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PAIA - PROMOTION OF ACCESS TO INFORMATION MANUAL ::

4 Seasons Car Hire CC

 

 

PAIA MANUAL

 

 

Prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 (as amended)

 

DATE OF COMPILATION: 09/09/2025

DATE OF REVISION: 16/04/2026

 

TABLE OF CONTENTS

 

 

1.    LIST OF ACRONYMS AND ABBREVIATIONS.. 3

2.    PURPOSE OF PAIA MANUAL. 3

3.    KEY CONTACT DETAILS FOR ACCESS TO INFORMATION OF 4 SEASONS CAR HIRE CC.. 4

4.    GUIDE ON HOW TO USE PAIA AND HOW TO OBTAIN ACCESS TO THE GUIDE. 4

5.    CATEGORIES OF RECORDS OF 4 SEASONS CAR HIRE CC WHICH ARE AVAILABLE WITHOUT A PERSON HAVING TO REQUEST ACCESS.. 7

6.    DESCRIPTION OF THE RECORDS 4 SEASONS CAR HIRE CC WHICH ARE AVAILABLE IN ACCORDANCE WITH ANY OTHER LEGISLATION………………………………………………………8

7.    DESCRIPTION OF THE SUBJECTS ON WHICH THE BODY HOLDS RECORDS AND CATEGORIES OF RECORDS HELD ON EACH SUBJECT BY 4 SEASONS CAR HIRE CC.. 8

8.    PROCESSING OF PERSONAL INFORMATION.. 8

8.1       Purpose of Processing Personal Information. 8

8.2       Description of the categories of Data Subjects and of the information or categories of information relating there to. 9

8.3       The recipients or categories of recipients to whom the personal information may be supplied. 9

8.4       Planned transborder flows of personal information. 10

8.5       Personal information received from third parties……………………………………………...10

8.6       General description of Information Security Measures to be implemented by the responsible party to ensure the confidentiality integrity and availability of the information. 10

8.7        Data breaches…………………………………………………………………………………....11

9.    AVAILABILITY OF THE MANUAL………………………………………………………………….…11

10.  UPDATING OF THE MANUAL. 12

11. FORMS……………………………………………………………………………………………………12

 

 

 

 

 

1.LIST OF ACRONYMS AND ABBREVIATIONS

 

  1. “CEO”                             Chief Executive Officer

 

  1. “DIO”                              Deputy Information Officer;

 

  1. “IO“                                 Information Officer;

 

 

  1. “Minister”                       Minister of Justice and Correctional Services;

 

  1. “PAIA”                            Promotion of Access to Information Act No. 2 of 2000( as Amended;

 

  1. “POPIA”                          Protection of Personal Information Act No.4 of 2013;

 

  1. “Regulator”                    Information Regulator; and

 

 

  1. “Republic”                      Republic of South Africa

 

 

 

2.PURPOSE OF PAIA MANUAL

 

 

This PAIA Manual is useful for the public to-

 

  1. check the categories of records held by a body which are available without a person having to submit a formal PAIA request;

 

  1. have a sufficient understanding of how to make a request for access to a record of the body, by providing a description of the subjects on which the body holds records and the categories of records held on each subject;

 

  1. know the description of the records of the body which are available in accordance with any other legislation;

 

  1. access all the relevant contact details of the Information Officer and Deputy Information Officer who will assist the public with the records they intend to access;

 

  1. know the description of the guide on how to use PAIA, as updated by the Regulator and how to obtain access to it;

 

  1. know if the body will process personal information, the purpose of processing of personal information and the description of the categories of data subjects and of the information or categories of information relating thereto;

 

  1. know the description of the categories of data subjects and of the information or categories of information relating thereto;

 

  1. know the recipients or categories of recipients to whom the personal information may be supplied;

 

  1. know if the body has planned to transfer or process personal information outside the Republic of South Africa and the recipients or categories of recipients to whom the personal information may be supplied; and

 

  1. know whether the body has appropriate security measures to ensure the confidentiality, integrity and availability of the personal information which is to be processed.

 

3.KEY CONTACT DETAILS FOR ACCESS TO INFORMATION OF 4 SEASONS CAR HIRE CC

 

  1. Chief Information Officer

 

Name:                              Wouter Evers

Email:                               w.evers@4seasons-car-rental.com

 

 

  1. Access to information general contacts
  2.                                w.evers@4seasons-car-rental.com

 

 

  1. National or Head Office

 

Postal Address:               30 Topaz Street

Somerset West

7130

 

Physical Address:            30 Topaz Street

Somerset West

7130

 

Email:                              w.evers@4seasons-car-rental.com

Tel:                                  (021) 855 5691

Website:                          https://www.4seasons-car-rental.com/

 

  

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

 

 

  1. The Regulator has, in terms of section 10(1) of PAIA, as amended, updated and made available the revised Guide on how to use PAIA (“Guide”), in an easily comprehensible form and manner, as may reasonably be required by a person who wishes to exercise any right contemplated in PAIA and POPIA.

