PAIA Manual

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

Effective Date: 25 September 2026
Last Updated: 4 October 2026
Version: 1.0

1. Company Details

Legal Name: SUSTA (Pty) Ltd
Registration Number: 2026/707252/07
Company Type: Private Company
Place of Registration: Republic of South Africa

Registered Office and Principal Place of Business:
14A Luttig Street
Middelburg
Mpumalanga
1050
South Africa

Address for Service of Legal Documents:
14A Luttig Street, Middelburg, Mpumalanga, 1050, South Africa

Telephone: 083 388 2616 / 076 124 2023
Email: management@susta.co.za
Website: https://susta.co.za/

2. Purpose of this Manual

This Manual explains how SUSTA (Pty) Ltd makes information available and how a person may request access to records held by SUSTA in terms of the Promotion of Access to Information Act 2 of 2000 (PAIA).

It also provides information about SUSTA’s processing of personal information in terms of the Protection of Personal Information Act 4 of 2013 (POPIA).

This Manual is intended to assist persons who wish to exercise rights of access to information in accordance with applicable law.

3. Information Officer

Information Officer: N.A. du Randt
Appointment Date: 3 September 2026
Information Regulator Registration Number: 2026-067686
Email: management@susta.co.za
Telephone: 076 124 2023

N.A. du Randt is SUSTA’s registered Information Officer and is responsible for assisting with requests for access to information and performing the applicable duties under PAIA and POPIA.

4. How to Request Access to Information

A person requesting access to a record held by SUSTA must make the request using the prescribed PAIA Form 2 and in the manner required by PAIA.

Requests should be submitted to:

Information Officer
SUSTA (Pty) Ltd
14A Luttig Street
Middelburg
Mpumalanga
1050
South Africa

Email: management@susta.co.za
Telephone: 076 124 2023

The request should sufficiently identify the record requested and provide the information reasonably necessary for SUSTA to identify the requester and the record concerned.

Where applicable, SUSTA may require payment of a prescribed fee before processing a request, in accordance with PAIA and the applicable regulations.

Access to a record is subject to the requirements and grounds for refusal contained in PAIA.

The Information Regulator’s PAIA Guide explains the prescribed request process and the rights and remedies available to requesters.

5. Records Automatically Available

The following categories of information are generally available to the public without a formal PAIA request:

  • Information published on the SUSTA website
  • SUSTA’s publicly available product information
  • SUSTA’s published policies and notices
  • Contact information published by SUSTA
  • Publicly available company and business information
  • This PAIA Manual
  • Information that SUSTA is otherwise required by law to make publicly available

The availability of information does not mean that every underlying record is automatically available.

6. Records Available Under Other Legislation

SUSTA may hold records created or maintained in accordance with applicable legislation, including, where applicable:

  • Companies Act 71 of 2008
  • Promotion of Access to Information Act 2 of 2000
  • Protection of Personal Information Act 4 of 2013
  • Consumer Protection Act 68 of 2008
  • Electronic Communications and Transactions Act 25 of 2002
  • Basic Conditions of Employment Act 75 of 1997, where applicable
  • Income Tax Act 58 of 1962
  • Other legislation applicable to SUSTA’s business activities

The existence of a record does not necessarily mean that access to the record will be granted. Access remains subject to applicable legal requirements and grounds for refusal.

7. Categories of Records Held by SUSTA

Depending on SUSTA’s activities and operations, records may be held in the following categories:

7.1 Corporate and Legal Records

  • Registration and incorporation records
  • Memorandum of Incorporation
  • Corporate governance records
  • Statutory records
  • Agreements and contracts
  • Legal correspondence

7.2 Financial Records

  • Accounting records
  • Invoices and receipts
  • Financial statements
  • Tax records
  • Payment records
  • Banking and financial records

7.3 Customer and Order Records

  • Customer contact information
  • Orders and transaction records
  • Delivery information
  • Returns and refund records
  • Customer correspondence
  • Complaints and enquiries

7.4 Product and Commercial Records

  • Product information
  • Product specifications
  • Supplier information
  • Pricing information
  • Manufacturing and quality records
  • Commercial agreements
  • Product safety and compliance records

7.5 Marketing and Communications Records

  • Marketing communications
  • Customer communication preferences
  • Website enquiries
  • Newsletter or mailing-list information, where applicable
  • Social media and other communication records

7.6 Employee and Contractor Records

Where applicable:

  • Employment records
  • Contractor records
  • Payroll records
  • Qualifications and related employment information
  • Other records required for employment administration

7.7 Website and Technical Records

Where applicable:

  • Website enquiries
  • Website account information
  • Website logs
  • Security records
  • Cookie and analytics information
  • Technical records associated with website operation

8. Processing of Personal Information

SUSTA processes personal information for legitimate business purposes and in accordance with POPIA.

