PAIA Manual.

This Manual is published by Zentrio (Pty) Ltd (registration number 2026/489361/07, tax number 9612335225), trading as YohWeb("YohWeb", "the Company") in accordance with Section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA), as read with the Protection of Personal Information Act 4 of 2013 (POPIA) (which amended certain provisions of PAIA).

The purpose of this Manual is to:

• Inform you (the requester) of the categories of records YohWeb holds;
• Explain which records are available automatically (without a PAIA request);
• Explain which records require a formal PAIA request;
• Set out the procedure for making a PAIA request, the prescribed fees, and the response timelines;
• Detail the grounds on which we may refuse access;
• Explain how to appeal a refusal or lodge a complaint with the Information Regulator.

PAIA gives effect to the constitutional right of access to information held by the State and by private bodies, subject to justifiable limitations aimed at protecting privacy, commercial confidentiality, and other legitimate interests. This Manual balances your right of access with our obligations under POPIA to protect personal information.

This Manual is updated at least annually, or sooner if there are material changes to the Company's structure, operations, or applicable SA law.

Section 51(1)(a) of PAIA requires us to publish our contact details. They are:

Information Officer (per PAIA s51(1)(a) read with POPIA s17):

Registered & operating in the Republic of South Africa

PAIA gives every person (including juristic persons like companies, trusts and NGOs) the right of access to records held by private bodies, subject to certain grounds for refusal. The right is rooted in section 32 of the Constitution, which guarantees access to information held by the State and (in service of any right) by private bodies.

The right applies to:

• Any personal information the body holds about you (this overlaps with your rights under POPIA);
• Records you need to exercise or protect any rights (you must state which right you intend to exercise or protect);
• Public-interest records (subject to limitations and grounds for refusal).

Access is not automatic. You must submit a formal request using the prescribed form (Form C). We respond within 30 days — extendable by another 30 days in complex cases, with written notice to you (PAIA s27).

Section 51(1)(b)(i) of PAIA requires us to list records available without a PAIA request. The following are available on our website or on request from our Information Officer, free of charge:

• This PAIA Manual;
• Our Privacy Policy;
• Our Terms of Service;
• Our Cookie Policy;
• Service descriptions, pricing, and portfolio at yohweb.co.za;
• Public marketing materials, blog posts, case studies;
• Company contact details and physical address;
• Public records we're required to file (e.g. CIPC registration details, BBBEE certificate on request);
• Press releases and public statements.

These are also available in alternative formats on request (e.g. large print, audio, accessible PDF) — please contact us if you need an accessible version. We don't charge for reasonable alternative-format requests.

Section 51(1)(b)(ii) of PAIA requires us to list categories of records that may be requested (subject to grounds for refusal). The following categories of records are held by YohWeb:

Important: Records about third parties (other clients, our employees, our suppliers) cannot be disclosed without their consent — see Grounds for Refusal. POPIA also restricts disclosure of personal information where it would be unreasonable (POPIA s63 — equivalent to PAIA s34).

Section 51(1)(b)(iii) of PAIA requires us to describe the categories of records we may refuse access to. We may refuse access where one of the grounds in PAIA sections 33 to 46 applies, including:

• Trade secrets: Our proprietary tools, frameworks, AI prompts, automation recipes, pricing models, and internal processes (PAIA s40);
• Commercial / financial info of third parties: Information that could prejudice a third party's commercial position (PAIA s36);
• Client confidential information: Records belonging to other clients, including their CRM data, analytics, and project files (PAIA s37 + POPIA);
• Third-party personal information: Personal information of our staff, contractors, or other clients (PAIA s34 + POPIA s63 — unless consent is given or it would be reasonable to disclose);
• Legal privilege: Communications with our attorneys, legal advice, and litigation strategy (PAIA s37);
• Safety of individuals or property: Records that could endanger someone's life or physical safety (PAIA s38);
• Law enforcement: Records that could prejudice an investigation or prosecution (PAIA s44);
• Research information: Where disclosure would seriously prejudice research (PAIA s43);
• Defence / security / international relations: Records affecting the Republic's interests (PAIA s41);
• Economic interests of the State: Records affecting currency, exchange rates, or fiscal policy (PAIA s42).

If we refuse access (in whole or part), we'll tell you in writing with reasons, and inform you of your right to appeal — see Internal Appeal and Information Regulator.

