PAIA Manual | BXE � Promotion of Access to Information Act Manual Platform Features How It Works About Contact Get Started PAIA Manual Promotion of Access to Information Act 2 of 2000 (PAIA) Section 51 Manual | Version 2.0 | Effective Date: January 2026 This PAIA Manual is prepared in accordance with Section 51 of the Promotion of Access to Information Act 2 of 2000 ("PAIA") and applies to BXE Ltd. This manual is available for inspection at our registered office and on our website. 1. Introduction This manual is prepared in accordance with Section 51 of the Promotion of Access to Information Act 2 of 2000 ("PAIA"). PAIA gives effect to the constitutional right of access to information held by both public and private bodies, subject to justifiable limitations aimed at protecting certain rights and interests, including privacy, commercial confidentiality, and security. This manual serves as a reference document for requesters wishing to access information held by BXE Ltd ("BXE", "the Company", "we", "us", "our"). 3. Information Officer Details PAIA Information Officer In compliance with PAIA, BXE has designated the following person as Information Officer: Requests for access to information must be directed to the Information Officer using the contact details above. A completed PAIA Request Form (Annexure A) must accompany all requests. 4. Guide on How to Use PAIA The South African Human Rights Commission ("SAHRC") has compiled a guide on how to use PAIA. The guide is available for inspection at the SAHRC offices and on their website. The guide provides information on: The objects of PAIA The process for requesting access to information The grounds for refusal of access The rights of third parties The remedies available for non-compliance 5. Records Available Without Request (Section 52(2) PAIA) The following records are automatically available without submitting a formal PAIA request: 5.1 Publicly Accessible Records Company registration certificate (available on request) VAT registration certificate (available on request) PAIA Manual (this document) Privacy Policy (available on our website) Terms and Conditions (available on our website) Marketing brochures and publicly available materials Information published on our website at www.bxe.co.za 5.2 How to Access These Records These records may be accessed without submitting a PAIA request form by: Visiting our website at www.bxe.co.za Contacting our Information Officer at paia@bxe.co.za Attending our registered office during business hours (by appointment) 6. Records Requiring Formal Request (Section 51(1)(e) PAIA) Access to the following records requires a formal PAIA request using the prescribed form (Annexure A). Access may be refused on grounds set out in Section 7 below. 6.1 Customer Records Customer contracts and agreements Customer correspondence and communications Customer billing and payment records Customer support tickets and complaints Usage data and analytics (subject to Customer's own data protection obligations) 6.2 Employee Records (Subject to Labour Relations Act and POPIA) Personnel files Employment contracts Salary and benefits information Disciplinary records Training and development records 6.3 Financial Records Annual financial statements Management accounts Tax records Audit reports Bank statements 6.4 Operational Records Internal policies and procedures Minutes of board meetings Contracts with suppliers and partners Intellectual property records IT security and infrastructure documentation (subject to security restrictions) 6.5 Legal Records Legal correspondence (subject to legal privilege) Litigation records Regulatory compliance records Licenses and permits Important Note Not all records listed above are automatically available. Many records are subject to confidentiality obligations, legal privilege, or third-party privacy rights. Each request will be assessed on its merits in accordance with PAIA. 7. Grounds for Refusal of Access (PAIA Part 3) Access to records may be refused under the following grounds set out in PAIA: Section Ground for Refusal Section 63-65 Protection of privacy of third parties (including personal information under POPIA) Section 66-68 Protection of commercial information, trade secrets, and financial information Section 69 Protection of safety of individuals Section 70 Protection of police dockets and law enforcement information Section 71 Legal privilege (lawyer-client communications) Section 72 Breach of confidence Section 73-74 Research and cultural heritage information Where access is refused, the Information Officer will provide written reasons for the refusal and inform the requester of their right to lodge a complaint or appeal. 