PAIA manual

Effective August 2026. This manual is prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000, as amended. It helps members of the public understand the categories of records held by Asibonge Legacy Group (Pty) Ltd, which records may be available without a formal request, how to request access to a record, who to contact, and how ALG processes personal information.

The manual also provides information relevant to POPIA, including categories of data subjects, categories of personal information processed, recipients of personal information, cross-border processing and a general description of security safeguards.

Registered name

Asibonge Legacy Group (Pty) Ltd

Registration number

2018/198210/07

Nature of body

Diversified operating and investment group, private company

Physical address

Unit 15, Sunninghill Office Park, 16 Peltier Drive, Sunninghill, Sandton, 2191, South Africa

Website

www.asibongelegacygroup.co.za

General email

info@asibongelegacygroup.co.za

Information Officer / Head of the private body

The Information Officer, Asibonge Legacy Group (Pty) Ltd

Requests and enquiries

info@asibongelegacygroup.co.za, marked for the attention of the Information Officer

Physical address

Unit 15, Sunninghill Office Park, 16 Peltier Drive, Sunninghill, Sandton, 2191, South Africa

All requests for access to records, and all enquiries under PAIA or POPIA, should be directed to the Information Officer using the contact details above.

The Information Regulator has made available a Guide on how to use PAIA. It explains the objects of PAIA and POPIA, the manner in which requests may be made, the assistance available, applicable remedies and fees, and related procedural matters. The Guide is available from the Information Regulator in South Africa's official languages, and may also be requested from ALG's Information Officer. The Regulator publishes the prescribed PAIA request and complaint forms on its website and eServices platform.

Corporate website content

Public corporate profile, general information, business capabilities, contact information and public announcements, available on the website.

Published policies

Privacy policy, terms of use, this PAIA manual and the POPIA statement, available on the website.

Public marketing material

Brochures, capability statements, media releases and other documents expressly published by ALG, available on the website or on request where still current.

Public vacancies

Vacancies or career notices ALG elects to publish, available through the website while active.

Public procurement notices

Requests or notices ALG elects to make public, available through the stated publication channel while active.

The fact that a category is listed as potentially available does not mean every record in that category is public. Confidential, personal, privileged, commercially sensitive, security-sensitive or otherwise protected information may be withheld in accordance with PAIA and other law.

Depending on applicability and the nature of a record, legislation under which ALG may create, hold or maintain records includes the Companies Act 71 of 2008; the Income Tax Act 58 of 1962 and Tax Administration Act 28 of 2011; the Value-Added Tax Act 89 of 1991; the Basic Conditions of Employment Act 75 of 1997; the Labour Relations Act 66 of 1995; the Employment Equity Act 55 of 1998; the Skills Development Act 97 of 1998 and Skills Development Levies Act 9 of 1999; the Unemployment Insurance Act 63 of 2001 and Unemployment Insurance Contributions Act 4 of 2002; the Compensation for Occupational Injuries and Diseases Act 130 of 1993; the Occupational Health and Safety Act 85 of 1993; the Broad-Based Black Economic Empowerment Act 53 of 2003; the Protection of Personal Information Act 4 of 2013; the Promotion of Access to Information Act 2 of 2000; the Electronic Communications and Transactions Act 25 of 2002; the Consumer Protection Act 68 of 2008; the Copyright Act 98 of 1978; the Cybercrimes Act 19 of 2020; and the Protected Disclosures Act 26 of 2000.

This manual is for Asibonge Legacy Group (Pty) Ltd only. The operating companies within the group are separate registered legal entities. Each is a private body in its own right under PAIA and is responsible for its own PAIA manual, records schedule, privacy notice and POPIA governance, including any sector-specific legislation applicable to that entity. A request concerning records held by an operating company should be directed to that entity.

Corporate governance

Incorporation records, governance policies, board and committee records, delegations, resolutions, corporate structure and statutory records.

Strategy and investment

Business plans, evaluations, transaction documents, due diligence, proposals, board submissions and strategic records, subject to confidentiality and privilege.

Finance and tax

Accounting records, management accounts, budgets, bank records, tax records, audit files, invoices, payments and financial controls.

Legal and compliance

Contracts, legal opinions, disputes, regulatory correspondence, policies, licences, insurance records, compliance assessments and privileged material.

Human resources

Employee files, recruitment records, payroll information, performance records, training, disciplinary and grievance records, leave and benefits.

Procurement and suppliers

Supplier registrations, due diligence, contracts, purchase orders, bids, quotations, supplier performance and compliance records.

Customers and business development

Enquiries, proposals, contracts, relationship records, correspondence, CRM information and service-related records at Group level.