Section 51(1)(c) of PAIA requires us to set out the procedure. To make a formal PAIA request:

1. Complete Form C — the prescribed PAIA request form, available at inforegulator.org.za or from our Information Officer. You don't have to use Form C — a letter or email with the same information is acceptable under PAIA s53(2), as long as it provides the required details.
2. Provide the required information:Your name & contact details; the record you want (be specific); the format you want it in (paper, electronic, CD, etc.); and which right you intend to exercise or protect with the information (and why you need it).
3. Submit it to our Information Officer by email (howzit@yohweb.co.za), WhatsApp (010 880 1234), or post (Randburg, Johannesburg, 2194). Mark it for the attention of the Information Officer.
4. Pay the request feeof R50 (if applicable — personal-info requests under POPIA are free). We'll send you an invoice and a written acknowledgment of receipt.
5. Wait — we respond within 30 days (PAIA s25). If we need more time (e.g. the request is complex, involves third parties, or requires extensive search), we may extend once by another 30 days, with written notice to you (PAIA s27).
6. Access — if approved, pay the access fee (if any — see Fees) and collect the records in the format you requested. We may impose reasonable conditions to protect the records (e.g. inspecting on our premises for originals).

PAIA distinguishes between mandatory grounds (where we must refuse) and discretionary grounds (where we may refuse, weighing your right of access against the interests protected).

Mandatory refusal (PAIA s34–s38):

• s34 — Unreasonable disclosure of personal information about a third party (natural person), unless that third party consents or the disclosure would be reasonable. (POPIA s63 mirrors this.)
• s35 — Commercial information of a third party where disclosure would likely cause harm to their commercial or financial interests (trade secrets, financial/technical/commercial info, supplier/client lists).
• s36 — Commercial information of YohWeb where disclosure would likely harm our commercial position (trade secrets, financial info, computer programs we own, our pricing models).
• s37 — Information subject to legal privilege (lawyer-client communications, litigation strategy, settlement negotiations).
• s38 — Safety of individuals or property where disclosure could endanger someone's life or physical safety, or enable a crime.

Discretionary refusal (PAIA s39–s46):

• s39 — Research information of a third party, where disclosure would seriously prejudice research;
• s40 — Defence, security & international relations of the Republic;
• s41 — Economic interests & financial welfare of the Republic (currency, exchange rates, fiscal policy);
• s42 — Commercial activities of public bodies;
• s43 — Law enforcement & investigations (current or prospective);
• s44 — Legal proceedings where disclosure would prejudice a fair trial;
• s45 — Defence of the Republic;
• s46 — Operations of public bodies (frank advice, policy deliberations, occupational or professional secrets).

Even where a ground for refusal applies, we'll consider whether the public-interest override in PAIA s46(2) or the disclosure-of-irrelevant-portions rule in s28 applies — we'll release what we can, redacting what we must.

If we refuse, we'll give you written reasons (PAIA s25(3)) and tell you how to appeal.

Section 51(1)(d) of PAIA requires us to set out the applicable fees. PAIA fees are prescribed by regulation (the most recent being the PAIA Regulations, 2021, read with the POPIA Regulations). Current fees:

Fees are reviewed by the Information Regulator periodically. We'll always confirm the total in writing before you commit. Personal-info requests under POPIA s23 are free (once per year) — we won't charge you to see your own data.

If your request is refused (in whole or in part), or you're unhappy with our response, you have several avenues:

1. Internal appeal (within 30 days of refusal):Submit a written appeal to our Information Officer. A senior manager not involved in the original decision will review it within 21 days and respond in writing with reasons. There's no fee for an internal appeal.
2. Complaint to the Information Regulator (within 30 days of internal appeal outcome): Lodge a complaint with the Information Regulator of South Africa using Form 1 (available at inforegulator.org.za). The Regulator can investigate, mediate, and issue an enforcement notice.
3. Application to court (as a last resort):If the Regulator's process doesn't resolve it, you may apply to a competent court (usually the High Court) for appropriate relief under PAIA s78. Time limits apply (usually 30 days from the decision you're challenging).

The Information Regulator of South Africais the independent constitutional body established under POPIA to oversee both POPIA and PAIA. You can contact them if you're unhappy with how we've handled your request, or if you want to complain about a POPIA breach.

The Regulator can investigate complaints, attempt conciliation, issue enforcement notices, conduct assessments, and refer matters to court. Their services are free.

Section 51(3) of PAIA requires us to make this Manual available in three places:

• On our website: At yohweb.co.za/paia-manual — free to read or download in PDF.
• At our offices: A printed copy is available for inspection at our Randburg and Sandton studios during office hours (Mon–Fri 08:00–17:00 SAST). Just WhatsApp ahead so we're ready.
• At the Information Regulator: We submit a copy to the Information Regulator of South Africa as required by PAIA section 51(3) and POPIA section 18.

This Manual is also available in accessible formats (large print, audio, accessible PDF) on request — email our Information Officer and we'll sort it sharp sharp.

This Manual was last reviewed on the date shown at the top of this page. We'll review it at least annually, or sooner if there are material changes to our business, SA law, or Information Regulator guidance.

This Manual is published in compliance with PAIA & POPIA · Last reviewed annually · Proudly Mzansi