PAIA & POPIA Manual
Version 1.0 | Adopted 21 August 2026 | Next review: August 2027
Manual in terms of Section 51 of the Promotion of Access to Information Act, 2 of 2000 (PAIA), incorporating the processing descriptions required by the Protection of Personal Information Act, 4 of 2013 (POPIA), for Elite Vision Holdings (Pty) Ltd, trading as Elite Scholars. For details on how we handle personal information day to day, see our Privacy Policy.
1. Introduction
This manual is published in terms of section 51 of the Promotion of Access to Information Act, 2 of 2000 ("PAIA"), as amended by the Protection of Personal Information Act, 4 of 2013 ("POPIA"). It explains how to request access to records held by Elite Vision Holdings (Pty) Ltd, trading as Elite Scholars ("the Company"), and describes how the Company processes personal information.
2. Company and Information Officer Contact Details
Registered name: Elite Vision Holdings (Pty) Ltd. Registration number: 2025/272981/07. Trading as: Elite Scholars. Registered address: 85 5th Street, Halfway Gardens, Midrand, Gauteng, 1686. Website: elitescholars.co.za. Email: info@elitescholars.co.za. Information Officer: Governor Baloyi (Director), governor@elitescholars.co.za. The Information Officer is registered with the Information Regulator (South Africa).
3. The Regulator's Guide (Section 10 of PAIA)
The Information Regulator has published a Guide on how to use PAIA, in all official languages, explaining how to complete request forms, fees, and remedies. The Guide is available from the Information Regulator: https://inforegulator.org.za | inforeg@inforegulator.org.za | JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001.
4. Records Available in Terms of Other Legislation
The Company holds records in terms of, among others: the Companies Act 71 of 2008 (statutory company records), the Income Tax Act 58 of 1962 and Value-Added Tax Act 89 of 1991 (tax records), the Basic Conditions of Employment Act 75 of 1997 and related labour legislation (staff and contractor records), the Consumer Protection Act 68 of 2008 (client agreements), POPIA (personal-information processing records), and the Broad-Based Black Economic Empowerment Act 53 of 2003 (B-BBEE affidavit).
5. Categories of Records Held
Company and statutory records (incorporation documents, share register, resolutions, statutory registers); financial records (annual financial statements, management accounts, invoices, quotations, payment and settlement records, bank records, SARS filings); client and learner records (enquiries, enrolments, parent/guardian and learner account information, consent records, session and progress records, communications); workforce records (tutor, advisor and referrer applications, verification documents, contracts and agreements, payout and commission records); operational and technology records (platform data, first-party analytics records, notification and correspondence records, supplier and operator agreements); and marketing records (website content, campaign and referral-programme records).
6. Records Automatically Available (No PAIA Request Needed)
Website content at elitescholars.co.za, including service and programme descriptions, published pricing, the privacy notice, and this manual.
7. How to Request Access to a Record
Complete the prescribed request form (Form 2, PAIA Regulations 2021), available from the Information Regulator’s website or from the Information Officer. Submit it to the Information Officer at governor@elitescholars.co.za or the registered address, together with the prescribed request fee (currently R140 for private bodies; the Information Officer will confirm the current prescribed amount and any access/reproduction fees per the PAIA Fees Regulations). Provide sufficient particulars to identify the record and the right you seek to exercise or protect (where the request relates to third-party rights), and proof of identity. The Company will respond within 30 days as required by PAIA, subject to the Act’s provisions for extension, third-party notification and grounds of refusal. If a request is refused, the requester may lodge a complaint with the Information Regulator or apply to court as provided in PAIA.
8. Processing of Personal Information (POPIA Description)
Purposes of processing: providing tutoring, advisory and application-support services; client onboarding and account management; billing and payment processing; workforce recruitment, verification and payment; referral-programme administration; communication with parents, guardians and learners; safeguarding; legal and regulatory compliance; and service improvement via first-party analytics. Data subjects include learners (including children under 18, processed with parent/guardian consent obtained at registration), parents/guardians and adult clients, tutors, advisors and referrers, and website visitors (self-hosted first-party analytics only, no third-party advertising trackers). Recipients: personal information may be processed by the Company’s operators - payment gateways (Ozow, PayFast, Paystack), cloud hosting and storage (Amazon Web Services), authentication (Google Firebase) and email delivery - under data-processing terms as required by POPIA sections 20-21. Personal information is not sold or shared for third-party marketing. Cross-border transfers: platform infrastructure is hosted in an AWS region outside South Africa (us-east-1, United States); transfers rely on contractual safeguards in the AWS Data Processing Addendum providing an adequate level of protection as contemplated in section 72(1)(a) of POPIA. Security measures: role-based access control; least-privilege administrative access; audit logging; encryption in transit; per-environment authentication; multi-factor authentication on administrative systems; no storage of cardholder data (payments processed by PCI DSS-compliant gateways). Data subject rights: data subjects (or, for children, their parents/guardians) may request access to, correction of, or deletion of their personal information, and may object to processing or withdraw consent, by contacting the Information Officer. Retention: personal information is retained only as long as required for the purposes above or as required by law, after which it is deleted or de-identified.
9. Availability of this Manual
This manual is available on this page (with a PDF copy for download), at the registered office, and will be provided on request to the Information Officer. It is reviewed annually. Adopted by Governor Baloyi (Director and Information Officer) on 21 August 2026.
PAIA and POPIA enquiries: Governor Baloyi (Information Officer), governor@elitescholars.co.za.