PAIA Manual
Promotion of Access to Information Act 2 of 2000
PAIA Manual of Synesis (Pty) Ltd, prepared in terms of section 51 of PAIA. Date of compilation: October 2026
1. Acronyms and abbreviations
| CIPC | Companies and Intellectual Property Commission |
| IO | Information Officer |
| PAIA | Promotion of Access to Information Act 2 of 2000, as amended |
| POPIA | Protection of Personal Information Act 4 of 2013 |
| Regulator | Information Regulator (South Africa) |
| Synesis | Synesis (Pty) Ltd, registration number 2025/975263/07 |
2. Purpose of this manual
This manual explains how members of the public may request access to records held by Synesis. It sets out:
- the categories of records that are available without a formal request;
- how to request access to other records, and the subjects and categories of records Synesis holds;
- records available in terms of other legislation;
- the contact details of the Information Officer;
- where to obtain the Regulator’s Guide on how to use PAIA;
- how Synesis processes personal information, including the purposes of processing, categories of data subjects, recipients, cross-border transfers and security measures.
3. Key contact details
Information Officer: The Director, Synesis (Pty) Ltd
Deputy Information Officer: None designated
Email: info@synesis.co.za (marked “PAIA request”)
Physical address: Thatchfield Ridge, Centurion, Gauteng
Postal address: As above
Website: http://www.synesis.co.za
The Information Officer is registered with the Information Regulator in terms of section 55(2) of POPIA.
4. Guide on how to use PAIA
The Information Regulator has published an updated Guide, in terms of section 10 of PAIA, to help people exercise their right of access to information. The Guide is available in each of the official languages and in braille. It explains, among other things, the objects of PAIA and POPIA, how to make a request to a public or private body, the assistance available from Information Officers and the Regulator, the remedies available, and the fees payable.
The Guide may be obtained from the Information Regulator’s website at inforegulator.org.za, or requested from our Information Officer. Copies in English and Afrikaans are available for inspection at our offices, by appointment, during normal business hours.
5. Records available without a request
The following records are automatically available and may be accessed without a formal PAIA request:
| Category of record | Available on website | Available on request |
|---|---|---|
| Information about our services and how to engage us | Yes | Yes |
| Privacy Notice | Yes | Yes |
| This PAIA manual | Yes | Yes |
| Company name, registration number and contact details | Yes | Yes |
6. Records available in terms of other legislation
Synesis keeps records as required by the following legislation, where applicable. Access to these records is subject to the provisions of PAIA and of the relevant Act.
| Legislation | Examples of records |
|---|---|
| Companies Act 71 of 2008 | Memorandum of Incorporation, securities register, register of directors, minutes and resolutions, beneficial ownership register, CIPC filings |
| Income Tax Act 58 of 1962 and Tax Administration Act 28 of 2011 | Tax returns, assessments and supporting records |
| Value-Added Tax Act 89 of 1991 (if registered) | VAT records and invoices |
| Basic Conditions of Employment Act 75 of 1997 and related labour legislation (if applicable) | Employment records |
| Electronic Communications and Transactions Act 25 of 2002 | Electronic records and communications |
| Protection of Personal Information Act 4 of 2013 | Records of processing, consents and data subject requests |
| Promotion of Access to Information Act 2 of 2000 | This manual and records of PAIA requests |
7. Subjects and categories of records held
| Subject | Categories of records |
|---|---|
| Company and statutory | Memorandum of Incorporation, statutory registers, minutes and resolutions of Synesis, CIPC filings and correspondence |
| Finance and tax | Accounting records, financial statements, invoices, quotes, bank records, tax records |
| Client engagements | Engagement letters, quotes, correspondence, and records prepared or held on behalf of clients, including minutes, resolutions, registers and filings |
| Board evaluations | Questionnaires, individual responses, interview notes and evaluation reports |
| Suppliers and service providers | Agreements, invoices and correspondence |
| Information technology | System access records, security settings, website and email administration records |
| Personnel (if applicable) | Contracts, payroll and statutory employment records of employees or contractors |
Records held for clients are confidential to those clients. A request for such records will normally be referred to, or require the consent of, the client concerned, and may be refused on the grounds set out in Chapter 4 of Part 3 of PAIA.
