PAIA

PAIA MANUAL

Manual prepared in terms of Section 51 of the Promotion of Access to Information Act 2 of 2000, as amended

Business: Gensys Security Solutions
Legal Entity: Gensys Security Solutions cc
Registration Number: 2010/115221/23
Physical Address: 20, Childrens Way, Bergvliet, South Africa
Postal Address: 20, Childrens Way, Bergvliet, South Africa
Telephone: +27 83 236 5391
Email: info@gensys-security.co.za
Website: https://gensys-security.co.za

Information Officer: A J Askew – Managing Director
Information Officer Email: paia@gensys-security.co.za

Effective Date: 21 August 2026
Version: 1.0

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1. INTRODUCTION

This Manual is prepared in accordance with the requirements of the Promotion of Access to Information Act 2 of 2000 ("PAIA"), as amended.

PAIA gives effect to the constitutional right of access to information held by public and private bodies where that information is required for the exercise or protection of rights.

The purpose of this Manual is to:

1. provide information about Gensys Security Solutions and the records it holds;
2. explain how a person may request access to records held by Gensys Security Solutions;
3. identify records that may be available without submitting a formal PAIA request;
4. provide the contact details of the person responsible for handling PAIA requests;
5. explain the grounds upon which access to information may be refused;
6. explain the remedies available to a requester; and
7. provide information concerning the processing of personal information by Gensys Security Solutions in terms of the Protection of Personal Information Act 4 of 2013 ("POPIA").

This Manual should be read together with Gensys Security Solutions' Privacy Policy and other applicable policies.

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2. DETAILS OF Gensys Security Solutions

2.1 Business Activities

Gensys Security Solutions operates as an e-commerce and/or retail business providing products and related services to customers in South Africa.

The business may conduct activities including:

• online retail sales;
• product procurement and supply;
• order processing;
• payment processing;
• customer support;
• delivery and logistics;
• returns and refunds;
• marketing and promotional activities;
• website and online platform operations;
• supplier and service-provider management; and
• other activities associated with the operation of an e-commerce business.

The exact activities of Gensys Security Solutions may change from time to time.

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3. CONTACT DETAILS OF THE INFORMATION OFFICER

The Information Officer is responsible for facilitating requests for access to information in terms of PAIA.

Information Officer: A J Askew
Position: Managing Director
Physical Address: 20, Childrens Way, Bergvliet, South Africa
Postal Address: 20, Childrens Way, Bergvliet, South Africa
Email: paia@gensys-security.co.za

PAIA requests should preferably be submitted in writing to the Information Officer using the prescribed PAIA request form.

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4. THE INFORMATION REGULATOR

The Information Regulator is the independent regulatory authority responsible for matters relating to PAIA and POPIA.

The Information Regulator provides PAIA guidance, forms and information concerning access to records.

Information Regulator

Physical Address:
Woodmead North Office Park
54 Maxwell Drive
Woodmead
Johannesburg
South Africa

Postal Address:
P.O. Box 31533
Braamfontein
Johannesburg
2017

Telephone: 010 023 5200
Email: enquiries@inforegulator.org.za

The Information Regulator's PAIA eServices platform provides access to PAIA manuals and related resources.

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5. GUIDE ON HOW TO USE PAIA

The Information Regulator publishes a Guide explaining how a person may exercise rights under PAIA and POPIA.

A requester is encouraged to consult the current Guide before submitting a request.

The Guide explains matters including:

• the rights available under PAIA;
• how to request access to a record;
• the prescribed forms;
• applicable fees;
• grounds for refusal;
• complaints and other remedies; and
• relevant POPIA rights.

The official Information Regulator resources should be consulted for the current version of the Guide and prescribed forms.

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6. RECORDS HELD BY Gensys Security Solutions

Gensys Security Solutions may hold records relating to the following categories.

6.1 Corporate Records

These may include:

• registration documents;
• founding documents;
• company/shareholder records where applicable;
• organisational records;
• policies and procedures;
• minutes and resolutions;
• statutory records;
• licences and permits;
• agreements and contracts; and
• correspondence relating to the operation of the business.

Access to certain corporate records may be restricted by applicable legislation.

