PAIA section 51

PAIA manual

IMKHONA (Pty) Ltd, registration number 2019/523163/07. Prepared under section 51 of the Promotion of Access to Information Act 2 of 2000, as amended. Compiled 27 October 2026. Next review by October 2027.

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

CEOChief Executive Officer
IOInformation Officer
PAIAPromotion of Access to Information Act 2 of 2000
POPIAProtection of Personal Information Act 4 of 2013
RegulatorInformation 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.

CategoryRecordsWhere
Company informationServices, commodities, logistics routes, leadership, contact detailsThis website
Marketing materialBusiness profileOn request by email
Legal noticesPrivacy notice and this PAIA manualThis 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.

LawRecords
Companies Act 71 of 2008Memorandum 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 2011Tax returns, VAT records, supporting accounting records
Basic Conditions of Employment Act 75 of 1997, Labour Relations Act 66 of 1995Employment contracts, time and remuneration records, disciplinary records
Unemployment Insurance Act 63 of 2001, Unemployment Insurance Contributions Act 4 of 2002UIF registration and contribution records
Skills Development Levies Act 9 of 1999Skills development levy records
Compensation for Occupational Injuries and Diseases Act 130 of 1993Registration, injury reports and assessment records
Occupational Health and Safety Act 85 of 1993Incident registers, risk assessments, safety appointments
Mine Health and Safety Act 29 of 1996Site inductions and safety records required on mine premises
National Road Traffic Act 93 of 1996Vehicle registration and roadworthiness records, driver licence and professional driving permit records
Cross-Border Road Transport Act 4 of 1998Cross-border permits for loads into neighbouring countries
Broad-Based Black Economic Empowerment Act 53 of 2003B-BBEE certificates and affidavits
Promotion of Access to Information Act 2 of 2000, Protection of Personal Information Act 4 of 2013This manual, PAIA requests and outcomes, Information Officer registration

7. Subjects and categories of records

SubjectCategories of records
Company secretarialIncorporation documents, share register, directors' resolutions, statutory returns
FinanceAnnual financial statements, management accounts, invoices, bank records, asset and finance agreements
TaxIncome tax, VAT, PAYE, UIF and skills levy records
Human resourcesEmployment contracts, payroll, leave, training, disciplinary and job application records
Clients and contractsQuotes, haulage and service contracts, delivery notes, weighbridge tickets, correspondence
Suppliers and subcontractorsSupplier agreements, subcontracting agreements, B-BBEE and tax compliance documents
Fleet and operationsVehicle records, maintenance logs, GPS tracking data, trip and load records, route plans
Health and safetyIncident reports, risk assessments, induction records, driver medical fitness certificates
PremisesCCTV recordings, lease and access records
Insurance and legalInsurance policies and claims, legal opinions, litigation records
Information technologyWebsite 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.

ItemFee
Request feeR140.00, except for a request for your own personal information
Photocopy or printed A4 pageR2.00 per page or part of a page
Copy on a flash drive you provideR40.00
Transcription of an audio recordR24.00 per A4 page
Search and preparationR145.00 per hour or part of an hour after the first hour, up to R435.00
Deposit, where search and preparation exceed 6 hoursOne third of the access fee
PostageThe 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 subjectsPersonal information
Clients and their staffNames, job titles, contact details, company registration and VAT numbers, addresses, bank details, contract and payment history
Suppliers and subcontractorsNames, contact details, registration and VAT numbers, bank details, B-BBEE and tax status, subcontracted drivers' licence and permit details
EmployeesNames, identity numbers, contact details, addresses, next of kin, qualifications, remuneration, tax and bank details, leave, disciplinary and training records
DriversDriving 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 applicantsCVs, qualifications, references and contact details
Visitors to our premisesCCTV images, names and times of visits
Website visitors and enquirersServer 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

RecipientInformation
South African Revenue ServiceTax, PAYE, VAT and UIF information
Department of Employment and Labour, Compensation FundUIF and COIDA records, injury reports
Auditors, accountants and legal advisersFinancial, employment and contract records they need
Banks, funders and insurersCompany and vehicle details, claims and finance applications
Mines, wash plants, ports and clientsDriver names, licence and PrDP details and vehicle details needed for site access and load tracking
Fleet tracking providerVehicle GPS location and driving data
Web and email hosting providerWebsite files, server logs and mailboxes, stored in South Africa
South African Police Service and courtsRecords 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.