8.1 Purposes of Processing

Personal information may be processed for purposes including:

  • Processing and fulfilling customer orders
  • Delivering products
  • Processing payments
  • Responding to enquiries
  • Managing returns, refunds and complaints
  • Providing customer support
  • Maintaining business and financial records
  • Communicating with customers
  • Marketing, where permitted by law
  • Maintaining website security
  • Improving website functionality and services
  • Complying with legal and regulatory obligations

8.2 Categories of Data Subjects

SUSTA may process personal information relating to:

  • Customers and prospective customers
  • Website visitors
  • Suppliers and service providers
  • Business contacts
  • Employees and contractors, where applicable
  • Other persons who communicate with SUSTA

8.3 Categories of Personal Information

Depending on the relationship and purpose, information may include:

  • Names and contact details
  • Delivery and billing information
  • Order and transaction information
  • Correspondence and enquiries
  • Account information
  • Marketing preferences
  • Website and technical information
  • Other information lawfully provided to SUSTA

SUSTA does not seek to collect personal information that is unnecessary for the relevant purpose.

9. Recipients of Personal Information

Where necessary and lawful, SUSTA may provide personal information to categories of recipients such as:

  • Payment service providers
  • Delivery and courier providers
  • Website and hosting service providers
  • IT and technology service providers
  • Professional advisers
  • Accounting and financial service providers
  • Government, regulatory or law-enforcement authorities where legally required
  • Other service providers necessary to operate SUSTA’s business

Where a third party processes personal information on SUSTA’s behalf as an operator, SUSTA will require appropriate contractual confidentiality and security measures in accordance with POPIA.

10. Transborder Processing

Some service providers used by SUSTA may process or store information outside the Republic of South Africa.

Where personal information is transferred outside South Africa, SUSTA will ensure that the transfer complies with the requirements of section 72 of POPIA.

The specific providers and locations may depend on the technology, payment, hosting, communication and other services used by SUSTA from time to time.

11. Information Security

SUSTA takes appropriate, reasonable technical and organisational measures to protect the integrity and confidentiality of personal information and to prevent its loss, damage, unauthorised destruction, unlawful access or unlawful processing.

SUSTA reviews its security safeguards periodically and updates them where reasonably necessary to address identified risks or deficiencies.

These measures may include:

  • Access controls
  • Password protection
  • Secure website connections
  • Appropriate hosting and technical security measures
  • Limiting access to personal information to persons who require it
  • Appropriate data backup and recovery measures
  • Security monitoring and maintenance where appropriate

No electronic system can be guaranteed to be completely secure.

12. Records That May Be Refused

Access to records may be refused where PAIA or another applicable law permits or requires refusal.

Depending on the circumstances and applicable provisions of PAIA, access may be refused in relation to records containing, among other things:

  • Personal information of another person
  • Confidential information
  • Commercially sensitive information
  • Trade secrets
  • Information subject to legal privilege
  • Information whose disclosure could prejudice SUSTA or another person’s legitimate interests
  • Other records falling within a ground for refusal under PAIA

Where only part of a record may lawfully be disclosed, SUSTA may consider whether the remainder can be provided in accordance with applicable law.

13. PAIA Guide and Assistance

The Information Regulator publishes a Guide explaining how to use PAIA and POPIA and how to exercise rights under those laws.

The Guide may be obtained from the Information Regulator and its eServices platform.

SUSTA’s Information Officer may also provide reasonable assistance concerning the process for submitting an access request.

14. Complaints and Remedies

A requester who is dissatisfied with the handling or outcome of a PAIA request may use the remedies available under applicable law.

A requester aggrieved by a decision of a private body may submit a complaint to the Information Regulator in the prescribed manner and form, within the period permitted by PAIA.

A requester may also approach a court where permitted by applicable law.

The Information Regulator provides a PAIA complaints process through its eServices platform.

15. Availability of this Manual

A current copy of this PAIA Manual is available:

Online:
Through the SUSTA website under PAIA Manual.

At SUSTA’s principal place of business:
14A Luttig Street, Middelburg, Mpumalanga, 1050, South Africa, during reasonable business hours.

A hard copy may also be provided upon request, subject to any applicable reasonable copying or reproduction charge.

16. Updating of this Manual

SUSTA will review this Manual periodically and update it when reasonably necessary, including where there are material changes to SUSTA’s business, information practices, contact details or applicable legal requirements.

Revision History

VersionDateDescription
1.04 October 2026Initial publication

17. Approval

Issued by:
N.A. du Randt
Information Officer
SUSTA (Pty) Ltd

Date: 4 October 2026