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6.2 Financial Records

These may include:

• accounting records;
• invoices;
• receipts;
• payment records;
• financial statements;
• banking records;
• tax records;
• budgets;
• creditor records;
• debtor records;
• supplier payment records; and
• other financial information.

Access may be refused where disclosure would prejudice the legitimate commercial or financial interests of Gensys Security Solutions or another party.

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6.3 Human Resources Records

These may include:

• employment applications;
• employee records;
• employment contracts;
• payroll records;
• disciplinary records;
• performance records;
• leave records;
• training records;
• workplace policies;
• correspondence with employees; and
• other personnel-related records.

Personal information relating to employees and other individuals will be protected in accordance with applicable privacy legislation.

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6.4 Customer Records

These may include:

• customer names;
• contact details;
• delivery addresses;
• account information;
• order histories;
• invoices;
• correspondence;
• complaints;
• returns and refunds;
• customer service records; and
• transaction information.

Access to another person's personal information will generally be subject to the requirements and limitations of PAIA and POPIA.

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6.5 Supplier and Contractor Records

These may include:

• supplier agreements;
• quotations;
• invoices;
• purchase orders;
• service agreements;
• correspondence;
• supplier contact details;
• delivery records; and
• contractor information.

Commercially sensitive information may be protected from disclosure.

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6.6 Marketing Records

These may include:

• advertising material;
• marketing campaigns;
• promotional material;
• newsletters;
• social media content;
• customer communications;
• marketing databases; and
• website content.

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6.7 Information Technology Records

These may include:

• website records;
• website administration records;
• system documentation;
• software licences;
• IT service agreements;
• security policies;
• technical documentation;
• system logs; and
• other electronic records.

Access may be restricted where disclosure could compromise the security of information systems.

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6.8 Legal Records

These may include:

• agreements;
• legal correspondence;
• legal opinions;
• litigation records;
• dispute records;
• regulatory correspondence; and
• records relating to legal proceedings.

Certain legal records may be privileged and/or protected from disclosure.

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7. RECORDS AUTOMATICALLY AVAILABLE

Certain information about Gensys Security Solutions may be made available without a formal PAIA request.

Depending on the information concerned, this may include:

• publicly available website information;
• product information;
• publicly available terms and conditions;
• publicly available contact information;
• publicly available marketing material;
• publicly available company information; and
• other information that Gensys Security Solutions voluntarily makes available.

The fact that a category of information is listed in this section does not necessarily mean that every record within that category will be available.

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8. REQUESTING ACCESS TO RECORDS

A person requesting access to a record held by Gensys Security Solutions must submit a request in the prescribed form and manner.

The request must contain sufficient information to allow Gensys Security Solutions to identify:

1. the record or records being requested;
2. the requester;
3. the form of access required;
4. the right the requester seeks to exercise or protect; and
5. why the requested record is required for the exercise or protection of that right.

Where a person makes a request on behalf of another person, appropriate proof of authority may be required.

PAIA provides that a request for access to a record of a private body must be made in the prescribed form to the private body at its address, fax number or electronic mail address.

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9. PRESCRIBED PAIA REQUEST FORM

A requester should use the applicable prescribed PAIA request form.

The current prescribed forms should be obtained from the Information Regulator or another official government source to ensure that the latest version is used.

The request should be sent to:

Information Officer – Gensys Security Solutions

Email: paia@gensys-security.co.za

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10. FEES

Where applicable, Gensys Security Solutions may require payment of prescribed fees in accordance with PAIA and the applicable regulations.

The requester may be required to pay a prescribed request fee before the request is processed.

Additional fees may apply where permitted, including costs associated with:

• searching for records;
• preparing records;
• reproduction;
• transcription;
• copying;
• postage; or
• other permitted forms of access.

The applicable fee will be communicated to the requester where required.

PAIA provides for fees relating to requests for records held by private bodies.

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11. PROCESSING OF PAIA REQUESTS

Upon receiving a valid request, Gensys Security Solutions will:

1. acknowledge receipt where appropriate;
2. assess whether the request complies with PAIA;
3. identify the requested records;
4. determine whether the records exist and are held by Gensys Security Solutions;
5. consider whether any grounds for refusal apply;
6. consider the rights and interests of third parties where applicable;
7. consider applicable privacy and confidentiality requirements;
8. determine whether access should be granted, refused or partially granted; and
9. notify the requester of the outcome.

