PROMOTION OF ACCESS TO INFORMATION ACT MANUAL

Prepared in terms of Section 51 of the Promotion of Access to Information Act 2 of 2000

LMTS QA Consulting
Version: 1.0
Effective date: 5 September 2026
Last reviewed: 5 September 2026

1. Introduction

This Manual has been prepared by LMTS QA Consulting ("LMTS") in accordance with section 51 of the Promotion of Access to Information Act 2 of 2000 ("PAIA"), as amended.

PAIA gives effect to the constitutional right of access to information held by the State and information held by another person or private body where that information is required for the exercise or protection of a right.

This Manual is intended to assist persons who wish to request access to records held by LMTS and to explain:

• the categories of records held by LMTS;

• records that may be available without a formal PAIA request;

• records available under other legislation;

• how a request for access may be made;

• how LMTS processes personal information;

• categories of data subjects whose information may be processed;

• recipients of personal information;

• possible cross-border transfers;

• information-security safeguards; and

• remedies available where access is refused.

2. Details of the Private Body

Trading Name: LMTS QA Consulting

Registered Legal Entity:
[INSERT FULL REGISTERED COMPANY NAME]

Registration Number:
[INSERT CIPC REGISTRATION NUMBER]

Business Type:
Private company / [INSERT CORRECT LEGAL FORM]

Website:
www.lmtsqa.co.za

Physical Address:
[INSERT PHYSICAL ADDRESS]

Postal Address:
[INSERT POSTAL ADDRESS]

Telephone:
[INSERT TELEPHONE NUMBER]

General Email:
[INSERT GENERAL EMAIL]

PAIA / Privacy Email:
[INSERT PAIA OR INFORMATION OFFICER EMAIL]

3. Information Officer

For purposes of PAIA and the Protection of Personal Information Act 4 of 2013 ("POPIA"), requests should be directed to LMTS's Information Officer.

Information Officer:
[INSERT NAME]

Designation:
[CEO / Managing Director / Other Applicable Designation]

Telephone:
[INSERT]

Email:
[INSERT]

Physical Address:
[INSERT]

Where LMTS has appointed one or more Deputy Information Officers, their contact details may also be published on the LMTS website.

4. Purpose of This Manual

The purpose of this Manual is to enable persons to:

1. understand what categories of records LMTS holds;

2. identify records that may be requested;

3. determine whether records are automatically available;

4. understand the procedure for making a PAIA request;

5. identify the correct Information Officer;

6. understand applicable fees and procedures;

7. understand the categories of personal information processed by LMTS;

8. understand how personal information may be shared or transferred;

9. understand LMTS's general information-security safeguards; and

10. understand available remedies where a request is refused.

5. PAIA Guide

The Information Regulator of South Africa has published a Guide on how to use PAIA.

The Guide contains information regarding:

• the objectives of PAIA;

• how to make requests for access to records;

• assistance available from Information Officers;

• applicable forms;

• applicable fees;

• grounds upon which access may be refused;

• complaints to the Information Regulator; and

• applications to court.

The Guide is available from the Information Regulator of South Africa and through its official website.

Information Regulator Contact Details

Information Regulator (South Africa)
Woodmead North Office Park
54 Maxwell Drive
Woodmead
Johannesburg
2191

Postal Address:
P.O. Box 31533
Braamfontein
Johannesburg
2017

Telephone: 010 023 5200

Toll Free: 0800 017 160

General Enquiries: enquiries@inforegulator.org.za

PAIA Complaints: PAIAComplaints@inforegulator.org.za

The Information Regulator's contact details may change from time to time, and requesters should consult the Regulator's official website for the latest information.

6. Records Automatically Available

Certain records may be available without a formal request under PAIA.

Subject to availability and applicable restrictions, these may include:

CategoryExamplesWebsite informationPublic pages, service descriptions, contact informationLegal policiesTerms of Service, Privacy Policy, Cookie Policy, PAIA ManualCareersPublished vacancies and job descriptionsMarketing informationBrochures, service descriptions, public company profilesPublic announcementsNews, articles, notices and updatesPublic testimonialsTestimonials approved for publicationPublic corporate informationInformation lawfully published through public registriesPublic recruitment informationGeneral information relating to vacancies and recruitment processes

The fact that a category appears above does not mean every record falling within that category is automatically available.

