PAIA Manual

The 1996 Constitution of the Republic of South Africa establishes a foundational right to access information held by both state and private entities. The Promotion of Access to Information Act 2 of 2000 (PAIA), effective 9 March 2001, operationalises this right by advancing transparency and accountability.

Under PAIA, private bodies must grant requestors access to records if three conditions are met: the record is necessary to exercise or protect a legal right, all procedural requirements are satisfied, and no statutory grounds for refusal apply.

This manual facilitates record access under section 51 of PAIA. It is available:

• For inspection at nuvoteQ offices, free of charge
• In physical copies, subject to prescribed fees
• As a PDF on nuvoteq.io or upon request from the Information Officer

PAIA permits requests only when records are required to exercise or protect legal rights. You may request in one of four capacities:

• Personal requestor — seeking your own records
• Agent requestor — acting with explicit consent on someone else's behalf
• Third-party requestor — requesting another's records with that person's consent
• Public body — when procedural compliance is met and no refusal grounds exist

The Chief Executive Officer has delegated PAIA responsibilities to:

Information Officer: Marina Lazaridis (marina@nuvoteq.io)

Deputy Information Officer: Ricky Haug (ricky@nuvoteq.io)

Physical address: 47 Hazelwood Rd, Hazelwood, Pretoria, 0081, South Africa.

nuvoteQ (Pty) Ltd is a South African registered company providing software solutions globally to Contract Research Organisations (CROs) and healthcare industry organisations. Additional company information is available at nuvoteq.io.

nuvoteQ maintains records across these categories. Many records concern third parties — clients, employees — which are confidential and client property. We protect third-party confidential information carefully.

• Corporate affairs and investor relations
• Corporate secretariat and governance (memoranda of incorporation, board minutes, statutory returns)
• Finance and taxation (annual financial statements, audit reports, tax records)
• Human resources (employment contracts, employee benefits, training records)
• Information technology (agreements, licences, operating systems)
• Intellectual property (trademark applications, copyrights)
• Legal (litigation pleadings, material licences and permits)
• Sales, marketing and communication (brochures, client information, strategies)

Complete the prescribed Form 'Request for Access to a Record' (ML-GM-01 v00 TPL-1.0) or the comparable Information Regulator form. Requirements:

• Complete the form in English
• Provide identity proof (agents must provide proof for both the authorising person and themselves)
• Type or print responses in BLOCK LETTERS
• Respond 'N/A' if questions don't apply and 'nil' if nothing requires disclosure
• Submit via conventional mail, email or fax to the Information Officer

Payment details are available from the Information Officer. Payment occurs via electronic fund transfer or direct deposit. Proof of payment must be supplied with the request. Four fee types may apply:

• Request fee — R57.00 (incl. VAT), non-refundable (not applicable to personal requestors seeking their own records)
• Reproduction fee — applied to automatically available records
• Access fee — to reimburse nuvoteQ for search, reproduction and record preparation costs
• Deposit — one-third of applicable access fee, payable if the request concerns another person and preparation exceeds six hours

We will decide within thirty (30) days of receipt whether to grant or decline a request and provide written notice with reasons. This period may extend by up to a further thirty days if the request involves large information volumes or requires searches across multiple offices — you will be notified in writing of any extension.

Requests may be refused on these grounds per the Act:

• Mandatory privacy protection of third-party natural persons (including deceased individuals)
• Mandatory commercial information protection — trade secrets, financial, commercial, scientific or technical information whose disclosure could harm third-party or nuvoteQ interests
• Information disclosed in confidence where release would breach a duty of confidence
• Mandatory individual safety and property protection
• Legal privilege protection from production in proceedings (unless waived)
• Third-party and nuvoteQ research information protection

If you are aggrieved by an Information Officer refusal, you may apply to a court within thirty (30) days of the notification for appropriate relief.

Use the 'Request for Correction or Deletion of a Record' form (ML-GM-01 v00 TPL-2.0). Submission requirements mirror the access request process.

We will action requests within thirty (30) days of receipt, with extensions possible for large information volumes. You will be notified of any extension in writing.

The Information Regulator is an independent body that monitors and enforces compliance with PAIA and POPIA.

Physical address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001

Email: inforeg@justice.gov.za (general) · complaints.IR@justice.gov.za (complaints)

Tel: +27 (0)11 877 3600