PAIA Policy

1. Background


1.1. Intention
This Manual is intended to assist persons wishing to access information in terms of the Act from any member of the BBD Group, comprising:

  CompanyRegistration Number
  BBD Holdings (Pty) Ltd2016/056422/07
  Barone, Budge and Dominick (Pty) Ltd      1984/007889/07
  BBD International (Pty) Ltd1999/017630/07
  BBD Management Services (Pty) Ltd2016/198051/07
  BBD IndiaU74900PN2014FTC152955

1.2. Process
Should a requester, as contemplated in the Act, require access to any information, they must contact the BBD Information Officer at [email protected]

2. Terms used


In this Manual:

2.1. terms defined in the Act shall have the meaning set out therein
2.2. reference to sections shall be a reference to sections in the Act
2.3. the following terms shall have the meaning assigned to them.

2.3.1 “the Act” means the Promotion of Access to Information Act No. 2 of 2000, as amended, together with any regulations published in terms thereof

2.3.2. “Head” means the information head of the BBD group, who shall act as the information head of each member of the BBD Group, as specified in paragraph 4
2.3.3. “Manual” means this manual, together with all annexes thereto as amended and made available on the Website from time to time
2.3.4. “SAHRC” means the South African Human Rights Commission
2.3.5. “Website” means the BBD Group website at www.bbdsoftware.com.

3. Background to the BBD Group


The BBD Group conducts the business of software development and the provision of IT system-related services.

4. Section 51(1)(a) information

  NAME OF PRIVATE BODYBBD Holdings Proprietary Limited and its subsidiaries listed in paragraph 1.1
  PHYSICAL ADDRESSThe Zone Boulevard Cnr Cradock & Tyrwhitt Ave, Rosebank, Johannesburg 2196
  POSTAL ADDRESSP.O. Box 72420 Parkview, South Africa 2122
  CONTACTInformation Officer
  EMAIL[email protected]

5. Section 51(1)(b) information


5.1. Guide. In terms of section 10 of the Act, the SAHRC has published a guide containing information reasonably required by a person wishing to exercise or protect any right in terms of the Act. This guide is available from the SAHRC offices, the details of which appear below, or on the SAHRC website at:


And contains the following information:

5.1.1. the objects of the Act
5.1.2. particulars of the information officer of every public body
5.1.3. particulars of every private body are practicable
5.1.4. the manner and form of a request for access to information held by a body
5.1.5. assistance available from both the information officer and the SAHRC in terms of this Act
5.1.6. all remedies in law regarding acts, omissions, rights and duties, including how to lodge an internal appeal and a court application
5.1.7. schedules of fees to be paid in relation to requests for access to information
5.1.8. regulations made in terms of the Act.

5.2. Queries
Any queries regarding the guide should be directed to:

The South African Human Rights Commission, PAIA Unit, the Research and Documentation Department

  POSTAL ADDRESS      Private Bag 2700, Houghton, 2041
  PHYSICAL ADDRESS      Braampark Forum 3, 33 Hoofd Street, Braamfontein
  WEBSITE    www.sahrc.org.za
  PHONE     011 877 3600
  EMAIL     [email protected]
  FAX     011 403 0625

6. Section 51(1)(c) information


The BBD Group has not published any notice in terms of section 52.

7. Section 51(1)(d) information


7.1. Each member of the BBD Group keeps records in accordance with all such legislation as is applicable to it, which includes but is not limited to, the legislation set out in Schedule 1.
7.2. Where records are kept in terms of any of the above legislation and same is of a public nature, these may, in certain circumstances, be available without the requirement of a request in terms of the Act.

8. Section 51(1)(e) information


This part of the Manual sets out a description of the subjects on which the BBD Group holds records and the categories of records held on each subject. These include operational records of the BBD Group, which it may utilise in the day to day running and administration of its business, including:

  • client databases
  • accounting information
  • internal phone lists
  • policies
  • directives
  • minutes of meetings
  • administrative information

8.1. Records that may be requested

Subject to the provisions of the Act and paragraph 8.2, each member of the BBD Group retains the following records:

8.1.1. Operational information

Such information as relates to the operational, commercial and financial interests of relevant member, including (without limitation):

