMENT POLICY

Background

The Applicant is a private company applying for a Category 1 FSP License.  The FSP will be providing advice and intermediary services as stipulated in the Business Plan of the business.

Section 3A(2)(a) of the General Code of Conduct stipulates that every provider, other than a representative, must adopt, maintain and implement a conflict of interest management policy that complies with the provisions of the Act. The policy is to provide for mechanisms in place at Pantheon Advisory (Pty) Ltd to identify, mitigate and manage the conflicts of interest to which the Pantheon Advisory (Pty) Ltd is a party. This Conflict of Interest Management Policy is designed as prescribed in the General Code of Conduct for Financial Services Providers and Representatives as amended by Board Notice 58 of 2010 and Board Notice 146 of 2014.

Objective of the Policy

This Conflict of Interest Management Policy intends to document our existing conflict of interest management procedures in a simple form as required by the Financial Sector Conduct Authority.

In terms of the Financial Advisory and Intermediary Services Act, 2002, Pantheon Advisory (Pty) Ltd are required to maintain and operate effective organisational and administrative arrangements with a view to taking all reasonable steps to identify, monitor and manage conflict of interest. Pantheon Advisory (Pty) Ltd have put in place a policy to safeguard its clients’ interests and ensure fair treatment of clients.

All providers, key individuals, representatives, associates and administrative personnel will commit to such policy and the processes will be monitored on an ongoing basis.

Pantheon Advisory (Pty) Ltd will keep and maintain a register in which all actual or potential conflicts are recorded.

Mission Statement on Conflict of Interest

 Pantheon Advisory (Pty) Ltd are committed to ensuring that all business is conducted in accordance with good business practice. Pantheon Advisory (Pty) Ltd will conduct business in an ethical and equitable manner and in a way that safeguards the interests of all stakeholders to minimise and manage all real and potential conflicts of interests. Like any financial services provider, Pantheon Advisory (Pty) Ltd are potentially exposed to conflicts of interest in relation to various activities. However, the protection of our clients’ interests is our primary concern and so our policy sets out how:

we will identify circumstances which may give rise to actual or potential conflicts of interest entailing a material risk of damage to our clients’ interests;

we have established appropriate structures and systems to manage those conflicts; and

we will maintain systems in an effort to prevent damage to our clients’ interests through identified conflict of interest.

Understanding the Definitions

Conflict of Interest

A conflict of interest may occur when in rendering a financial service to you we do not act objectively or do not render an unbiased or fair service to you or do not act in your interests, including but not limited to:

1. a) A financial interest
2. b) An ownership interest
3. c) Any relationship with a third party.

A Financial Interest

Any cash, cash equivalent, voucher, gift, service, advantage, benefit, discount, domestic or foreign travel, hospitality, accommodation, sponsorship, valuable consideration, other incentive or valuable consideration (exceeding R1000 per annum) other than –

An ownership interest

Training, that is not exclusively available to a selected group of providers or representatives, on –

Products and legal matters relating to those products;

General financial and industry information;

Specialised technological systems of a third party necessary for the rendering of a financial service, but excluding travel and accommodation associated with that training.

An Ownership Interest

(i)   any equity or proprietary interest for which a fair value was paid on acquisition other

       than such an interest held by a nominee;

(ii)  includes any dividend, profit share or similar benefit derived from such interest. 

Fair Value

Has the meaning assigned to it in the financial reporting standards adopted or issued under the Companies Act, 61 of 1973.

New Entrant

Is a person who has never been authorised as a financial services provider or appointed as a representative by any FSP.

Sign-On Bonus

Is any financial interest offered or received directly or indirectly, upfront or deferred, and with or without conditions, as an incentive to become a provider.

Here a financial interest includes but is not limited to a:

1) Loan, advance, credit facility or any other similar arrangement; or

2) Compensation for the

– Potential or actual loss of any benefit including any form of income, or part thereof; or

– Cost associated with the establishment of a provider’s business or operations, including the sourcing of business, relating to the rendering of financial services;

What may we Give and Receive

We confirm that we will only receive or offer financial interest from or to the aforesaid providers or other third party in the form of:

Remuneration Policy

Our remuneration policy is either fixed salaries paid, or based on as-and-when commission payable on the business placed onto our books. This will be a recurring commission earning on active policies which advisors are servicing. From this income the company covers overhead expenses, reinvest into the company and pay the owners of the business for their services. The wellbeing of the company and its client’s is at the centre of our approach and all expenditure are in line with our solvency requirements as put forth by legislation.

