Legal
PAIA manual
Promotion of Access to Information Act, 2000 (Act 2 of 2000), section 51
Version 2.0. Last revised: 14/10/2026. Owner: Information Officer. Approved by: Managing Director.
1. Introduction and purpose
This manual is published under section 51 of the Promotion of Access to Information Act, 2000 (PAIA). It explains which records XContent holds, how to request access to them, the fees that apply, how we process personal information, and what you can do if you disagree with our decision.
It applies to XContent Digital Solutions (Pty) Ltd, trading as XContent.
2. Company details
| Detail | Information |
|---|---|
| Company name | XContent Digital Solutions (Pty) Ltd |
| Registration number | 2017/164224/07 |
| Sector | Technology and business services |
| Principal place of business | 20 Charles de Gaulle Crescent, Building 1, Equity Estate, Highveld, Centurion, 0157 |
| Postal address | Postnet Suite 218, Private Bag X1007, Lyttelton, 0140 |
| Website | xcontent.ai |
| Director | D de Lange |
3. Information Officer
| Contact detail | Information |
|---|---|
| Information Officer | Andrew Janse Van Vuuren |
| [email protected] | |
| Phone | +27 11 014 1778 |
| Physical address | 20 Charles de Gaulle Crescent, Building 1, Equity Estate, Highveld, Centurion, 0157 |
| Postal address | Postnet Suite 218, Private Bag X1007, Lyttelton, 0140 |
Send all PAIA requests to the Information Officer.
4. The Information Regulator's guide
The Information Regulator has published a guide on how to use PAIA, available in all official languages. It explains your rights and how to exercise them. You can find it at inforegulator.org.za/paia-guidelines, or ask the Regulator for a copy.
The Information Regulator (South Africa), JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001. PO Box 31533, Braamfontein, Johannesburg, 2017. General enquiries: [email protected]. PAIA complaints: [email protected]. POPIA complaints: [email protected]. Website: inforegulator.org.za.
5. Records available without a request
The following are available without a PAIA request: information published on xcontent.ai, including product and service information, this manual and our privacy policy.
6. Records held under other legislation
We keep records as required by legislation that applies to us, including:
- Companies Act, 2008
- Income Tax Act, 1962
- Value-Added Tax Act, 1991
- Tax Administration Act, 2011
- Basic Conditions of Employment Act, 1997
- Labour Relations Act, 1995
- Employment Equity Act, 1998
- Unemployment Insurance Act, 2001
- Skills Development Levies Act, 1999
- Compensation for Occupational Injuries and Diseases Act, 1993
- Broad-Based Black Economic Empowerment Act, 2003
- Electronic Communications and Transactions Act, 2002
- Protection of Personal Information Act, 2013
- Consumer Protection Act, 2008
7. Subjects and categories of records
- Company and statutory records: incorporation documents, share register, minutes and resolutions
- Financial records: accounting records, invoices, tax and VAT records, banking records
- Personnel records: employment contracts, payroll, leave, performance and training records
- Customer records: agreements, correspondence, service and support records
- Supplier and partner records: agreements, purchase orders and correspondence
- Operational records: policies, procedures and internal reports
- Technical records: software, system documentation and specifications
- Marketing and business development records
- Quality, audit and compliance records
- Intellectual property records, such as trademarks
8. Processing of personal information
| Category of data subject | Personal information processed |
|---|---|
| Customers and prospective customers | Names, contact details, organisation and role, correspondence, contract and billing information |
| Employees and job applicants | Identity and contact details, employment, payroll, tax, banking and performance information |
| Suppliers and partners | Company and contact details, banking details, agreements |
| Website visitors | Form submissions, technical and, with consent, analytics data |
Purposes: providing our products and services, managing customer and supplier relationships, employment, responding to enquiries, meeting legal obligations and keeping our systems secure.
Recipients: our operators (including Microsoft, ConnectWise and, for website analytics with consent, Google), professional advisers, auditors, banks and regulators where the law requires.
Transfers outside South Africa: our sales and service system, ConnectWise, is hosted in the European Union, which is subject to the GDPR. Some Microsoft cloud services may process data outside South Africa. Website analytics, used only with the visitor's consent, are processed by Google (Google Analytics) and Microsoft (Microsoft Clarity), mainly in the United States. Transfers meet section 72 of POPIA.
Security measures: access control and multi-factor authentication, encryption, firewalls and monitoring, backups, and confidentiality obligations for staff and operators.
9. How to request access
Submit your request on Form 2, Request for Access to Record, prescribed in the PAIA Regulations, 2021. You can get the form from the Information Officer or the Information Regulator's website. Send it:
- by email to [email protected]
- by hand to 20 Charles de Gaulle Crescent, Building 1, Equity Estate, Highveld, Centurion, 0157
- by post to Postnet Suite 218, Private Bag X1007, Lyttelton, 0140
Your request must give enough detail to identify the record, show which right you want to exercise or protect and why the record is needed, state the form of access you want, and include your contact details. If you act for someone else, include proof of your authority.
10. Time frames
| Stage | Time frame |
|---|---|
| Acknowledgement of your request | Within 7 days of receipt (our service standard) |
| Decision on your request | Within 30 days of receipt |
| Extension | Up to a further 30 days, with written notice and reasons, where PAIA allows |
If we do not decide within the time allowed, the request is regarded as refused.
11. Fees
Fees are prescribed in Annexure B to the PAIA Regulations, 2021. We will tell you what is payable before we process your request.
| Item | Fee |
|---|---|
| Request fee, per request | R140.00 |
| Photocopy or printed copy, per A4 page or part | R2.00 |
| Copy in computer-readable form | As prescribed in Annexure B |
| Transcription of an audio record, per A4 page | R24.00 |
| Search and preparation, per hour or part after the first hour | R145.00, to a maximum of R435.00 |
| Deposit, where search and preparation will exceed six hours | One third of the access fee |
| Postage | Actual cost |
If your request is refused, any deposit you paid will be refunded.
12. Grounds for refusal
We may refuse access only on the grounds in Chapter 4 of Part 3 of PAIA, including where disclosure would:
- unreasonably disclose personal information about a third party
- disclose a third party's trade secrets or confidential commercial information
- breach a duty of confidence owed to a third party
- endanger the life or physical safety of a person, or the security of property
- disclose records privileged from production in legal proceedings
- disclose XContent's trade secrets or commercial information that could harm our commercial or financial interests
- disclose research information that would seriously disadvantage the researcher
If we refuse, we will give you written reasons and tell you how to challenge the decision.
13. If you disagree with our decision
PAIA has no internal appeal for private bodies. If you are unhappy with our decision, our fees or an extension, you may:
- lodge a complaint with the Information Regulator within 180 days of our decision, using the Regulator's PAIA complaint form
- apply to court for appropriate relief
The Information Regulator (South Africa), JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001. PO Box 31533, Braamfontein, Johannesburg, 2017. General enquiries: [email protected]. PAIA complaints: [email protected]. POPIA complaints: [email protected]. Website: inforegulator.org.za.
14. Availability of this manual
This manual is available on xcontent.ai, at our principal place of business for inspection during office hours, and from the Information Officer on request. The Information Officer reviews it at least once a year.