PAIA MANUAL (SECTION 51) Paradigm Management Consulting
Prepared in terms of Section 51 of the Promotion of Access to Information Act, 2 of 2000 (PAIA), as amended, and incorporating required POPIA disclosures for private bodies.
Version: 1.1
Date of compilation: 07 April 2026
Next review date: 07 April 2027 (or earlier if records/processes change)
1) LIST OF ACRONYMS AND ABBREVIATIONS
• CEO – Chief Executive Officer / Managing Director
• DIO – Deputy Information Officer
• IO – Information Officer
• PAIA – Promotion of Access to Information Act, 2 of 2000 (as amended)
• POPIA – Protection of Personal Information Act, 4 of 2013
• Regulator – Information Regulator (South Africa)
• Republic – Republic of South Africa
2) PURPOSE OF THIS PAIA MANUAL
• Provide the public with information on the types and categories of records held by Paradigm Management Consulting.
• Explain how to request access to records in terms of PAIA.
• Describe records that may be available through other legislation.
• Provide POPIA-related disclosures required in a PAIA Manual for a private body (purpose of processing; categories of data subjects and personal information; recipients; planned transborder flows; and a general security description).
3) SCOPE
• This Manual applies to Paradigm Management Consulting and all records held by Paradigm relating to workplace bullying consulting, investigations, training, workshops, advisory services, book and digital product sales (website/checkout), and internal operations and governance.
4) DETAILS OF THE PRIVATE BODY (Section 51(1)(a))
• Name of private body: Paradigm Management Consulting
• Website: https://paradigmconsulting.co.za/
• Physical address: 41 Chris Barnard Street, Vorna Valley, Midrand, Johannesburg, South Africa
• Email: info@paradigmconsulting.co.za
• Telephone: +27 79 743 3834
5) INFORMATION OFFICER (IO) AND DEPUTY INFORMATION OFFICER (DIO)
• Information Officer (IO): Managing Director (Grant Saptoe)
• Email: info@paradigmconsulting.co.za
• Telephone: +27 79 743 3834
• Physical address: 41 Chris Barnard Street, Vorna Valley, Midrand, Johannesburg
• Deputy Information Officer (DIO): Not appointed.
6) GUIDE ON HOW TO USE PAIA (Section 10 Guide)
• A guide compiled by the Information Regulator is available to assist requesters in exercising rights under PAIA and explains how to submit requests. • How to obtain the Guide: request it from the Information Regulator (South Africa) or via its website/resources where published.
7) CATEGORIES OF RECORDS AVAILABLE WITHOUT A PAIA REQUEST (Section 52(2) Notice)
• Records publicly available on Paradigm’s website (including articles, service descriptions, general information, and product listings).
• Marketing brochures and published training outlines that Paradigm makes publicly available.
• Note: If no formal Section 52(2) notice applies, access without a formal request is limited to records that are publicly available.
8) RECORDS AVAILABLE IN TERMS OF OTHER LEGISLATION (Section 51(1)(b)(iii))
• Certain records may be available in terms of applicable South African legislation, including (where relevant): Companies Act; Tax Administration/VAT/Income Tax legislation; Basic Conditions of Employment Act and Labour Relations Act (employment records, if applicable); and the Consumer Protection Act (product sales and consumer rights).
9) SUBJECTS AND CATEGORIES OF RECORDS HELD (Section 51(1)(b)(iv))
• Availability is subject to the grounds of refusal in PAIA and other applicable law.
• 9.1 Corporate & Governance: Company registration records; governance and compliance documentation; policies and procedures.
•9.2 Finance & Administration: Invoices, quotations, payment confirmations; accounting records; supplier and contractor records.
• 9.3 Client Services & Projects: Consultation records; proposals; service agreements; attendance registers; investigation documentation (confidential); reports and recommendations (confidential).
• 9.4 Human Resources (if applicable): Employment contracts; HR policies; payroll-related information (if applicable).
• 9.5 Marketing & Communications: Published articles, newsletters, website content; client communications.
• 9.6 Website, E-commerce & Support: WooCommerce orders and transaction references; delivery logs; customer support tickets and email queries.
10) REQUEST PROCEDURE (HOW TO REQUEST ACCESS)
• 10.1 Request form: Requests must be submitted on the prescribed Request for Access to Record of Private Body (Form C).
• 10.2 Submission: Address requests to the Information Officer using the contact details in Section 5. •
10.3 Information required: Provide sufficient detail to identify the record; the right being exercised or protected; and an explanation of why the record is required for that right.
• 10.4 Timeframes: Paradigm will respond within PAIA timeframes and may grant, refuse on lawful grounds, or request clarification where needed.
• 10.5 Fees: Prescribed request and access fees may apply depending on the request and records requested (in line with PAIA regulations). Fees are available on request.
11) GROUNDS FOR REFUSAL OF ACCESS (SUMMARY)
• Access may be refused where PAIA permits, including to protect personal information of third parties, commercial confidentiality, legally privileged information, and confidential client/investigation records, and for other lawful refusal grounds. PART B — POPIA INFORMATION REQUIRED IN THE PAIA MANUAL (Section 51(1)(c))
• PAIA Section 51 requires private bodies to include POPIA processing disclosures: purpose of processing; categories of data subjects and personal information; recipients; planned transborder flows; and a general description of security measures.
12) PURPOSE OF PROCESSING PERSONAL INFORMATION
• Paradigm processes personal information to provide consulting, training and advisory services; process orders and deliver products (books/eBooks); communicate with clients and enquiries; meet legal/regulatory obligations; and maintain security and prevent fraud.
13) CATEGORIES OF DATA SUBJECTS AND PERSONAL INFORMATION
• Clients and client representatives: names, contact details, organisational information.
• Website visitors: limited technical data, cookies where enabled.
• Customers: billing and delivery details, order history, transaction references.
• Suppliers/service providers: contact and contractual information.
• Employees/contractors (if applicable): employment/contract information necessary for operations.
14) RECIPIENTS / CATEGORIES OF RECIPIENTS
• Personal information may be supplied to payment gateway providers (e.g., PayFast); couriers/delivery providers; hosting/IT support providers; professional advisers (accountants/legal) where necessary; and regulators/law enforcement where legally required.
15) PLANNED TRANSBORDER FLOWS
• Where cloud, email, hosting or analytics providers process data outside South Africa, Paradigm will take reasonable steps to ensure appropriate safeguards consistent with POPIA.
16) GENERAL DESCRIPTION OF INFORMATION SECURITY MEASURES
• Paradigm applies reasonable safeguards to protect confidentiality, integrity and availability of personal information, including access control, password discipline, limited access on a need-to-know basis, secure hosting and updates where applicable, backups, and malware protection practices where implemented.
17) AVAILABILITY AND UPDATING OF THIS MANUAL (Section 51(3))
• This Manual will be updated periodically and made available on the website (once published), at the principal place of business for inspection during business hours, to any person upon request (a reasonable reproduction fee may apply), and to the Information Regulator upon request.
ANNEXURE A — REQUEST FORM (FORM C)
• Attach or link the prescribed PAIA Form C (Request for Access to Record of Private Body) when publishing
this Manual online, or make it available upon request.
CONTACT / PAIA REQUEST SUBMISSION FORM (for convenience)
This form is provided for convenience only. Formal PAIA requests should be submitted using the prescribed
Form C, where applicable.