Processes and Internal Controls

Identification of Conflict of Interest

To adequately manage conflicts of interest we must identify all relevant conflicts     timeously.  In determining whether there is or may be a conflict of interest to which the policy applies, Pantheon Advisory (Pty) Ltd considers whether there is a material risk of damage to the client, taking into account whether Pantheon Advisory (Pty) Ltd or its representative, associate or employee:

is likely to make a financial gain, or avoid a financial loss, at the expense of the client;

has an interest in the outcome of a service provided to the client or of a transaction carried out on behalf of the client, which is distinct from the client’s interest in that outcome;

has a financial or other incentive to favour the interest of another client, group of clients or any other third party over the interests of the client;

receives or will receive from a person other than the client, an inducement in relation to a service provided to the client in the form of monies, goods or services, other than the legislated commission or reasonable fee for that service.

Our policy defines possible conflicts of interest as, inter alia:

conflicts of interest between Pantheon Advisory (Pty) Ltd and the client;

conflicts of interest between our clients if we are acting for different clients and the different interests conflict materially;

conflicts of interest where associates, product suppliers, distribution channels or any other third party is involved in the rendering of a financial service to a client;

storing confidential information on clients which, if we would disclose or use, would affect the advice or services provided to clients. We may only receive commissions authorised in terms of applicable legislation.

Pantheon Advisory (Pty) Ltd maintain an index of potential conflict risks, taking into consideration all business areas and income streams. The index is updated with all new conflicts identified, and to ensure completeness is reviewed on an annual basis. Apart from the register of actual conflict of interests, record must be kept of potential conflict of interest and closely monitored by the KI/assigned staff.

All employees, including internal compliance officers and management, are responsible for identifying specific instances of conflict and are required to notify the Key Individual of any conflicts they become aware of. The Key Individual will assess the implications of the conflict and how the conflict should be managed and act impartially to avoid a material risk of harming clients’ interests.

Measurement for avoidance and mitigation of Conflict of Interests

Create awareness and knowledge of applicable stipulations of the General Code of Conduct and relevant legislation relating to conflict of interest, through training and educational material.

Ensure understanding and adoption of conflict of interest policy and management measures by all employees, representatives and associates.

Carry out regular inspections on all commissions, remuneration, fees and financial interests proposed or received in order to avoid non-compliance.

Keep a register of conflicts of interest.

Once a conflict of interest has been identified it needs to be appropriately and adequately managed.

The Key Individual will assess each conflict, including whether the conflict is actual or perceived, what the value of the conflict or exposure is and the potential reputational risk. Compliance and management then agree on the controls that need to be put in place to manage the conflict.

• Disclosure
  Where there is no other way of managing a conflict, or where the measures in place do not sufficiently protect clients’ interests, the conflict must be disclosed to allow clients to make an informed decision on whether to continue using our service in the

situation concerned. In all cases, where appropriate and where determinable, the monetary value of non-cash inducements will be disclosed to clients. The Key Individual will ensure transparency and manage conflict of interests. Conflicts or Potential Conflicts of Interest will be either disclosed in the Client advice record, the disclosure letter, or by means of a separate disclosure.

• Publication
  We will publish our conflict of interest management policy in appropriate media and ensure that it is easily accessible for public inspection at all reasonable times. Provide details e.g. our COI policy is available in hard copy in the compliance file/stored electronically. A copy will be provided on the client’s request.
• Declining to act
  We may decline to act for a client in cases where we believe the conflict of interest cannot be managed in any other way.

Ongoing monitoring of Conflict of Interest Management

This policy will be reviewed annually and must be included in your annual FSCA compliance report, containing details “…on at least the implementation, monitoring and compliance with, and the accessibility of the conflict of interest management policy.”

