1. Introduction and company details
The Promotion of Access to Information Act 2 of 2000 ("PAIA") gives effect to the constitutional right of access to any information held by the state and any information that is held by another person and that is required for the exercise or protection of any rights.
Safety Management Group (Pty) Ltd ("SMG") is a private body providing workplace health and safety consulting, compliance auditing, safety system implementation, accredited training, and industrial relations services throughout South Africa.
This Manual has been compiled in accordance with Section 51 of PAIA as amended by the Protection of Personal Information Act 4 of 2013 (POPIA) to inform requesters of the records held by SMG and the procedure required to access them.
2. Information Officer & contact details
The Head of the Private Body has duly appointed an Information Officer in terms of Section 51(1)(a) of PAIA and Section 55 of POPIA:
Information Officer Contact Particulars
Designated Information Officer: R. Liebenberg
Registered physical address: The Atrium, 9th Floor on 5th Street, Sandton, Johannesburg, 2196
Postal address: PO Box 78120, Sandton, 2146
Direct telephone: 083 564 6663 / 011 883 0000
Email address:[email protected]
National branches: Cape Town, Johannesburg, Pretoria, Port Elizabeth, East London
3. Guide of the Information Regulator (Section 10)
The Information Regulator has compiled an official guide in terms of Section 10 of PAIA containing information reasonably required by a person wishing to exercise any right contemplated in PAIA and POPIA.
The Guide is available in each of the official South African languages on the Information Regulator's website (inforegulator.org.za) or may be inspected at our Johannesburg office during ordinary business hours.
4. Records available without formal request (Section 52)
The following categories of records are automatically available without requiring a formal request under PAIA, via our website or upon simple request:
- Marketing brochures and service overview sheets.
- Free downloadable safety screening checklists and compliance calendars.
- Published insights, articles, and regulatory update commentary.
- Public accreditation status with the Department of Employment and Labour, QCTO, and Saiosh.
5. Schedule of records held by SMG
SMG holds records in the following categories. Access to these records may be subject to the grounds for refusal set out in PAIA:
| Record category | Record subjects & types |
|---|---|
| Statutory & Company | Certificate of Incorporation, Memorandum of Incorporation, director resolutions, share register, and statutory company filings under the Companies Act 71 of 2008. |
| Financial & Tax | Audited annual financial statements, tax returns, VAT records, management accounts, invoices, credit notes, and banking records. |
| Human Resources & Personnel | Employment contracts, payroll records, disciplinary records, medical certificates of fitness, leave records, and internal training logs. |
| Accredited Training | QCTO, Department of Labour, and Saiosh course materials, learner assessment portfolios, attendance registers, and certification records. |
| Client Health & Safety | Compliance audit reports, workplace risk assessments, Section 24 incident investigations, safe work procedures, and contractor file evaluations. |
6. Access request procedure
To request access to records held by SMG under PAIA, the requester must follow these steps:
- Complete Prescribed Form 2: Obtain and complete Form 2 (Request for Access to Record of Private Body), available from the Information Regulator's website or by contacting our Information Officer.
- Sufficient detail: The request must provide sufficient detail to enable the Information Officer to identify the record requested, the requester's identity, contact information, and preferred form of access.
- Specify the right: The requester must clearly specify the right they seek to exercise or protect, and explain why the record is required for that purpose.
- Submit the request: Submit the completed Form 2 together with proof of identity and payment of the prescribed request fee to [email protected].
SMG will consider and respond to the request within 30 calendar days, which may be extended by an additional 30 days if the request requires extensive searches or third-party consultations.
7. Prescribed fees
PAIA provides for two types of fees: a request fee and an access fee. A requester (other than a personal requester seeking their own personal information) must pay the prescribed request fee of R140.00 before the request is processed.
If access is granted, an access fee is payable for reproduction, search, and preparation time in accordance with the prescribed tariff published by the Information Regulator.
8. Grounds for refusal of access
In terms of Chapter 4 of PAIA, SMG is entitled or required to refuse access to records under specific circumstances, including:
- Mandatory protection of privacy of third parties: If disclosure would involve the unreasonable disclosure of personal information of a natural person (Section 63).
- Protection of commercial information: Trade secrets, financial, scientific, or technical information that could harm the commercial interests of SMG or a third party (Section 64).
- Confidential information: Records that would breach a duty of confidence owed to a third party in terms of an agreement (Section 65).
- Safety of individuals and property: Where disclosure could endanger the life, physical safety, or security of a building or installation (Section 66).
- Privileged records: Privileged information generated in legal proceedings unless the privilege has been waived (Section 67).