Gensys Security Solutions will process requests within the periods prescribed by PAIA, subject to any lawful extension or other applicable provision.

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12. GROUNDS FOR REFUSAL

Access to a record may be refused where PAIA permits or requires refusal.

Potential grounds may include protection of:

• personal information of another person;
• confidential information;
• commercial information;
• trade secrets;
• financial interests;
• privileged information;
• information supplied in confidence;
• safety or security;
• legally protected interests;
• information relating to legal proceedings; or
• other interests protected by PAIA.

A refusal will be dealt with in accordance with the applicable provisions of PAIA.

Where only part of a record is subject to a valid ground for refusal, Gensys Security Solutions may consider whether the remainder of the record can lawfully be disclosed.

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13. PROTECTION OF PERSONAL INFORMATION

Gensys Security Solutions recognises the importance of protecting personal information.

Gensys Security Solutions processes personal information in accordance with the Protection of Personal Information Act 4 of 2013 ("POPIA") and other applicable legislation.

Personal information may be processed for purposes including:

• processing customer orders;
• delivering products;
• processing payments;
• communicating with customers;
• handling enquiries;
• processing returns and refunds;
• providing customer support;
• preventing fraud;
• maintaining business records;
• complying with legal obligations;
• improving services;
• marketing, where legally permitted; and
• operating and securing the website and information systems.

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14. CATEGORIES OF DATA SUBJECTS

Gensys Security Solutions may process personal information relating to:

• customers;
• prospective customers;
• website users;
• employees;
• prospective employees;
• suppliers;
• contractors;
• service providers;
• business partners;
• representatives of organisations; and
• other persons who interact with Gensys Security Solutions.

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15. CATEGORIES OF PERSONAL INFORMATION

Depending on the relationship with Gensys Security Solutions, personal information may include:

• names and surnames;
• contact information;
• email addresses;
• telephone numbers;
• physical addresses;
• postal addresses;
• delivery addresses;
• account information;
• order information;
• payment-related information;
• transaction information;
• correspondence;
• employment information;
• identification information where legally required;
• website usage information; and
• other information reasonably required to conduct the business.

Gensys Security Solutions will seek to limit the collection and processing of personal information to what is reasonably necessary for legitimate business purposes and applicable legal requirements.

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16. RECIPIENTS OF PERSONAL INFORMATION

Where necessary and lawful, personal information may be shared with:

• payment service providers;
• banks and financial institutions;
• courier and delivery companies;
• IT and hosting service providers;
• website service providers;
• professional advisers;
• accountants;
• auditors;
• legal advisers;
• insurers;
• government or regulatory authorities where legally required; and
• other contracted service providers.

Gensys Security Solutions will take reasonable steps to ensure that appropriate safeguards apply to personal information processed on its behalf.

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17. SECURITY OF PERSONAL INFORMATION

Gensys Security Solutions will implement reasonable technical and organisational measures designed to protect personal information against:

• loss;
• damage;
• unauthorised access;
• unauthorised disclosure;
• misuse;
• alteration; and
• unlawful processing.

Security measures may include access controls, passwords, authentication, restricted access, backups, monitoring and other appropriate safeguards.

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18. CROSS-BORDER TRANSFERS

Where personal information is transferred outside South Africa, Gensys Security Solutions will take reasonable steps to ensure that the transfer is conducted in accordance with applicable POPIA requirements.

This may include transfers to technology providers, hosting providers, payment providers or other service providers located outside South Africa.

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19. RETENTION OF RECORDS

Gensys Security Solutions will retain records and personal information for periods determined by:

• applicable legislation;
• contractual requirements;
• business requirements;
• tax requirements;
• accounting requirements;
• legal requirements;
• dispute-resolution requirements; and
• legitimate business purposes.

Personal information will not be retained for longer than is necessary unless retention is required or authorised by law.

