The purpose of Promotion of Access to Information Act is to promote the right of access to information, to foster a culture of transparency and accountability in South Africa, and to encourage an open democracy where individuals from all walks of life are empowered to engage with government and participate in decisions which affect their lives. Bastion’s values include being agile, authentic, and achieving things together through teamwork while encompassing acceptance, inclusion, and respect.

The purpose of the PAIA manual is to enable persons to:

• check the categories of records held by a body which are available without a person having to submit a formal PAIA request;
• have a sufficient understanding of how to make a request for access to a record of the body, by providing a description of the subjects on which the body holds records and the categories of records held on each subject;
• know the description of the records of the body which are available in accordance with any other legislation;
• access all the relevant contact details of the Information Officer who will assist the public with the records they intend to access;
• know the description of the guide on how to use PAIA, as updated by the Regulator and how to obtain access to it;
• know if the body will process personal information, the purpose of processing of personal information and the description of the categories of data subjects and of the information or categories of information relating thereto;
• know the description of the categories of data subjects and of the information or categories of information relating thereto;
• know the recipients or categories of recipients to whom the personal information may be supplied;
• know if the body has planned to transfer or process personal information outside the Republic of South Africa and the recipients or categories of recipients to whom the personal information may be supplied; and
• know whether the body has appropriate security measures to ensure the confidentiality, integrity and availability of the personal information which is to be processed.

• The basis of this policy is that requests for access to information must be processed in compliance with relevant Promotion of Access to Information legislation, Bastion’s policy, governance directives and administrative directives of its Information Officer.
• This policy applies to the directors, the Information Officer, all employees and all third parties processing personal information as operators where Bastion is the responsible party.

In this Manual, unless the context clearly indicates a contrary intention, the words herein below defined shall bear the meanings assigned to them, and cognate expressions shall bear corresponding meanings:

• “Access fee” – means the fee paid by the requester to the public or private body from which information is being requested, to cover the costs of finding and if necessary, copying, the records you require;
• “Act” – means the Promotion of Access to Information Act, No 2 of 2000;
• “Bastion” – means Bastion Graphics (Proprietary) Limited, a private company registered in accordance with the laws of the Republic of South Africa, with registration number 1971/007122/07;
• “Guide” – means the guide published by the SAHRC in terms of section 10 of the Act;
• “IO“ – Information Officer;
• “Manual” – means this manual published in terms of section 51 of the Act;
• “Minister” – means the Cabinet member responsible for the administration of justice, presently the Department of Justice and Constitutional Development;
• “PAIA” – Promotion of Access to Information Act No. 2 of 2000 (as amended);
• “POPIA” – Protection of Personal Information Act No.4 of 2013;
• “Personal requester” – means a Requester seeking access to a record containing personal information about the Requester;
• “Private Body” – in terms of the Act, means a natural person who carries or has carried on any trade, business, or profession, but only in such capacity; a partnership which provides or has carried on any trade, business, or profession; or any former or existing juristic person, but excludes a public body;
• “Republic” – Republic of South Africa
• “Requester” – in terms of the Act, means any person, including but not limited to a public body or an official thereof, who make a request for access to a record of that Private Body or a person acting on behalf of that person;
• “Request for access” – means a request for access to a record of a private body;
• “Request fee” – means the cost to be paid for making a request for access to information
• “SAHRC” – means the South African Human Rights Commission.
• “The Head of Bastion”- means the Chief Executive Officer of Bastion;

Bastion is an end-to-end solutions provider for corporate communications, offering value-creating advice and solutions for high-quality stakeholder and investor communications, corporate reporting, and online communications.

Chief Information Officer
Benjamin Joannou
Tel: +27 11 778 5800
Email: info@bastiongroup.co.za

Access to information (general contacts)
Email: info@bastiongroup.co.za

Head Office
Telephone: +27 11 778 5800
Email: info@bastiongroup.co.za
Website: www.bastiongroup.co.za
Postal Address: PO Box, 52048, Saxonwold, 2193
Physical Address: Block E, Pinmill Farm, 164 Katherine St, Sandton

• In terms of section 10 of the Act, the SAHRC has published a guide containing information relating to:
  • obtaining access to a record of a Private Body and the assistance that is available from the SAHRC in this regard;
  • lodging a court application against a decision by the head of a private body;
  • the forms required and the fees that are payable for accessing a record; and
  • the voluntary disclosure of information by private bodies.
• Requesters are referred to the Guide in terms of Section 10 which has been compiled by the South African Human Rights Commission, which will contain information for the purposes of exercising Constitutional Rights. The Guide is available from the SAHRC.
• The contact details of the Commission are:
  Postal Address: Private Bag 2700, Houghton, 2041
  Telephone number :+27 11 877 3600
  Fax number: +27 11 403 0625
  Website: www.sahrc.org.za

• According to section 52(2) of the Act, the Minister must publish a description of the categories of records of the Private Body that are automatically available without a person having to request access in terms of the Act.
• To date, no notice has yet been published by the Minister.