Confidential, proprietary, personal, privileged or otherwise protected information may remain restricted.

7. Records Available in Terms of Other Legislation

LMTS may hold records required under South African legislation.

Depending upon applicability to LMTS and its activities, such legislation may include:

• Companies Act 71 of 2008;

• Companies Regulations;

• Income Tax Act 58 of 1962;

• Tax Administration Act 28 of 2011;

• Value-Added Tax Act 89 of 1991, where applicable;

• Basic Conditions of Employment Act 75 of 1997;

• Labour Relations Act 66 of 1995;

• Employment Equity Act 55 of 1998, where applicable;

• Skills Development Act 97 of 1998;

• Skills Development Levies Act 9 of 1999, where applicable;

• Unemployment Insurance Act 63 of 2001;

• Compensation for Occupational Injuries and Diseases Act 130 of 1993;

• Occupational Health and Safety Act 85 of 1993;

• Electronic Communications and Transactions Act 25 of 2002;

• Consumer Protection Act 68 of 2008, where applicable;

• Protection of Personal Information Act 4 of 2013;

• Promotion of Access to Information Act 2 of 2000;

• Cybercrimes Act 19 of 2020;

• Copyright Act 98 of 1978;

• Trade Marks Act 194 of 1993; and

• other legislation applicable to LMTS from time to time.

Inclusion of legislation in this Manual does not constitute a representation that every provision of that legislation applies to LMTS.

8. Categories of Records Held by LMTS

LMTS may hold records relating to the following subjects.

8.1 Corporate and Governance Records

These may include:

• incorporation records;

• CIPC records;

• company registration documents;

• governance records;

• company policies;

• resolutions;

• delegations of authority;

• company registers;

• organisational structures;

• insurance records;

• strategic documents; and

• statutory records.

8.2 Financial Records

These may include:

• accounting records;

• invoices;

• quotations;

• purchase orders;

• payment records;

• bank-related records;

• financial statements;

• tax records;

• budgets;

• expense records;

• debtor and creditor information;

• supplier payments; and

• audit records.

8.3 Human Resources and Employment Records

These may include:

• employment contracts;

• employee personal information;

• payroll records;

• remuneration information;

• leave records;

• performance records;

• disciplinary records;

• training records;

• qualifications;

• skills-development records;

• employment-equity information;

• policies and procedures; and

• occupational health and safety records.

Access may be restricted where records contain confidential or personal information.

9. Recruitment and Job Application Records

Because LMTS operates an online recruitment and job-application platform, records may include:

• job advertisements;

• vacancy specifications;

• job descriptions;

• applicant details;

• CVs and résumés;

• cover letters;

• application responses;

• qualifications;

• professional certifications;

• employment histories;

• portfolio information;

• interview records;

• evaluation records;

• shortlisting information;

• correspondence;

• reference information;

• offer information;

• recruitment decisions; and

• consent relating to future opportunities.

Unsubmitted job-application drafts stored only in a user's browser local storage are not ordinarily records held by LMTS until they are transmitted to LMTS.

10. Client and Professional Services Records

Records may include:

• client information;

• contracts;

• master services agreements;

• statements of work;

• proposals;

• quotations;

• project plans;

• meeting records;

• requirements;

• project correspondence;

• deliverables;

• testing documentation;

• test plans;

• test cases;

• defect reports;

• QA reports;

• project-management records;

• digital-transformation documentation;

• client system information;

• service reports;

• staff-augmentation information;

• implementation records; and

• acceptance documentation.

Many of these records may contain confidential, proprietary, commercially sensitive or third-party information and may therefore be subject to statutory grounds for refusal.

11. Information Technology Records

LMTS may hold:

• infrastructure records;

• system configurations;

• network information;

• architecture information;

• software documentation;

• databases;

• application information;

• security logs;

• audit logs;

• access-control records;

• user records;

• backup information;

• incident records;

• vulnerability information;

• software-development records;

• source-code repositories;

• technical documentation;

• CMS records;

• website records; and

• cybersecurity information.

Information that could compromise the confidentiality, integrity or availability of LMTS or third-party systems may be restricted.