Edward Bell  will be responsible for supervision and monitoring of this policy as well as the process to be followed e.g. inspection of new business transactions, client interviews, discussion with product providers, etc. The key individual or staff member in charge of supervision and monitoring of this policy will regularly monitor and assess all related matters.

Training and Staff

All employees and representatives are required to read Board Notice 58 of 2010 together with Board Notice 146 of 2014 as well as this policy and to sign a statement to the effect that they have done so and fully understand the provisions of all three documents and the application thereof.

Comprehensive training on the Conflict of Interest policy will be provided to all employees and representatives as part of specific and/or general training on the FAIS Act. Training will be incorporated as part of all new appointees’ induction and refresher training provided on an annual basis.

The Key Individual, Edward Bell , will conduct ad hoc checks on business transactions to ensure the policy has been complied with.

The Compliance Officer will include monitoring of the Conflict of Interest policy as part of his/her general monitoring duties and will report thereon in the annual compliance report. 

The compliance function is outsourced to an external Compliance company with no shareholding in this FSP. The Compliance practice functions objectively and sufficiently independently of the FSP and avoids conflicts of interest.

Non-compliance will be subject to disciplinary procedures in terms of FAIS and employment conditions and can ultimately result in debarment or dismissal as applicable.

Avoidance, limitation or circumvention of this policy via an associate will be deemed non-compliance.

This policy shall be reviewed annually and updated if applicable.

Representative Incentives

We confirm we will not offer any financial interest to our key individuals or representatives for-

(i)   favouring quantity of business over quality of service; or

(ii)   giving preference to a specific product supplier where more than one supplier can be  

       recommended to a client; or

(iii)  giving preference to a specific product of a supplier where more than one product of that

       supplier can be recommended.

Sign-On Bonus

We do not offer a sign-on bonus to any person other than a new entrant, as an incentive to become a Category I provider that is authorised or appointed to give advice.

Only applicable to CAT I providers that are authorised to give advice

As a Category I provider that is we do not receive a sign-on bonus from any person.

Registers

With regard to existing third-party relationships, being the product suppliers listed in authorised or appointed to give advice, we confirm that

our Contact Stage Disclosure letter, we confirm that we do not have an ownership interest or are subject to exclusive training nor are there any other circumstances which could lead to a potential conflict of interest.  Should any conflicts arise with regard to any of these, prior to entering into any business transaction with you, we undertake to disclose these in the registers below.

Pantheon Advisory (Pty) Ltd have implemented the registers below:

1. Nature and Extent of Ownership interests
2. Financial Interest Received
3. Nature and Extent of Business Relationships

At Pantheon Advisory (Pty) Ltd we believe in open, honest and transparent interactions with our clients. In the course of our business activities, situations may arise whereby we may become entitled to certain financial interests supplied by external parties in addition to the commission that we earn or the fees that we charge.

At Pantheon Advisory (Pty) Ltd we take pride therein that our advice is objective and free of external influence, but wish to disclose to you, our valued client, that we have received the following financial interests and wish to disclose the value and the reason for receiving the financial interests.

We do not believe that the financial interests received constitute a conflict of interest, but would gladly address any concerns you may have. Please refer to Annexure 1 to this register for a complete list.

We may also enjoy a preferred status with one or more of the product supplier companies with whom we hold contracts. This status allows us and our customers certain benefits when dealing with these providers.

We similarly make every effort to ensure that our advice is not influenced by our status with any one product supplier, but believe that disclosure of these business relationships and the benefits they include, allow you to make informed decisions. Please refer to Annexure 2 for complete details of these business relationships.

In accordance with the General Code of Conduct we are required to disclose any ownership interest we may have in external parties. These are contained in Annexure 3.Masthead Membership

We are proud to state that we are members of the Masthead Financial Advisors Association. This association is a voluntary body of independent financial advisors, regulated by its own constitution and code of conduct. This code of conduct requires its members to adhere to ethical and professional standards and to act in the best interest of our clients.

As members of the Association we may become entitled to certain discounts by virtue of our membership.