 

  1. The Guide is available in each of the official languages and in braille.

 

 

  1. The aforesaid Guide contains the description of

 

  1.  the objects of PAIA and POPIA;

 

  1. the postal and street address, phone and fax number and, if available, electronic mail address of-

 

  1. the Information Officer of every public body, and

 

  1. every Deputy Information Officer of every public and private body designated in terms of section 17(1) of PAIA1 and section 56 of POPIA2;

 

  1. the manner and form of a request for-

 

  1. access to a record of a public body contemplated in section 113; and

 

  1. access to a record of a private body contemplated in section 504;

 

  1. the assistance available from the IO of a public body in terms of PAIA and POPIA;

 

  1. the assistance available from the Regulator in terms of PAIA and POPIA;

 

  1. all remedies in law available regarding an act or failure to act in respect of a right or duty conferred or imposed by PAIA and POPIA, including the manner of lodging-

 

 

 
 
 

1 Section 17(1) of PAIA- For the purposes of PAIA, each public body must, subject to legislation governing the employment of personnel of the public body concerned, designate such number of persons as deputy information officers as are necessary to render the public body as accessible as reasonably possible for requesters of its records.

2 Section 56(a) of POPIA- Each public and private body must make provision, in the manner prescribed in section 17 of the Promotion of Access to Information Act, with the necessary changes, for the designation of such a number of persons, if any, as deputy information officers as is necessary to perform the duties and responsibilities as set out in section 55(1) of POPIA.

3 Section 11(1) of PAIA- A requester must be given access to a record of a public body if that requester complies with all the procedural requirements in PAIA relating to a request for access to that record; and access to that record is not refused in terms of any ground for refusal contemplated in Chapter 4 of this Part.

 

4 Section 50(1) of PAIA- A requester must be given access to any record of a private body if-

  1. that record is required for the exercise or protection of any rights;
  2. that person complies with the procedural requirements in PAIA relating to a request for access to that record; and
  3. access to that record is not refused in terms of any ground for refusal contemplated in Chapter 4 of this Part.

 

 

  1. an internal appeal;

 

  1. a complaint to the Regulator; and

 

 

  1. an application with a court against a decision by the information officer of a public body, a decision on internal appeal or a decision by the Regulator or a decision of the head of a private body;

 

  1. the provisions of sections 145 and 516 requiring a public body and private body, respectively, to compile a manual, and how to obtain access to a manual;

 

  1. the provisions of sections 157 and 528 providing for the voluntary disclosure of categories of records by a public body and private body, respectively;

 

  1. the notices issued in terms of sections 229 and 5410 regarding fees to be paid in relation to requests for access; and

 

  1. the regulations made in terms of section 9211.

 

 

  1. Members of the public can inspect or make copies of the Guide from the offices of the public and private bodies, including the office of the Regulator, during normal working hours.

 

  1. The Guide can also be obtained-

 

  1. upon request to the Information Officer;
  2. from the website of the Regulator (https://www.justice.gov.za/inforeg/).

 

 
 
 

5 Section 14(1) of PAIA- The information officer of a public body must, in at least three official languages, make available a manual containing information listed in paragraph 4 above.

 

6 Section 51(1) of PAIA- The head of a private body must make available a manual containing the description of the information listed in paragraph 4 above.

7 Section 15(1) of PAIA- The information officer of a public body, must make available in the prescribed manner a description of the categories of records of the public body that are automatically available without a person having to request access

8 Section 52(1) of PAIA- The head of a private body may, on a voluntary basis, make available in the prescribed manner a description of the categories of records of the private body that are automatically available without a person having to request access

9 Section 22(1) of PAIA- The information officer of a public body to whom a request for access is made, must by notice require the requester to pay the prescribed request fee (if any), before further processing the request.

10 Section 54(1) of PAIA- The head of a private body to whom a request for access is made must by notice require the requester to pay the prescribed request fee (if any), before further processing the request.

 

11 Section 92(1) of PAIA provides that –“The Minister may, by notice in the Gazette, make regulations regarding-

  1. any matter which is required or permitted by this Act to be prescribed;
  2. any matter relating to the fees contemplated in sections 22 and 54;
  3. any notice required by this Act;
  4. uniform criteria to be applied by the information officer of a public body when deciding which categories of records are to be made available in terms of section 15; and
  5. any administrative or procedural matter necessary to give effect to the provisions of this Act.”