12. Website and CMS Records

Records may include:

• CMS content;

• website pages;

• articles;

• job posts;

• testimonials;

• newsletter subscription information;

• contact-form submissions;

• enquiry records;

• website logs;

• cookie preference records;

• analytics records;

• administrative records;

• moderation records; and

• content revision histories.

13. Supplier and Contractor Records

These may include:

• supplier details;

• service agreements;

• quotations;

• invoices;

• due-diligence information;

• correspondence;

• performance records;

• professional qualifications;

• contractor information;

• confidentiality agreements; and

• payment information.

14. Legal and Compliance Records

These may include:

• legal agreements;

• legal correspondence;

• litigation records;

• regulatory correspondence;

• compliance assessments;

• POPIA documentation;

• PAIA requests;

• information-security records;

• risk assessments;

• incident reports;

• audit reports;

• policies;

• registers; and

• compliance evidence.

Records protected by legal professional privilege will not ordinarily be disclosed where PAIA permits refusal.

15. Marketing and Communications Records

These may include:

• marketing materials;

• newsletters;

• mailing lists;

• communication preferences;

• marketing consent records;

• unsubscribe records;

• testimonials;

• website content;

• public-relations material;

• social-media content; and

• business-development records.

16. Processing of Personal Information

LMTS processes personal information for legitimate business and operational purposes including:

• providing professional services;

• responding to enquiries;

• managing clients;

• managing recruitment;

• processing job applications;

• operating the website and CMS;

• administering newsletter subscriptions;

• publishing authorised testimonials;

• managing employees and contractors;

• maintaining financial records;

• managing suppliers;

• providing customer support;

• maintaining security;

• meeting contractual obligations;

• complying with legal obligations;

• conducting authorised marketing;

• managing business risks; and

• establishing, exercising or defending legal rights.

Further information is contained in the LMTS Privacy Policy.

17. Categories of Data Subjects and Personal Information

Data SubjectInformation That May Be ProcessedWebsite visitorsIP address, device information, browser information, website usage and preferencesEnquirersName, surname, contact details, organisation and enquiry informationNewsletter subscribersName, email, consent and subscription preferencesJob applicantsContact details, CV, experience, education, skills, qualifications and application informationEmployeesIdentification, contact, employment, payroll, performance and statutory informationContractorsContact, professional, contractual and payment informationClientsContact, contractual, commercial, billing and project informationClient personnelContact details, role, project and system-related informationSuppliersContact, business, banking, tax and contractual informationTestimonial contributorsName, organisation, title, testimonial, image where authorisedBusiness contactsContact details, employer, role and correspondenceWebsite administratorsUser identifiers, access information and activity recordsRefereesContact details, relationship to applicant and reference information

18. Recipients of Personal Information

Personal information may, where lawful and necessary, be supplied to:

• authorised LMTS employees;

• hiring managers;

• contractors;

• professional advisers;

• IT service providers;

• hosting providers;

• cloud service providers;

• email and communication providers;

• recruitment providers;

• payroll and accounting providers;

• auditors;

• insurers;

• clients;

• prospective clients where authorised;

• regulators;

• courts;

• law-enforcement agencies; and

• other recipients authorised or required by law.

LMTS does not sell personal information.

19. Cross-Border Processing

Some technology, cloud, hosting or professional-service providers used by LMTS may process information outside the Republic of South Africa.

LMTS may also transfer information internationally where required for a client engagement, supplier relationship or other legitimate business purpose.

Where personal information is transferred outside South Africa, LMTS will seek to comply with section 72 of POPIA and applicable data-protection requirements.

20. Information-Security Measures

LMTS implements reasonable technical and organisational measures intended to preserve the confidentiality, integrity and availability of information.

Measures may include:

• identity and access management;

• role-based access control;

• authentication controls;

• password controls;

• encryption where appropriate;

• endpoint security;

• firewalls;

• secure hosting;

• backups;

• logging and monitoring;

• malware protection;

• vulnerability management;

• security patching;

• change management;

• secure development practices;

• data minimisation;

• confidentiality obligations;

• employee awareness;

• incident-management procedures;

• supplier controls; and

• disaster-recovery and continuity arrangements where appropriate.

Detailed security architecture, configurations and controls are not publicly disclosed where doing so could create security risk.

