PAIA Policy

Effective Date: 23 August 2024

1. ABOUT US

1.1 Bash (Pty) Ltd (the 'Company', 'we', 'us', or 'our') is a private company registered and operating in accordance with the laws of the Republic of South Africa, situated at 2nd floor, Block 3, Northgate Park, Section Street, Paarden Eiland, Cape Town, Western Cape, 7441 ("offices"). At the Company, we understand the importance of transparency and value your right of access to information.

2. ABOUT THIS PAIA MANUAL

2.1 This manual is published pursuant to section 51 of the Promotion of Access to Information Act No. 2 of 2000 ("PAIA").

2.2 A copy of this manual is available:

2.2.1. at https://bashafrica.com/ ("website");
2.2.2. at our offices during ordinary business hours;
2.2.3. to any person upon request and upon the payment of a reasonable prescribed fee; and
2.2.4. to the Information Regulator upon request.

2.3 We may update this manual from time to time by publishing a revised version on our website which shall take effect on the date of publication.

3. DEFINITIONS

3.1 This manual is published pursuant to section 51 of the Promotion of Access to Information Act No. 2 of 2000 ("PAIA").

3.1.1. "Information Regulator" means the independent body established in terms of section 39 of the Protection of Personal Information Act 4 of 2013;
3.1.2. "POPIA" means the Protection of Personal Information Act 4 of 2013;
3.1.3. "Record" means any recorded information in the possession or under the control of the Company, whether or not it was created by the Company, regardless of form or medium.

4. ENTRY POINT FOR ACCESS TO INFORMATION REQUESTS

4.1 Section 50 of PAIA provides that the Company is required to provide access to a Record if:

4.1.1. that Record is required for the exercise or protection of any rights;
4.1.2. the requesting person complies with PAIA's procedural requirements for access to that Record (explained in paragraph 5);
4.1.3. access to that Record is not refused based on grounds for refusal in sections 62 to 70 of PAIA.

4.2 Information will only be furnished if sufficient particulars are provided to identify the right being protected or exercised, and an explanation of why the Record is needed for that right. It also notes that individual rights are subject to limitations, including privacy, commercial confidentiality, and good governance.

5. GUIDE ON HOW TO USE PAIA AND HOW TO OBTAIN ACCESS TO THE GUIDE

5.1 The Information Regulator has updated and made available a revised guide on how to use PAIA (in an easily comprehensible form) under section 10(1) of PAIA. This guide assists individuals in exercising their right to access information under PAIA and POPIA.

5.2 Availability of the guide:

5.2.1. Members of the public can inspect or copy the guide from the offices of public and private bodies, including the Information Regulator's office, during normal working hours. It's also available upon request from the Information Officer.
5.2.2. The guide is electronically available for download from the Information Regulator's website at the following link: https://inforegulator.org.za/wp-content/uploads/2020/07/PAIA-Guide-English_20210905.pdf.

5.3 Any enquiries regarding the guide should be directed to the Information Regulator.

Contact Type	Details
Postal Address	JD House 27 Stiemans Street Braamfontein Johannesburg 2001
Telephone Number	+27 (0) 10 023 5207
Fax Number	086 500 3351
Email Address	enquiries@inforegulator.org.za
Website	www.inforegulator.org.za

6. CATEGORIES OF RECORDS WHICH ARE AVAILABLE WITHOUT A PERSON HAVING TO REQUEST ACCESS

Category of Records	Types of the Record	Availability
Product information	Any information relating to our products and services we may publish from time to time	Available on our website/ on request
Public facing policies and notices	Privacy Policy, Cookie Policy, Terms and Conditions, and PAIA Manual	Available on our website/ on request
Marketing information and promotional material	Any brochures, press releases, and publications we may publish from time to time	Available on our website and social media platforms

7. RECORDS KEPT BY THE COMPANY IN ACCORDANCE WITH OTHER LEGISLATION

7.1 Please note that the recording of the subject and categories of Records held by the Company in this manual does not imply that a request for access to said Records will be granted. All requests for access will be evaluated on a case-by-case basis in accordance with the provisions of PAIA and the relevant legislation concerned.

7.2 The Company may be required to provide access to certain Records to persons or entities who are entitled to access such Records under other legislation, which legislation may include, but not be limited to:

7.2 Legislation Records:

7.2.1. Companies Act 71 of 2008;
7.2.2. Basic Conditions of Employment Act 75 of 1997;
7.2.3. Compensation for Occupational Injuries and Diseases Act 130 of 1993;
7.2.4. Income Tax Act 58 of 1962;
7.2.5. Unemployment Insurance Act 30 of 1966;
7.2.6. Value Added Tax Act 89 of 1991;
7.2.7. Protection of Personal Information Act 4 of 2013;
7.2.8. Consumer Protection Act 68 of 2008;
7.2.9. Broad-Based Black Economic Empowerment Act 53 of 2003;
7.2.10. Financial Intelligence Centre Act 38 of 2001;
7.2.11. Labour Relations Act 66 of 1995;
7.2.12. Occupational Health and Safety Act 85 of 1993;
7.2.13. Pension Funds Act 24 of 1956;
7.2.14. Promotion of Access to Information Act 2 of 2000;
7.2.15. Skills Development Act 97 of 1998;
7.2.16. National Credit Act 34 of 2005;
7.2.17. Competition Act 89 of 1998;
7.2.18. Unemployment Insurance Contributions Act 4 of 2002.

8. DESCRIPTION OF THE SUBJECTS AND CATEGORIES OF RECORDS WHICH THE COMPANY HOLDS

Subjects on which the body holds Records	Categories of Records
Human resources / employment	Employee lists, contracts, personnel records, disciplinary records, compensation, employment conditions, Employment Equity Plan, pension/provident fund records, employee tax info, training schedules/manuals, payroll records, and internal policies.
Financial / accounting	Annual financial statements, tax returns, audit reports, invoices (creditors/debtors), bank facilities/account details, accounting officer/auditor details, formal books of account, other financial statements, source documents, banking records, and management reports.
Company	Company registration documents, founding statement/Memorandum of Incorporation, share register, other statutory registers, and minutes of meetings.
Information technology	Computer/mobile device usage policy, disaster recovery plans, hardware asset registers, information security policies/standards/procedures, IT systems/user manuals, information usage policy, project implementation plans, software licensing, and system documentation/manuals.
Intellectual property	Trade-marks, copyrights/designs, software licences, and domain name records.
Webpage	Company profile/information (strategy, history, executive management, teams, values, news, contact/banking details, career opportunities), online retail products (images, prices, descriptions, reviews, departments), retail terms/policies (website use, exchange/return policy), and secured personal user accounts (login page, personal details, order history, address book, credit cards, invoices, exchanges, returns).
Miscellaneous	Insurance records, marketing agreements, supplier agreements, lease agreements, confidentiality/non-disclosure agreements, and other relevant agreements.

9. PROCESSING OF PERSONAL INFORMATION

9.1 For information concerning the Company's compliance with POPIA, users should refer to their privacy policy available at https://bashafrica.com/pages/privacy-policy.

10. CONTACT INFORMATION: HEAD OF BODY

Field	Details
Name	Shaun Turner
Designation	Chief Executive Officer
Postal address	2nd floor, Block 3, Northgate Park, Section Street, Paarden Eiland, Cape Town, Western Cape, 7441
Street address	2nd floor, Block 3, Northgate Park, Section Street, Paarden Eiland, Cape Town, Western Cape, 7441
Phone number	+27 (0)21 856 8460
Email address	contact@aresholdings.co.za