PAIA Manual

1. Introduction & Purpose

This manual is published in terms of Section 51 of the Promotion of Access to Information Act, 2000 (Act 2 of 2000) (“PAIA”), as amended, which gives effect to the constitutional right of access to any information held by a private body as contemplated in Section 32 of the Constitution of the Republic of South Africa, 1996.

The purpose of this manual is to inform the public of the types of records held by Mind Money Movement (Pty) Ltd (trading as PeakRank Digital), how to request access to such records, the procedure to follow when making a request, and the fees payable.

A copy of this manual is available for inspection during normal business hours, on our website at peakrank.co.za/paia, and has been submitted to the Information Regulator (South Africa).

2. Details of the Private Body

The following are the full details of the private body as required under PAIA:

3. Information Officer

The Information Officer is designated in terms of PAIA and POPIA, and is responsible for encouraging compliance with the conditions for lawful processing of personal information and for receiving and processing all requests made under PAIA.

All requests for access to records must be directed to the Information Officer using the contact details above. Requests must be submitted on the prescribed Form C.

4. Guide on How to Use PAIA

The Information Regulator has compiled a guide in terms of Section 10 of PAIA to assist persons who wish to exercise their right of access to information. This guide is available free of charge from the Information Regulator:

5. Categories of Records Held

The following categories of records are held by PeakRank Digital, in both physical and electronic form:

5.1 Company & Operational Records

• Company registration documents (CIPC — CoR14.3, MOI)
• Director records and share register
• Minutes of meetings and company resolutions
• Annual return filings
• Registered Information Officer documentation
• Internal policies and standard operating procedures
• Supplier and vendor agreements

5.2 Financial Records

• Annual financial statements and management accounts
• Tax returns and SARS correspondence
• VAT records (where applicable)
• Bank account statements and transaction records
• Invoices issued and received
• Expense reports and receipts
• Budget forecasts and cash flow projections

5.3 Client & Customer Records

• Client contact details (name, email, phone, company)
• Signed service agreements, proposals, and scopes of work
• SEO, GEO, and SEM audit reports and recommendations
• Campaign performance reports and analytics data
• Platform usage data and subscription records
• Billing and payment records per client
• Support and communication correspondence
• Termination notices and offboarding records

5.4 Employee & Contractor Records

• Employment contracts and independent contractor agreements
• Payroll records and payslips
• Performance reviews and disciplinary records
• Leave and attendance records
• UIF and COIDA registrations (where applicable)
• Non-disclosure agreements (NDAs)

5.5 Marketing, Brand & Digital Records

• Brand guidelines and design assets (logos, colour palettes, typography)
• Website source code and content management records
• Digital advertising campaign creatives and copy
• SEO and GEO strategy documents
• Social media accounts and content calendars
• Third-party platform agreements (Google, Meta, etc.)

5.6 Legal & Compliance Records

• This PAIA Manual and POPIA compliance documentation
• Privacy Policy and Terms & Conditions
• Data processing records and third-party data agreements
• Legal correspondence and retainer agreements
• Complaints register and resolution records
• Insurance policies

5.7 IT & Digital Infrastructure Records

• Domain registration and hosting records (peakrank.co.za)
• Software licences and SaaS subscriptions
• Data processing agreements with third-party providers: Vercel (hosting), Supabase (database), Resend (email)
• System and application logs
• Security audit logs and data breach incident records
• Data backup and cybersecurity policies
• User access logs and authentication records
• API integrations and third-party tool records

5.8 Data Retention Periods

• Active accounts: Personal information retained for the duration of the subscription.
• Cancelled accounts: Data retained for 90 days after cancellation, then archived to cold storage.
• Deletion requests: Processed within 30 business days. Anonymised aggregate data may be retained.
• Legal requirements: Invoices and tax records retained for up to 5 years as required by South African law.

6. Records Available Without a Request

The following records are publicly available and may be accessed without submitting a formal PAIA request:

7. Records Available Under Other Legislation

Access to the following categories of records is governed by specific legislation. Requests for such records should be made under the relevant Act:

8. How to Request Access to Records

A requester must complete the prescribed Form C (for PAIA requests to private bodies), available from the Information Regulator at inforegulator.org.za or from our Data Subject Forms page.

Step-by-step process

• Download and complete Form C — include your full name, contact details, and a clear description of the records requested.
• Pay the non-refundable request fee of R50.00 (waived if requesting your own personal information — attach a copy of your ID).
• Submit Form C plus proof of payment to the Information Officer at [email protected] with subject line: "PAIA Request — [Your Full Name]".
• Receive acknowledgement from the Information Officer within 5 business days.
• Await decision within 30 days of receipt (extendable by a further 30 days for complex requests, with written notice).
• If access is granted, any additional access fees will be communicated before records are provided.

Submit your request to:

9. Prescribed Fees

The following fees are prescribed in terms of the PAIA Regulations (as amended). Fees are subject to change in line with updated Regulations published by the Information Regulator.

Payment: EFT to company banking account. Details provided upon confirmation of your request. Reference: PAIA Request — [Your Name].

10. Grounds for Refusal of Access

Access to records may be refused on the grounds set out in Chapter 4 of PAIA, including but not limited to:

Mandatory grounds for refusal

• Protection of the privacy of a third party (Section 63)
• Protection of commercial information of a third party (Section 64)
• Protection of confidential information of a third party (Section 65)
• Protection of research information of a third party (Section 66)
• Endangerment of the life or safety of an individual (Section 67)

Discretionary grounds for refusal

• Protection of the commercial activities of the private body (Section 68)
• Privileged legal records — attorney-client privilege (Section 69)
• Records that are clearly frivolous, vexatious, or involve unreasonable diversion of resources (Section 45)
• Record does not exist or cannot be found after all reasonable steps (Section 23)

11. Remedies if a Request is Refused

If a request for access to a record is refused, or if you are not satisfied with the Information Officer's decision, the following remedies are available:

• Internal appeal: Submit a written appeal to the Information Officer within 30 days of the decision, setting out your grounds.
• Complaint to the Information Regulator: Lodge a complaint at inforegulator.org.za or by email to [email protected].
• Court application: Apply to a High Court of competent jurisdiction for appropriate relief in terms of Section 78 of PAIA.

12. Availability of This Manual

This manual is available:

• On our website at peakrank.co.za/paia
• On request from the Information Officer at [email protected]
• At our offices: 20 2nd Avenue, Diep River, Cape Town, Western Cape, 7965
• At the offices of the Information Regulator (South Africa)

This manual must be reviewed and updated at least annually. The current version (1.0) is effective from 3 March 2026. Material changes will be reflected in a new version submitted to the Information Regulator.