ICT, data and cybersecurity

System inventories, access records, policies, logs, incidents, vendor records, backups, architecture and security documentation, subject to security-based refusal grounds.

Privacy and information governance

POPIA assessments, privacy notices, processing registers, operator agreements, data subject requests, security compromise records and training records.

Marketing and communications

Website content, publications, campaigns, brand assets, media records, event communications and public relations material.

Risk, assurance and audit

Risk registers, internal controls, audit records, incident investigations, assurance reports and corrective-action records.

Health, safety and environment

Policies, risk assessments, incident records, training records and other records where applicable to Group activities.

ALG processes personal information for corporate administration, governance and statutory compliance; customer, supplier, partner and stakeholder relationship management; procurement, contracting, invoicing, payment and financial administration; recruitment, employment, training, performance and workforce administration; website operation, enquiries, communications, analytics and security; risk management, due diligence, legal claims, investigations and fraud prevention; information security, access control, incident response and business continuity; marketing and communications where permitted by law; and investment, acquisition, partnership and corporate transaction activities where applicable.

Customers and prospective customers

Names, contact details, organisation, role, service needs, correspondence, contractual and transaction information.

Suppliers and service providers

Business and contact details, registration and tax details, banking information, B-BBEE information, due diligence, contracts and performance records.

Employees and job applicants

Identity and contact information, CVs, qualifications, employment history, payroll and benefits data, performance, training, legal and employment records, and special personal information where lawfully required.

Directors, officers and business owners

Identity, contact, statutory, governance, beneficial ownership, due diligence and business information where applicable.

Website visitors

Technical logs, IP address, device and browser details, cookie identifiers, usage information and any information submitted through forms.

Professional advisers and partners

Contact, organisation, engagement, correspondence, contractual and due-diligence information.

Members of the public and complainants

Contact details, correspondence, complaint or request content and information necessary to address the matter.

Recipients may include authorised ALG personnel and governance bodies on a need-to-know basis; relevant operating entities where necessary to route or perform an enquiry or engagement; operators and service providers including IT, cloud, cybersecurity, communications, payroll, recruitment, professional and document-management providers; banks, insurers, auditors, accountants, lawyers and other professional advisers; regulators, government bodies, courts, law-enforcement authorities and statutory institutions where required or permitted by law; and business counterparties under appropriate confidentiality arrangements in connection with investments, acquisitions, disposals, restructuring or strategic transactions.

ALG may use cloud, communications or professional service providers with infrastructure or personnel outside South Africa. Where personal information is transferred to a foreign country, ALG will manage the transfer in accordance with section 72 of POPIA and will consider applicable contractual and legal safeguards. Specific countries and providers are maintained in ALG's internal information asset and operator registers.

ALG maintains reasonable technical and organisational safeguards appropriate to its processing activities and risks, which may include governance policies, access controls, strong authentication, multi-factor authentication, encryption, endpoint protection, secure network controls, patching, backups, monitoring, logging, physical safeguards, staff confidentiality and awareness, supplier due diligence, incident management and business continuity controls. Security details that could materially weaken ALG's security posture are not disclosed publicly.

ALG may refuse access where PAIA requires or permits refusal. Depending on the record this may include protection of the privacy of third parties, commercial information, confidential information, safety, security, privileged legal communications, research information, records connected to law enforcement, or other grounds recognised by PAIA. Where only part of a record is protected and the remainder can reasonably be severed, ALG will consider providing the accessible portion.

PAIA permits prescribed request and access fees in certain circumstances. Any fee charged will be determined in accordance with the PAIA Regulations in force at the time of the request, and the requester will be informed of applicable fees and payment requirements before access is provided where the law permits a fee.

ALG will communicate the outcome of a request and, where access is refused, will provide reasons to the extent required by law. A private body does not have the same compulsory internal appeal process that applies to certain public bodies. A requester may lodge a complaint with the Information Regulator in the prescribed manner and within the applicable time period, currently using Form 5, or may seek relief from a competent court as provided by PAIA.

Information Regulator (South Africa), Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg. Postal: P.O. Box 31533, Braamfontein, Johannesburg, 2017. Telephone 010 023 5200. Email enquiries@inforegulator.org.za. Website inforegulator.org.za, eServices eservices.inforegulator.org.za.

A copy of this manual is available on www.asibongelegacygroup.co.za and at ALG's head office for public inspection during normal business hours, subject to reasonable security and visitor procedures. A copy may be requested from the Information Officer and supplied subject to any fee permitted by applicable PAIA Regulations, and may be supplied to the Information Regulator on request.

The Information Officer will review this manual regularly and update it when there is a material change to ALG's records, processing activities, contact details, legal obligations, corporate structure or the applicable PAIA and POPIA framework..