The Masthead Financial Advisors Association holds 25% of the issued share capital in Masthead (Pty) Ltd, which is a separate legal entity that specialises in providing support services to independent financial services intermediaries. We have contracted with Masthead (Pty) Ltd to deliver certain services to us, including compliance services. For these services we pay a monthly service fee.

For the sake of full disclosure, please note that we derive no financial interest from Masthead other than services that are paid for.

Annexure 1

Financial Interest Received

Any cash, cash equivalent, voucher, gift, service, advantage, benefit, discount, domestic or foreign travel, hospitality, accommodation, sponsorship, valuable consideration, other incentive or valuable consideration (exceeding R1000 per annum) other than –

An ownership interest;

Training, that is not exclusively available to a selected group of providers or

representatives, on –

Products and legal matters relating to those products;

General financial and industry information;

Specialised technological systems of a third party necessary for the rendering of a financial service, but excluding travel and accommodation associated with that training.

Annexure 2

Business Relationship / Association

List the different product suppliers, outsource agreements and referral agreements you have with each company, and any associate in relation to a person

Annexure 3

Ownership Interest

Any equity or proprietary interest, for which fair value was paid by the owner at the time of acquisition, other than equity or a proprietary interest held as an approved nominee on behalf of another person. This includes any dividend, profit share or similar benefit derived from that equity or ownership interest.

PROMOTION TO ACCESS OF INFORMATION

PAIA MANUAL

For a copy of our PAIA manual, please contact our Information Officer at vineshchiba@pantheonlife.co.za.  To request access to a record, please complete and email this form to: vineshchiba@pantheonlife.co.za.  We will send respond with this form  to confirm the outcome of your request and fees payable.

DATE OF REVISION:

1. 1. LIST OF ACRONYMS AND ABBREVIATIONS

“COO” – Chief Operations Officer

“DIO” – Deputy Information Officer;

“IO“ – Information Officer;

“Minister” – Minister of Justice and Correctional Services;

“PAIA” – Promotion of Access to Information Act No. 2 of 2000( as Amended;

“POPIA” – Protection of Personal Information Act No.4 of 2013;

“Regulator” – Information Regulator; and

“Republic” – Republic of South Africa

2. PURPOSE OF 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. 

3. KEY CONTACT DETAILS FOR ACCESS TO INFORMATION OF PANTHEON ADVISORY

Chief Operations Officer

Name: Vinesh Chiba

Tel: 083 271 2868

Email: vineshchiba@pantheonlife.co.za

Access to information general contacts

Email: vineshchiba@pantheonlife.co.za

National or Head Office

Physical Address:       

Unit 29, First Floor Right,

Cambridge Office Park,

5, Bauhinia Street,

Highveld Techno Park,

Centurion,

0157

Postal Address:                                         

Postnet Suite 107,

Private Bag X32,

Highveld Park

Gauteng, 0169

Telephone:      0860 101 038

Email:              vineshchiba@pantheonlife.co.za

Website:          www.pantheonlife.co.za

4. 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 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 the public body.
     • the manner and form of a request for-
       • access to a record of a public body contemplated in section 11[1]; and
       • access to a record of a private body contemplated in section 50[2];
     • the assistance available from the IO 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
       • 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 14[3] and 51[4] requiring a public body and private body, respectively, to compile a manual, and how to obtain access to a manual;
     • the provisions of sections 15[5] and 52[6] providing for the voluntary disclosure of categories of records by a public body and private body, respectively;
     • the notices issued in terms of sections 22[7] and 54[8] regarding fees to be paid in relation to requests for access; and
     • the regulations made in terms of section 92[9].

• Members of the public can inspect or make copies of the 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 the Information Officer;
  • from the website of the Regulator (https://www.justice.gov.za/inforeg/).

• A copy of the Guide is also available in the following two official languages, for public inspection during normal office hours-
  • Afrikaans and English

5. CATEGORIES OF RECORDS OF PANTHEON ADVISORY WHICH ARE AVAILABLE WITHOUT A PERSON HAVING TO REQUEST ACCESS

The following records held by the private body are available without a person having to request access by completing Form. These are mostly records that may be available on the website and a person may download or request by sending an email or a letter. The following records are automatically available without having to submit a formal request to access the information in terms of the Act. 