 

 

  1. A copy of the Guide is also available in the following two official languages, for public inspection during normal office hours-

 

  1.  
    1. English And Afrikaans

 

 

5.CATEGORIES OF RECORDS OF 4 SEASONS CAR HIRE CC WHICH ARE AVAILABLE WITHOUT A PERSON HAVING TO REQUEST ACCESS

 

Category of records

Availability

PAIA Manual

Website or by email request

Contact Details

Website and business listings

Company Registration Information

Website or available via email request

Vehicle Rental Options & Pricing

Website

Branch Locations & Depots

Website

Terms & Conditions (e.g. Refund Policy)

Website

Privacy & Cookie Policies

Website

Booking Management Tools

Website

Rental Partners

Website

 

 

  1. DESCRIPTION OF THE RECORDS 4 SEASONS CAR HIRE CC WHICH ARE AVAILABLE IN ACCORDANCE WITH ANY OTHER LEGISLATION

 

Category of Records

Applicable Legislation

PAIA Manual

Promotion of Access to Information Act (Act 2 of 2000)

Employment Contracts

Basic Conditions of Employment Act (Act 75 of 1997)

Health & Safety Reports

Occupational Health and Safety Act (Act 85 of 1993)

 

Tax Records (e.g. VAT, PAYE)

Income Tax Act (Act 58 of 1962) and Value Added Tax Act (Act 89 of 1991)

Financial Statements

Companies Act (Act 71 of 2008)

UIF Registration & Contributions

Unemployment Insurance Act (Act 63 of 2001)

COIDA Registration & Incident Reports

Compensation for Occupational Injuries and Diseases Act (Act 130 of 1993)

POPIA Compliance Documentation

Protection of Personal Information Act (Act 4 of 2013)

B-BBEE Certificates

Broad-Based Black Economic Empowerment Act (Act 53 of 2003)

Vehicle Licensing & Roadworthy Records

National Road Traffic Act (Act 93 of 1996)

 

 

 

 

7.DESCRIPTION OF THE SUBJECTS ON WHICH THE BODY HOLDS RECORDS AND CATEGORIES OF RECORDS HELD ON EACH SUBJECT BY 4 SEASONS CAR HIRE CC

 

Subjects on which the body holds records

Categories of records

Finance

  • Annual financial statements
  • Invoices, receipts, and bank records
  • Tax and VAT submissions
  • Payroll records and budgets

Human Resources (HR)

  • Employee records and personal files
  • Recruitment advertisements and applications
  • HR policies and procedures
  • Training and skills development documents

Operations

  • Health and safety reports
  • Vehicle maintenance logs and incident reports
  • Standard operating procedures (SOPs)
  • Fleet usage and scheduling records

Supply Chain / Fleet Management

  • Vehicle acquisition and disposal records
  • Supplier contracts and service agreements Inventory and parts tracking
  • Insurance and registration documents

Legal & Compliance

  • PAIA Manual
  • POPIA compliance documentation
  • Licensing and regulatory certificates
  • B-BBEE documentation

Customer Service & Bookings

  • Booking confirmations and rental agreements
  • Customer feedback and complaint logs
  • Refund and cancellation records
  • Marketing and promotional materials

 

8.PROCESSING OF PERSONAL INFORMATION

 

8.1Purpose of Processing Personal Information

 

4 Seasons Car Hire CC collects and uses personal information for operational purposes, in line with South African privacy and data protection laws:

 

  • Facilitating vehicle rentals, bookings, and related services.
  • Verifying identity and driving credentials of clients (e.g., license and ID checks).
  • Drafting and managing rental agreements and legal documentation.
  • Communicating with clients regarding booking confirmations, vehicle availability, and service updates.
  • Managing marketing communications with consent, including newsletters, promotions, and travel alerts.
  • Ensuring regulatory and legislative compliance (e.g., POPIA, COIDA, SARS reporting).
  • Maintaining accurate records for accounting, fleet management, and administrative purposes.

                                   

8.2Description of the categories of Data Subjects and of the information or categories of information relating there to

 

 

Categories of Data Subjects

 

Personal Information that may be processed

Customers / Clients

Full name and surname

Physical or postal address

ID or passport number

Driver’s license details

Employment status

Bank account and payment details

Employees

Contact information (phone, email, address)

ID number and employment history

Tax number and payroll data

Leave and attendance records

Medical aid and provident fund membership

Suppliers / Contractors

Company name and registration number

Contact person’s name and details

Banking information

B-BBEE certificate and other compliance documents

Website Users / Enquirers

Name and contact details submitted via online forms

IP address and browser data

Booking preferences and rental history

Rental Partners

Business contact details

Partnership agreements and service records

Licensing and insurance documentation

 

 

8.3The recipients or categories of recipients to whom the personal information may be supplied

 

 

Recipients or Categories of Recipients to whom the personal information may be supplied