8. How to request access
- Complete the prescribed request form (Form 2 of the PAIA Regulations, 2021), available from the Information Regulator’s website.
- Send it to the Information Officer at info@synesis.co.za, or deliver it to the address in section 3.
- Provide enough detail to identify the record, state the form of access you require, and identify the right you are seeking to exercise or protect and why the record is needed for that purpose (section 53 of PAIA).
- If you are requesting on behalf of someone else, provide proof of the capacity in which you act.
Fees
A request fee and, if access is granted, an access fee may be payable as prescribed in the PAIA Regulations, 2021. The Information Officer will notify you of any fee payable before the request is processed. A deposit may be required where the search and preparation of the record will take longer than the prescribed period.
Timeframes
We will decide on a request within 30 days of receiving it in the prescribed form (section 56). This period may be extended by up to a further 30 days in the circumstances set out in section 57, in which case you will be notified.
Grounds for refusal
Access may be refused on the grounds set out in Chapter 4 of Part 3 of PAIA, including the protection of the privacy of third parties (section 63), commercial information of third parties (section 64), confidential information of third parties (section 65), records privileged from production in legal proceedings (section 67), and commercial information of Synesis (section 68).
Remedies
PAIA provides no internal appeal against a decision of a private body. If you are dissatisfied with a decision, you may lodge a complaint with the Information Regulator or apply to court within 180 days of being notified of the decision (sections 77A and 78).
9. Processing of personal information
9.1 Purpose of processing
Synesis processes personal information to respond to enquiries and prepare quotes; to deliver company secretarial and governance services, including Board evaluations; to make statutory filings on behalf of clients; to manage our business, finances and suppliers; to send governance updates to people who have opted in; and to comply with legal obligations.
9.2 Categories of data subjects and personal information
| Data subjects | Personal information processed |
|---|---|
| Clients and their contact persons | Names, contact details, organisation, correspondence, billing information |
| Directors, prescribed officers, Shareholders and beneficial owners of client companies | Names, identity or passport numbers, contact and residential details, shareholdings, appointment dates, information in minutes and resolutions |
| Directors and Committee members taking part in Board evaluations | Names, contact details, questionnaire responses and interview notes, including views on Board, Committee and individual performance |
| Website visitors and enquirers | Details submitted through the quote form, marketing consent records, basic technical data |
| Suppliers and service providers | Names, contact details, banking and contractual details |
| Employees and contractors (if applicable) | Identity, contact, banking, tax and employment details |
9.3 Recipients of personal information
| Recipient | Information shared |
|---|---|
| CIPC | Company, director and beneficial ownership information filed on behalf of clients |
| South African Revenue Service | Tax information of Synesis |
| Operators: Microsoft (email and document storage) and WordPress.com (website hosting) | Information stored in or submitted through these systems |
| Professional advisers, auditors and banks | Information required for the specific matter or transaction |
| Regulators, courts and law enforcement | Information required by law |
9.4 Cross-border transfers
Our cloud service providers may store or process personal information outside South Africa. Microsoft may store data in South Africa or in other regions it operates, and WordPress.com is hosted by Automattic Inc. in the United States. We use only providers bound by data-protection terms that give a level of protection comparable to POPIA, as section 72 of POPIA requires.
9.5 Security measures
- Two-step sign-in on all business accounts;
- encryption of data in transit and at rest by our cloud service providers;
- access limited to people who need it for their work;
- unique passwords held in a password manager;
- email authentication (SPF, DKIM and DMARC) to protect against impersonation;
- notification of security compromises to the Information Regulator through its eServices portal, and to affected data subjects, as required by section 22 of POPIA.
10. Availability of this manual
This manual is available on our website, for inspection at our offices by appointment during normal business hours, to any person on request at the prescribed fee for copies, and to the Information Regulator on request.
11. Updating of this manual
The Information Officer will review this manual at least once a year and update it whenever our information practices change. See also our Privacy Notice.
Issued by: The Director and Information Officer, Synesis (Pty) Ltd
Date: October 2026