• Certain of Bastion’s records are available in terms of legislation other than the Act and are listed in such legislation. In certain instances, the information referred to therein may only be accessed by the persons specified in the relevant legislation.
• The legislation, as amended from time to time, is as follows:
  • Companies Act No 61 of 1973
  • Employment Equity Act No 55 of 1998
  • Compensation for Occupational Injuries and Disease Act No 130 of 1993
  • Income Tax Act No 58 of 1962
  • Labour Relations Act No 66 of 1995
  • Value Added Tax Act No 89 of 1991
  • Basic Conditions of Employment Act No 75 of 1997
  • Skills Development Act No 9 of 1999
  • Skills Development Levy No 9 of 1999
  • Electronic Communications and Transactions Act No 25 of 2002
  • Promotion of Access of Information Act No 2 of 2000
  • Unemployment Insurance Act No 30 of 1996
  • Medical Schemes Act No 131 of 1998

• Secretarial
  Correspondence
  Founding documents
  Minutes of meetings
  Statutory returns
• Human Resources
  Conditions of service
  Employee records
  Employment contracts
  General correspondence
  Retirement annuity, pension and provident fund records
  Medical aid
  Performance appraisals
  Personnel guidelines, policies and procedures
  Remuneration records and policies
  Skills requirements
  Employees recruitment policies
  Statutory records
  Training records
• Marketing
  Client and customer database
• Financial
  Contracts
  Annual financial statements
  Asset register
  Banking records
  Budgets
  Financial transactions
  Insurance information
  Management accounts
  Purchase and order information
  Tax records (company and employee)
• Information technology
  IT policies and procedures
  Physical security (PC’s locked to fixture/locked computer room)
  Virus and malware protection
  Software updates
• Suppliers
  Personal information of all suppliers
  Financial records of all suppliers’ account
  Contract agreement with all suppliers
  Correspondence with all suppliers
  Tender documents
• Lessors
  Personal information details
  Lease agreements
  Correspondence
• Sponsors/donees
  Personal information details
  Contact details
  Receipts – 18A
  Donation register
  Correspondence
• Publishing houses
  Personal information details
  Contact details
  Details of advert
  Correspondence
• Statutory bodies e.g., SARS, Department of Labour, SETAs
  Personal information details
  Contact details
  Statutory returns
  Correspondence
• Auditors
  Personal information details
  Contact details
  Certificates of their registration with an authorizing body
  Audit reports
  Contract of service
  Statement of account
  Financial statements
  Correspondence
• Insurance houses
  Personal information details
  Contact details
  Insurance agreement
  Claim forms
  Correspondence
• Banking institutions
  Personal information details
  Contact details
  Record of accounts kept at the institution
  Correspondence
• Outsourced IT
  Personal information details of the company
  Contact details
  Contract with company
  Statement of account
  Correspondence
• Clients
  Identity numbers
  Dates of birth
  Telephone numbers
  Emails
• Addresses
  Contractual agreements
  Tender and RFP information

Bastion secures its data by maintaining reasonable measures to protect personal information from loss, misuse and unauthorised access, disclosure, alteration, and destruction. The company takes reasonable steps to keep personal information accurate, current, complete, and reliable for its intended use.

The manual is available for inspection at the office of Bastion free of charge, and on the Bastion website (refer to Part 2 of the manual). Copies are also available with the SAHRC and in the Government Gazette.

• Forms and fees
  • A request for information must be made in the prescribed form, a copy of which is annexed hereto as Annexure 1 and must be addressed to the head of the Bastion, submitted with the prescribed fee.
  • The prescribed request form and details regarding the prescribed fees are available from the head of Bastion and from the South African Human Rights Commission, whose contact details are set out in point 2 and 3 respectively above.
• Form of request
  • The requester must use the prescribed form to make the request for access to a record. This must be made to the head of the private body using the address, facsimile number or electronic mail address of the body concerned.
  • The requester must provide sufficient detail on the request form to enable the head of the private body to identify the record and the requester. The requester should also indicate which form of access is required. The requester should indicate if it requires notice of the decision of the head of the private body in any manner, other than in writing.
  • The requester must identify the right that is sought to be exercised or to be 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 head of the private body.
• Prescribed 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 head of the private body must by notice, require the requester to pay the prescribed fee, if any, before further processing the request.
  • The requester may lodge an application to the high court relating to the payment of the request fee.
  • After the head of the private body has decided on the request, the requester must be notified in the required form.
  • If the request is granted then a further access fee must be paid for the search, reproduction, preparation and for any time, in excess of the prescribed hours, required to search and prepare for the record disclosure.

Request for access to record of private body (Section 53(1) of the Promotion of Access to Information Act 2 of 2000 ) [Regulation 10]

30 June 2021

30 June 2020