  • accounting records
  • commercial contracts
  • company secretarial information, including, documents of incorporation, memorandum of incorporation, minutes of board of director’s meetings, records relating to the appointment of directors/auditors/secretary/public officer and other officers and share register and other statutory registers
  • customer database (consisting of customer personal information; commercial and financial information; information on contemplated, existing and past legal matters; information relating to agreements, proposals and intellectual and other property rights of customers)
  • domain name registrations
  • employment contracts
  • human resource information (including internal policies and procedures; training records and manuals business employee records; and personal information relating to past, present and prospective employees and directors)
  • information relating to the BBD Group’s marketing, business plans, systems and procedures
  • insurance policies
  • internal phone list
  • internal policies and procedures
  • records relating to information technology (hardware, software and data collection and storage)

8.1.2. Communications

Internal and external correspondence between each member of the BBD Group, its staff and cients, including letters, faxes, memos, emails and the like, to the extent that same are not covered by the records described in paragraph 8.1.1.

8.1.3. Website

The BBD Group’s website address is www.bbdsoftware.com and is accessible via the internet. The website contains various categories of information relating to the BBD Group, including a description of the services provided, a background to the business of the BBD Group, amongst others.

8.2. The request procedures

It should be noted that any and all records, whether specifically listed herein or not, shall only be made available subject to the provisions of the Act.

8.2.1. Form of request

Internal and external correspondence between each member of the BBD Group, its staff and customers, including letters, faxes, memos, emails and the like, to the extent that same are not covered by the records described in paragraph 4.

  • A requester must use the form set out in Schedule 2 to make a request for access to a record. This form must be submitted to the Information Officer. This request may be made to any of the contact details set out in paragraph 4
  • The requester must provide sufficient detail on the request form to enable the Information Officer to identify the record and the requester. The requester should also indicate which form of access is required and specify a postal address or fax number in the Republic of South Africa. The requester should also indicate if, in addition to a written reply, any other manner is to be used to inform the requester and state the necessary particulars to be so informed
  • The requester must identify the right that is sought to be exercised or protected and provide an explanation of why the requested record is required for the exercise or protection of that right
  • If a request is made on behalf of another person, the requester must submit proof of the capacity in which the requester is making the request to the satisfaction of the Information Officer

8.2.2. Fees

A requester who seeks access to a record containing personal information about that requester is not required to pay the request fee. Every other requester, who is not a personal requester, must pay the required request fee:

  • the Information Officer will by written notice require each requester (other than a personal requester) to pay the prescribed request fee (if any) before further processing any request
  • the fee that the requester must pay to a private body is R50, provided that the requester may lodge an application to the court against the tender or payment of the request fee
  • after the Information Officer has made a decision on the request, the requester will be notified in the required form. If the request is granted, then a further access fee must be paid for reproduction and for search and preparation and for any time that has exceeded the prescribed hours to search and prepare the record for disclosure.

9. Availability of manual

9.1. This Manual is available for inspection by the general public upon request, during office hours and free of charge, at the offices of the BBD Group. Copies of the Manual may be made, subject to the prescribed fees.
9.2. Copies may also be requested from the South African Human Rights Commission.
9.3. The Manual is also posted on BBD’s website referred to in paragraph.

Schedule 1

Legislation of General Application

  Basic Conditions of Employment ActAct 75 of 1997  
  Companies ActAct 71 of 2008
  Compensation for Occupational Injuries and Diseases Act  Act 130 of 1993  
  Competition ActAct 89 of 1998
  Consumer Protection ActAct 68 of 2008
  Copyright ActAct 61 of 1978
  Electronic Communications and Transactions Act  Act 25 of 2002
  Employment Equity ActAct 55 of 1998
  Income Tax ActAct 58 of 1962
  Insolvency ActAct 24 of 1936
  Interception and Monitoring Prohibition Act  Act 127 of 1992
  Intellectual Property Laws Amendments Act  Act 38 of 1997
  Labour Relations Act  Act 66 of 1995
  National Credit Act  Act 34 of 2005
  Occupational Health and Safety Act  Act 85 of 1993
  Prevention of Organised Crime ActAct 121 of 1998
  Protection of Personal InformationNo 4 of 2013p
  Protection of Businesses ActAct 99 of 1978
  Regional Services Councils ActAct 109 of 1985
  Skills Development ActAct 97 of 1998
  Skills Development Levies ActAct 9 of 1999
  Trade Marks ActAct 194 of 1993
  Unemployment Insurance ActAct 63 of 2001
  Unemployment Insurance Contributions Act  Act 4 of 2002
  Value Added Tax ActAct 89 of 1991

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