PAIA section 51
PAIA manual
This manual lists the records IMKHONA holds and explains how to request them and how we process personal information. It follows the private-body manual template published by the Information Regulator.
1. Abbreviations
| CEO | Chief Executive Officer |
| IO | Information Officer |
| PAIA | Promotion of Access to Information Act 2 of 2000 |
| POPIA | Protection of Personal Information Act 4 of 2013 |
| Regulator | Information Regulator of South Africa |
2. Purpose of this manual
Section 51 of PAIA requires every private body to publish a manual. You can use this one to see which records are open without a formal request, which subjects and categories of records we hold, how to request access, how to reach our Information Officer, how to get the Regulator's Guide, and how we process personal information under POPIA, including who receives it, whether it leaves South Africa and how we secure it.
3. Contact details
- Information Officer
- Matthew Magwalivha, Chief Executive Officer and head of the private body
- Deputy Information Officer
- None designated at present
- Email for requests
- info@imkhona.co.za, subject line "PAIA request"
- Telephone
- +27 (0)11 467 2021
- Physical address
- 321 Greenstone Gate, Greenstone Hill, Edenvale 1609, Gauteng
- Postal address
- 321 Greenstone Gate, Greenstone Hill, Edenvale 1609
- Website
- www.imkhona.co.za
4. The Regulator's PAIA Guide
Under section 10(1) of PAIA, the Information Regulator publishes a Guide on how to use PAIA and POPIA. It is available in every official language and in braille. The Guide explains the objects of both Acts, how to request records from public and private bodies, the help the Regulator and Information Officers can give, the remedies available, and the fees that apply.
You can download the Guide from the Regulator's PAIA page, including the English and isiZulu editions. Copies in English and isiZulu are available for inspection at our Edenvale office during business hours, and we will email one to you on request.
5. Records available without a request
IMKHONA has not published a notice under section 52 of PAIA. The records below are open to anyone without a PAIA request.
| Category | Records | Where |
|---|---|---|
| Company information | Services, commodities, logistics routes, leadership, contact details | This website |
| Marketing material | Business profile | On request by email |
| Legal notices | Privacy notice and this PAIA manual | This website and our office |
6. Records kept under other laws
We keep records under the laws below, as they apply to our business. Where one of these laws gives you a right of access, you may use that law instead of PAIA.
| Law | Records |
|---|---|
| Companies Act 71 of 2008 | Memorandum of incorporation, registers of directors and shareholders, minutes, annual financial statements |
| Income Tax Act 58 of 1962, Value-Added Tax Act 89 of 1991, Tax Administration Act 28 of 2011 | Tax returns, VAT records, supporting accounting records |
| Basic Conditions of Employment Act 75 of 1997, Labour Relations Act 66 of 1995 | Employment contracts, time and remuneration records, disciplinary records |
| Unemployment Insurance Act 63 of 2001, Unemployment Insurance Contributions Act 4 of 2002 | UIF registration and contribution records |
| Skills Development Levies Act 9 of 1999 | Skills development levy records |
| Compensation for Occupational Injuries and Diseases Act 130 of 1993 | Registration, injury reports and assessment records |
| Occupational Health and Safety Act 85 of 1993 | Incident registers, risk assessments, safety appointments |
| Mine Health and Safety Act 29 of 1996 | Site inductions and safety records required on mine premises |
| National Road Traffic Act 93 of 1996 | Vehicle registration and roadworthiness records, driver licence and professional driving permit records |
| Cross-Border Road Transport Act 4 of 1998 | Cross-border permits for loads into neighbouring countries |
| Broad-Based Black Economic Empowerment Act 53 of 2003 | B-BBEE certificates and affidavits |
| Promotion of Access to Information Act 2 of 2000, Protection of Personal Information Act 4 of 2013 | This manual, PAIA requests and outcomes, Information Officer registration |
7. Subjects and categories of records
| Subject | Categories of records |
|---|---|
| Company secretarial | Incorporation documents, share register, directors' resolutions, statutory returns |
| Finance | Annual financial statements, management accounts, invoices, bank records, asset and finance agreements |
| Tax | Income tax, VAT, PAYE, UIF and skills levy records |
| Human resources | Employment contracts, payroll, leave, training, disciplinary and job application records |
| Clients and contracts | Quotes, haulage and service contracts, delivery notes, weighbridge tickets, correspondence |
| Suppliers and subcontractors | Supplier agreements, subcontracting agreements, B-BBEE and tax compliance documents |
| Fleet and operations | Vehicle records, maintenance logs, GPS tracking data, trip and load records, route plans |
| Health and safety | Incident reports, risk assessments, induction records, driver medical fitness certificates |
| Premises | CCTV recordings, lease and access records |
| Insurance and legal | Insurance policies and claims, legal opinions, litigation records |
| Information technology | Website files, server logs, system access records |
Listing a category does not mean every record in it will be released. Access depends on the grounds for refusal in sections 63 to 69 of PAIA.