Complaints Policy

Conflict of Interest Management Policy,

Privacy Policy,

FSP License

6. DESCRIPTION OF THE RECORDS OF PANTHEON ADVISORY WHICH ARE AVAILABLE IN ACCORDANCE WITH ANY OTHER LEGISLATION AND/OR WHEN COMPLETING A REQUEST FOR INFORMATION FORM.

Administrative Records

These include, but are not limited to the following:

• the FSP’s license;
• the FSP’s Policies ;
• the FSP’s FICA RMCP;
• any personal records provided to the FSP by its personnel;
• any records which a third party has provided to the FSP about any of its personnel.

Human Resources Records

These include, but are not limited to the following:

• any personal records provided to the FSP by its personnel;
• any records which a third party has provided to the FSP about any of its personnel;
• conditions of employment and other personnel-related contractual and quasi-legal records
• internal evaluation and training records
• other internal records and correspondence

Client-related Records

These include, but are not limited to the following:

• advice records
• operational records
• information technology
• marketing records
• internal correspondence
• product records
• statutory records
• internal policies and procedures
• records held by officials of the FSP

Financial Records

These include, but are not limited to the following:

• financial statements
• audit records
• assets inventory

Other Parties

The FSP may possess records pertaining to other parties, including without limitation, contractors, suppliers, subsidiary/holding companies, joint venture companies and other financial services providers. 

These records include:

• service level agreements
• financial records
• correspondence

Alternatively, such other parties may possess records which can be said to belong to the FSP. The following records fall under this category:

• personnel, client or FSP records which are held by another party
• records held by FSP pertaining to other parties, including without limitation:
• financial records
• correspondence
• contractual records
• records provided by the other party

7. PROCESSING OF PERSONAL INFORMATION

• Purpose of Processing Personal Information

Our business processes personal information for purposes of providing sound financial planning, providing advice and intermediary services as well as to process product provider applications in order to implement contractual agreements.

7.2       Description of the categories of Data Subjects and of the information or categories of information relating thereto

Below is the categories of data subjects and the description of the nature or categories of the personal information to be processed.

7.3       The recipients or categories of recipients to whom the personal information may be supplied

7.4       Planned transborder flows of personal information

Client information is stored on cloud servers and with external service providers that allows us to render our services to clients. Some personal information may be stored in the cloud outside the Republic in jurisdictions all over the world where cloud service providers deem safe and secure.

7.5          General description of Information Security Measures to be implemented by the responsible party to ensure the confidentiality, integrity and availability of the information

Our data storage cloud services are secured by Data Encryption; Anti-virus and Anti-malware Solutions and password protection.

8. AVAILABILITY OF THE MANUAL

• A copy of the Manual is available-
  • on ( specify the website), if any;
  • head office of Pantheon Advisory for public inspection during normal business hours;
  • to any person upon request and upon the payment of a reasonable prescribed fee; and
  • to the Information Regulator upon request.

8.2 A fee for a copy of the Manual, as contemplated in annexure B of the Regulations, shall be payable per each A4-size photocopy made.

9. UPDATING OF THE MANUAL

The head of a Pantheon Advisory will on a regular basis update this manual.

Issued by:
Vinesh Chiba
Information Officer 

FOOTNOTES/REFERENCES

[1] 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. 

[1] Section 50(1) of PAIA- A requester must be given access to any record of a private body if-

that record is required for the exercise or protection of any rights;

that person complies with 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.

[1] 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. 

[1] 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.

[1] 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

[1] 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

[1] 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.

[1] 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. 

[1] 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.

[1] 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.

[2] Section 50(1) of PAIA- A requester must be given access to any record of a private body if-

1. that record is required for the exercise or protection of any rights;
2. that person complies with the procedural requirements in PAIA relating to a request for access to that record; and
3. access to that record is not refused in terms of any ground for refusal contemplated in Chapter 4 of this Part.

[3] 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.

[4] 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.

[5] 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

[6] 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

[7] 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.

[8] 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.

[9] 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.”