21. Right of Access to Records

A requester may request access to a record of LMTS where:

1. the record is required for the exercise or protection of a right;

2. the procedural requirements of PAIA have been complied with; and

3. no lawful ground for refusal applies.

The requester should identify the right being exercised or protected and explain why access to the requested record is necessary for that purpose.

22. How to Make a PAIA Request

A person requesting access to a record should use the prescribed PAIA Form 2 – Request for Access to Record.

The request should be submitted to the LMTS Information Officer using the contact details contained in this Manual.

The requester should provide sufficient information to enable LMTS to:

• identify the requester;

• identify the requested record;

• determine the form of access required;

• identify the right being exercised or protected;

• understand why the record is required for that right; and

• determine whether the requester acts personally or on behalf of another person.

Where a request is made on behalf of another person, appropriate proof of authority may be required.

The prescribed Form 2 is available from the Information Regulator.

23. Assistance to Requesters

LMTS will take reasonable steps to assist a requester where required by PAIA.

Where a request does not contain sufficient information to locate the relevant record, LMTS may request further particulars.

A requester should provide as much detail as possible, including:

• record title;

• record type;

• approximate date;

• relevant project;

• relevant person or department; and

• any known reference number.

24. Fees

PAIA allows certain prescribed fees to be charged for requests and access to records.

Where applicable, LMTS may require payment of:

• a prescribed request fee;

• reproduction costs;

• search and preparation costs;

• delivery costs; and

• other prescribed access fees.

Applicable fees will be calculated according to the prevailing PAIA regulations.

A requester will be advised of applicable fees before access is provided where required.

Certain persons or categories of requests may be exempt from fees under applicable law.

25. Decision on a Request

LMTS will process a valid PAIA request as soon as reasonably possible.

Subject to the provisions of PAIA, including third-party notification requirements, LMTS will ordinarily communicate its decision within 30 days after receiving a compliant request.

The statutory period may be extended in circumstances permitted by PAIA.

Where the period is lawfully extended, the requester will be notified accordingly.

26. Grounds for Refusal

Access to a record is not automatic merely because a PAIA request has been submitted.

PAIA contains mandatory and discretionary grounds upon which access may or must be refused.

These may include records relating to:

• privacy of third parties;

• personal information of another person;

• confidential information;

• commercial information of third parties;

• trade secrets;

• financial or technical information;

• information supplied in confidence;

• safety of individuals;

• security of property or systems;

• legally privileged information;

• LMTS's commercial information;

• research information; or

• information otherwise protected by law.

Where only part of a record is protected and the remainder can reasonably be separated, LMTS will consider whether access can be granted to the severable portion.

27. Third-Party Information

Where a requested record relates to information concerning a third party, LMTS may be required to notify that third party.

The third party may be entitled to make representations regarding disclosure.

This may affect the period within which LMTS can make a final decision.

28. Records That Cannot Be Found

If reasonable steps have been taken to locate a requested record but it cannot be found or does not exist, LMTS will deal with the matter in accordance with PAIA.

The requester will be informed where appropriate.

29. Complaints and Remedies

A private body does not ordinarily have the same internal appeal procedure available for certain public bodies under PAIA.

A requester or affected third party who is dissatisfied with LMTS's PAIA decision may, where permitted by law:

• lodge a complaint with the Information Regulator; or

• apply to a competent court.

The Information Regulator provides PAIA Form 5 – Complaint Form for applicable complaints.

Current complaint procedures should be obtained from the Information Regulator.

30. Availability of This Manual

This Manual will be made available:

• on the LMTS QA Consulting website;

• for public inspection at LMTS's principal place of business during normal business hours, subject to reasonable arrangements;

• to a person upon request as provided by PAIA; and

• to the Information Regulator upon request.

31. Updating the Manual

LMTS will review and update this Manual periodically and when material changes occur to:

• the organisation;

• information-processing activities;

• records held;

• applicable legislation;

• Information Officer details;

• technology;

• website functionality; or

• regulatory requirements.

32. Related Documents

This Manual should be read together with the:

• LMTS QA Consulting Privacy Policy;

• LMTS QA Consulting Cookie and Browser Storage Policy;

• LMTS QA Consulting Terms of Service;

• applicable recruitment notices;

• applicable client agreements; and

• other legal and compliance notices published by LMTS.