8. Request Procedure To request access to information, the following procedure must be followed: Step-by-Step Request Procedure Complete the PAIA Request Form: Use the prescribed form in Annexure A (available on our website or from our Information Officer). Provide sufficient detail to enable identification of the requested record. Submit the Request: Send the completed form to the Information Officer by email ( paia@bxe.co.za ) or by registered post to the postal address provided in Section 2. Pay the Request Fee: A request fee of R50 (fifty Rand) is payable before the request will be processed. Payment details will be provided upon receipt of the request. The fee may be waived for personal requests where the requester cannot afford the fee. Await Response: The Information Officer will respond within 30 days of receiving the request (subject to payment of the request fee). The period may be extended for a further 30 days for good cause shown. Pay Access Fee (if applicable): If access is granted, an access fee may be payable to cover search, preparation, reproduction, and postal costs. The fee structure is set out in Annexure B. Receive Access or Refusal Notice: If access is granted, the record will be made available in the requested format (subject to reasonable restrictions). If access is refused, written reasons will be provided. 9. Fees (PAIA Regulations) The fees for processing requests are prescribed in the PAIA Regulations (Government Gazette No. 39175). 10. Remedies for Non-Compliance If a requester is aggrieved by a decision (or failure to make a decision) of the Information Officer, the requester may: Internal Appeal: Lodge an internal appeal to the Information Officer within 30 days of the decision or expiry of the response period. Court Application: Apply to the High Court for appropriate relief within 180 days of the decision or expiry of the internal appeal period. Complaint to SAHRC: Lodge a complaint with the South African Human Rights Commission. 11. Availability of This Manual This PAIA Manual is available at: Our registered office at The Firs, Biermann Avenue, Rosebank, Johannesburg (during business hours) Our website at www.bxe.co.za/paia Available for download in PDF format upon request to paia@bxe.co.za 12. Updates to This Manual This manual is reviewed annually and updated as necessary to reflect changes in our operations, the law, or as required by the SAHRC. The latest version will always be available on our website. Version 2.0 | Approved by Information Officer: January 2026 ANNEXURE C: PRESCRIBED TIME PERIODS Action Time Period Information Officer to confirm receipt of request Within 14 days Information Officer to decide on request 30 days from receipt (subject to payment of request fee) Extension of decision period (notice) if good cause shown<\/td> 30 days (maximum total 60 days) Internal appeal period to Information Officer<\/td> 30 days from decision or expiry of response period Information Officer to decide on internal appeal<\/td> 30 days from receipt of appeal Court application (High Court)<\/td> 180 days from decision or internal appeal expiry 13. Other Applicable Legislation (Section 51(1)(f) PAIA) BXE is subject to the following legislation, which may affect the availability of certain records: Companies Act 71 of 2008 - Company records and disclosure requirements Income Tax Act 58 of 1962 - Tax records and returns Value-Added Tax Act 89 of 1991 - VAT records and invoices Protection of Personal Information Act 4 of 2013 (POPIA) - Data protection requirements Electronic Communications and Transactions Act 25 of 2002 - Electronic records and transactions Labour Relations Act 66 of 1995 - Employee records Basic Conditions of Employment Act 75 of 1997 - Employment records Employment Equity Act 55 of 1998 - Employment equity records Consumer Protection Act 68 of 2008 - Consumer records Cybercrimes Act 19 of 2020 - Cybersecurity and electronic evidence 14. Information Regulator of South Africa The Information Regulator is the national regulatory body responsible for monitoring compliance with POPIA and PAIA. Contact details: Information Regulator (South Africa) JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001 Private Bag X31, Braamfontein, 2017 Tel: 010 023 5200 Email: inforeg@justice.gov.za Website: www.justice.gov.za/inforeg/ PAIA Manual Version 2.0 | Effective January 2026 This PAIA Manual is prepared in compliance with Section 51 of the Promotion of Access to Information Act 2 of 2000. Ready to build your BXE growth system? Connect your website, CRM and customer-growth tools. Register for BXE → Growth Ecosystem BXE is an AI-driven growth system combining automated marketing, predictive CRM intelligence and data-powered campaigns to help businesses attract and convert customers at scale. Quick Links Platform How It Works About Contact Legal Terms & Conditions Privacy Policy PAIA Manual Contact support@bxe.co.za 087 821 6028 The Firs, Biermann Ave Rosebank, Johannesburg © 2025 BXE Ltd. All rights reserved.
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