8. How to request a record
Making the request
Use Form 02, Request for Access to Record, prescribed by regulation 7 of the PAIA Regulations, and email it to the Information Officer at info@imkhona.co.za or deliver it to our office. Section 53 of PAIA requires the form to identify the record and you, say how you want access, and give an email address, postal address or fax number for our reply. Section 50 requires you to explain which right you want to exercise or protect and why the record is needed for it. If you ask on someone else's behalf, include proof of your authority.
Fees
These are the fees the Information Regulator prescribes for private bodies. We will tell you on Form 03 what applies before we prepare any record.
| Item | Fee |
|---|---|
| Request fee | R140.00, except for a request for your own personal information |
| Photocopy or printed A4 page | R2.00 per page or part of a page |
| Copy on a flash drive you provide | R40.00 |
| Transcription of an audio record | R24.00 per A4 page |
| Search and preparation | R145.00 per hour or part of an hour after the first hour, up to R435.00 |
| Deposit, where search and preparation exceed 6 hours | One third of the access fee |
| Postage | The actual cost |
Our decision
We will decide within 30 days of receiving a complete request, as section 56 requires. Section 57 lets us extend that once, by up to 30 days, if the request covers many records or needs consultation, and we will tell you in writing if we do. We may refuse access only on the grounds in sections 63 to 69 of PAIA, which protect third parties' privacy and commercial or confidential information, people's safety, legally privileged records, our own commercial information and research information. Section 70 still requires disclosure where the public interest clearly outweighs the harm. If we refuse, we will give our reasons.
If you disagree with our decision
A private body has no internal appeal. Within 180 days of our decision you may complain to the Information Regulator under section 77A of PAIA (email PAIAComplaints@inforegulator.org.za, using Form 05) or apply to court under section 78.
9. Processing of personal information
Purposes
We process personal information to provide and invoice our services, operate a safe and lawful haulage fleet, employ and pay staff, manage suppliers and subcontractors, reply to enquiries, keep our premises and systems secure, and meet our legal duties.
Data subjects and the information we hold
| Data subjects | Personal information |
|---|---|
| Clients and their staff | Names, job titles, contact details, company registration and VAT numbers, addresses, bank details, contract and payment history |
| Suppliers and subcontractors | Names, contact details, registration and VAT numbers, bank details, B-BBEE and tax status, subcontracted drivers' licence and permit details |
| Employees | Names, identity numbers, contact details, addresses, next of kin, qualifications, remuneration, tax and bank details, leave, disciplinary and training records |
| Drivers | Driving licence and professional driving permit (PrDP) details, medical fitness certificates, GPS location and driving data from the vehicles they drive, trip and incident records |
| Job applicants | CVs, qualifications, references and contact details |
| Visitors to our premises | CCTV images, names and times of visits |
| Website visitors and enquirers | Server logs (IP address, browser, pages, time) and the enquiry form details described in our privacy notice |
Medical fitness certificates are special personal information under section 26 of POPIA. We hold them because the National Road Traffic Regulations require a medical certificate for a PrDP, and we process them under section 27(1)(b), with access limited to the people who manage driver compliance.
Recipients
| Recipient | Information |
|---|---|
| South African Revenue Service | Tax, PAYE, VAT and UIF information |
| Department of Employment and Labour, Compensation Fund | UIF and COIDA records, injury reports |
| Auditors, accountants and legal advisers | Financial, employment and contract records they need |
| Banks, funders and insurers | Company and vehicle details, claims and finance applications |
| Mines, wash plants, ports and clients | Driver names, licence and PrDP details and vehicle details needed for site access and load tracking |
| Fleet tracking provider | Vehicle GPS location and driving data |
| Web and email hosting provider | Website files, server logs and mailboxes, stored in South Africa |
| South African Police Service and courts | Records they request under a lawful process |
Transfers outside South Africa
Our website and email are hosted in South Africa. For export and cross-border contracts, including cargo through Maputo in Mozambique, we send the driver, vehicle and business contact details that the buyer, shipping agent, port or border authority needs, as section 72(1)(c) and (d) of POPIA allow. We will use a service that stores personal information outside South Africa only where section 72 permits it.
Security measures
Our website is served only over HTTPS. Systems and mailboxes require passwords, and access to employee, driver and finance records is limited to the staff who need them. Paper records are kept in locked storage at our office. Operators who process information for us do so under written agreements, as section 21 of POPIA requires. We report any security compromise to the Regulator and to the people affected, as section 22 requires.
10. Availability of this manual
This manual is available on this website, for inspection at our Edenvale office during business hours, from the Information Officer by email, and to the Information Regulator on request. A printed copy costs R2.00 per A4 page.
11. Updating this manual
The head of IMKHONA will review this manual at least once a year and update it whenever our records, processing or contact details change.
Issued by Matthew Magwalivha, Chief Executive Officer and Information Officer, IMKHONA (Pty) Ltd. 27 October 2026.