Purpose for Supplying Personal Information

Category of Personal Information

South African Police Service (SAPS)

Criminal background checks and legal compliance

ID numbers, driver’s license details, criminal history

Banks and Financial Institutions

Processing salary payments and verifying account details

Employee banking details, salary information

Debt Collection Agencies

Recovering outstanding accounts

Customer contact details, account balances, payment history

Benefit Administrators

Managing employee benefits such as medical aid and pensions

ID numbers, medical aid and provident fund membership

Government Departments (e.g. SARS)

Statutory reporting and regulatory compliance

Tax numbers, UIF contributions, employment records

Insurance Providers

Underwriting policies and processing claims

Vehicle details, driver information, claim history

IT and System Service Providers

Maintaining secure systems and managing booking platforms

Usernames, email addresses, booking data

Rental Partners and Affiliates

Coordinating third-party or cross-border vehicle rentals

Booking details, customer contact information

Legal Advisors or Auditors

Ensuring legal compliance and conducting financial audits

Financial records, contracts, compliance documentation

 

 

8.4Planned transborder flows of personal information

 

4 Seasons Car Hire CC makes use of secure cloud-based services which may result in certain categories of personal information being stored or processed outside the Republic of South Africa.

                   

Destination Country: United States

  • Cloud-based data storage and communication services through Microsoft 365 and related platforms.

 

Types of Information:

  • Employee information: names, contact details, HR and payroll records.
  • Client and prospective client information: email addresses, contact details, booking preferences, invoicing information.
  • General communication data: emails, shared documents, meeting notes.

 

8.5Personal information received from third parties

 

When we receive personal information from a third party on behalf of a data subject, we assume confirmation that they have written consent from the data subject that they are aware of the contents of this PAIA manual and the privacy policy, and do not have any objection to our processing their information in accordance with this policy.

 

8.6General description of Information Security Measures to be implemented by the responsible party to ensure the confidentiality integrity and availability of the information

 

4 Seasons Car Hire CC applies appropriate technical and organizational measures to safeguard personal information against loss, misuse, unauthorized access, or cyber threats. All protective actions are implemented in accordance with the Protection of Personal Information Act (POPIA) 4 of 2013 and industry best practices. Current security measures in place include:

 

  • Data Encryption
    • Encrypts files, emails, and communications to prevent unauthorized access
    • Applied to cloud storage, internal databases, and online booking systems

 

  • Antivirus and Anti-malware Software
    • Installed on all employee devices
    • Regularly updated to detect and block viruses, ransomware, and spyware

 

  • Firewalls and Network Security
    • Protects internal systems from external threats and unauthorized access
    • Monitors incoming and outgoing traffic for suspicious activity

 

  • Access Controls and User Authentication
    • Role-based access to sensitive data
    • Password protection and multi-factor authentication for system logins

 

  • Physical Security Measures
    • Restricted access to office premises using keycards or biometric systems
    • Secure storage of paper records in locked filing cabinets

 

  • Regular Backups and Data Recovery Plans
    • Automated backups of critical data to prevent loss
    • Disaster recovery protocols in place for system failures

 

  • Employee Training and Awareness
    • Staff educated on data protection policies and cybersecurity best practices
    • Ongoing training to identify phishing and social engineering threats

 

  • Compliance Monitoring
    • Regular audits to ensure alignment with POPIA and other data protection laws
    • Documentation of data handling procedures and breach response plans

 

 

  1. Data Breaches

 

Where are the reasonable grounds to believe that the personal information of a data subject has been accessed or acquired by any unauthorized person, the body shall notify the Information Regulator and the data subject, unless the identity of such data subject cannot be established.

 

The notification will be made as soon as reasonably possible after the discovery of the compromise, taking into account the legitimate needs of law enforcement or any measures reasonably necessary to determine the scope of the compromise and to restore the integrity of the responsible party’s information system.

 

 

9.AVAILABILITY OF THE MANUAL

 

  1. A copy of the Manual is available-

 

  1. head office of 4 Seasons Car Hire CC for public inspection during normal business hours;
  2. on their website

 

  1. to any person upon request and upon the payment of a reasonable prescribed fee; and

 

  1. to the Information Regulator upon request.

 

  1. A fee for a copy of the Manual as contemplated in annexure B of the Regulations shall be payable per each A4-size photocopy made.

 

 

10.UPDATING OF THE MANUAL

 

 

The head of Webb Accountants (SA) will on a regular basis update this manual.

 

 

  1. FORMS

 

The following forms are attached hereto for ease of reference:

 

  1. Form 1: Request for a copy of the guide
  2. Form 2: Request for access to record
  3. Form 3: Outcome of request and fees payable
  4. Form 5: Complaint form

 

 

Signed by

 

 

W. Evers

 

 

 

 
 

 

W. Evers

Director

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