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20. OTHER LEGISLATION

Depending on the nature and activities of Gensys Security Solutions, records may be maintained in accordance with applicable legislation, which may include:

• Companies Act 71 of 2008;
• Electronic Communications and Transactions Act 25 of 2002;
• Consumer Protection Act 68 of 2008;
• Protection of Personal Information Act 4 of 2013;
• Promotion of Access to Information Act 2 of 2000;
• Basic Conditions of Employment Act 75 of 1997;
• Labour Relations Act 66 of 1995;
• Employment Equity Act 55 of 1998;
• Income Tax Act 58 of 1962;
• Value-Added Tax Act 89 of 1991;
• Financial Intelligence Centre Act 38 of 2001, where applicable;
• National Credit Act 34 of 2005, where applicable; and
• other legislation applicable to the business.

The list is not exhaustive and may be amended as legislation changes.

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21. AVAILABILITY OF THIS MANUAL

Subject to applicable requirements, this Manual will be made available through:

1. the Gensys Security Solutions website;
2. the principal place of business of Gensys Security Solutions during normal business hours; and
3. other appropriate means.

The Information Regulator states that PAIA manuals are intended to explain the information available and the procedure for requesting access to records from public and private bodies.

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22. REMEDIES AVAILABLE TO A REQUESTER

If a requester is dissatisfied with a decision concerning access to a record, the requester may exercise any remedies available under PAIA.

Depending on the circumstances, this may include lodging a complaint with the Information Regulator or approaching a court for appropriate relief.

The applicable remedy will depend on the nature of the decision and the provisions of PAIA in force at the relevant time.

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23. UPDATES TO THIS MANUAL

Gensys Security Solutions may update this Manual from time to time.

The Manual will be reviewed when necessary to ensure that it remains consistent with:

• changes to the business;
• changes to applicable legislation;
• changes to PAIA requirements;
• changes to POPIA requirements; and
• changes to the contact details of the Information Officer.

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24. APPROVAL

This Manual has been prepared for Gensys Security Solutions in accordance with the requirements applicable to private bodies under PAIA.

Approved by: A J Askew

Name: A J Askew

Position: Managing Director

Signature:           

Date: 25/08/2026

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ANNEXURE A – PAIA REQUEST PROCESS

A requester should follow these steps:

1. Identify the record required.
2. Determine whether the information is already publicly available.
3. Obtain the applicable prescribed PAIA request form.
4. Complete the form fully.
5. Clearly identify the record or records requested.
6. Explain the right that the requester seeks to exercise or protect.
7. Explain why the record is required for that purpose.
8. Provide the required contact details.
9. Provide proof of authority where requesting on behalf of another person.
10. Submit the request to the Information Officer of Gensys Security Solutions.
11. Pay any applicable prescribed fee.
12. Await the decision of Gensys Security Solutions.
13. If dissatisfied, consider the remedies available under PAIA.

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ANNEXURE B – PAIA INFORMATION OFFICER

Organisation: Gensys Security Solutions

Information Officer: A J Askew

Email: paia@gensys-security.co.za

Telephone: +27 83 236 5391

Physical Address:
20 Childrens Way, Cape Town, South Africa

Postal Address:
As Above

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ANNEXURE C – AUTOMATICALLY AVAILABLE INFORMATION

The following categories of information may be available without a formal PAIA request:

• website content;
• product descriptions;
• product prices;
• publicly available promotional material;
• publicly available contact information;
• terms and conditions;
• privacy policy;
• returns policy;
• delivery information;
• other information deliberately published by Gensys Security Solutions.

This does not mean that all information falling within these broad categories will automatically be disclosed.

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ANNEXURE D – RELATED DOCUMENTS

The following documents should be maintained and made available where appropriate:

• Gensys Security Solutions Privacy Policy;
• Terms and Conditions;
• Returns and Refund Policy;
• Delivery Policy;
• Cookie Policy, where applicable;
• POPIA compliance documentation;
• PAIA request form;
• PAIA outcome notice;
• applicable Information Regulator Guide; and
• other applicable policies.

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DECLARATION

Gensys Security Solutions is committed to transparency, responsible information management and the protection of personal information.

This Manual is intended to assist members of the public, customers, employees, suppliers and other interested parties in understanding how information held by Gensys Security Solutions may be accessed in accordance with applicable South African law.

END OF MANUAL

Version: 1.0
Effective Date: 21 August 2026
Next Review Date: 21 August 2027