A few details need to be confirmed before this is converted into the final downloadable PDF:

ZenZero’s full registered legal name
Registration and VAT numbers
Current physical and postal addresses
The name and position of the registered Information Officer
Whether a Deputy Information Officer has been designated
The dedicated email address for PAIA and POPIA requests

PROMOTION OF ACCESS TO INFORMATION MANUAL

Prepared in accordance with section 51 of the Promotion of Access to Information Act 2 of 2000

ZenZero Agency

Last updated: 31 July 2026

1. Introduction

This Promotion of Access to Information Manual has been prepared by [FULL REGISTERED COMPANY NAME], trading as ZenZero Agency, in accordance with section 51 of the Promotion of Access to Information Act 2 of 2000, referred to in this Manual as “PAIA”.

The purpose of this Manual is to:

Explain the records held by ZenZero Agency
Explain how a person may request access to those records
Identify records that may be available without a formal PAIA request
Describe the personal information processed by ZenZero Agency
Explain how requests relating to personal information may be submitted
Provide the contact details of ZenZero Agency’s Information Officer
Explain the remedies available where a request is refused or not answered

This Manual should be read together with:

The Promotion of Access to Information Act 2 of 2000
The Protection of Personal Information Act 4 of 2013
The Regulations issued under PAIA
The Regulations issued under POPIA
ZenZero Agency’s Privacy Policy and POPIA Privacy Notice

2. Company details

Registered company name: [INSERT FULL REGISTERED COMPANY NAME]
Trading name: ZenZero Agency
Company registration number: [INSERT REGISTRATION NUMBER]
VAT number: [INSERT VAT NUMBER, IF APPLICABLE]
Type of body: Private body
Nature of business: Creative, marketing, advertising, branding, website development, social media management, content production and related agency services
Physical address: [INSERT CURRENT PHYSICAL ADDRESS]
Postal address: [INSERT POSTAL ADDRESS, IF DIFFERENT]
Telephone number: +27 (0) 11 568 4245
General email address: hello@zenzeroagency.com
Website: www.zenzeroagency.com

3. Information Officer details

For a private body that is a juristic person, the Information Officer is ordinarily the chief executive officer, managing director or equivalent officer, or a person duly authorised to perform that role.

ZenZero Agency’s Information Officer is responsible for handling requests made under PAIA and requests relating to personal information under POPIA.

Information Officer: [INSERT FULL NAME]
Position: [INSERT POSITION]
Email address: [INSERT INFORMATION OFFICER EMAIL]
Telephone number: [INSERT DIRECT TELEPHONE NUMBER]
Physical address: [INSERT CURRENT PHYSICAL ADDRESS]

Deputy Information Officer

Deputy Information Officer: [INSERT FULL NAME, IF APPLICABLE]
Position: [INSERT POSITION]
Email address: [INSERT EMAIL ADDRESS]
Telephone number: [INSERT TELEPHONE NUMBER]

All formal PAIA requests should be marked for the attention of the Information Officer.

4. The PAIA Guide

The Information Regulator has prepared a Guide explaining how to exercise rights under PAIA and POPIA.

The Guide contains information about:

The purpose of PAIA
How to make a request for access to records
The assistance available from an Information Officer
The fees that may be payable
The remedies available when a request is refused
How to lodge a complaint with the Information Regulator
How to apply to a court for appropriate relief

The Guide is available from the Information Regulator in each of South Africa’s official languages.

A copy may be obtained from:

Information Regulator of South Africa

Physical address:
Woodmead North Office Park
54 Maxwell Drive
Woodmead
Johannesburg
2191

Telephone: 010 023 5200
Toll-free number: 0800 017 160
Email: enquiries@inforegulator.org.za
Website: www.inforegulator.org.za

A requester may also ask ZenZero Agency’s Information Officer for assistance in accessing the Guide.

5. Records available without a formal PAIA request

Certain records may be made available without a formal PAIA request, subject to any legal, confidentiality, copyright, privacy or contractual restrictions.

These may include:

Publicly available website content
Company contact information
General descriptions of ZenZero Agency’s services
Published articles and news items
Public portfolio examples
Public job advertisements
Published policies and notices
Marketing brochures
Social media content
Public announcements
Information that ZenZero Agency is legally required to make publicly available

A request for these records may be submitted to hello@zenzeroagency.com.

The fact that a category is listed above does not mean that every record within that category will automatically be provided.

Records containing confidential, privileged, personal, client-owned or commercially sensitive information will not be automatically disclosed.

6. Categories of records held by ZenZero Agency

ZenZero Agency may hold the following categories of records.

6.1 Company and statutory records

These may include:

Company registration documents
Founding and constitutional documents
Shareholder records
Director and officer records
Company resolutions
Statutory registers
Organisational policies
Business licences and registrations
Insurance records
Internal governance records
Information Officer registration records
PAIA and POPIA compliance records

6.2 Financial and accounting records

These may include:

Financial statements
Management accounts
Bank records
Invoices
Quotations
Purchase orders
Credit notes
Payment records
Expense records
Tax records
VAT records
Asset registers
Audit records
Supplier accounts
Debtor and creditor records
Payroll records
Insurance records

6.3 Client and project records

These may include:

Client contact details
Client briefs
Proposals and quotations
Service agreements
Statements of work
Project plans
Meeting notes
Project correspondence
Approval records
Client instructions
Creative briefs
Design files
Website files
Marketing strategies
Social media content
Campaign material
Advertising records
Photographs and videos
Brand assets
Reports and analytics
Client databases supplied for project purposes
Website enquiries processed on behalf of clients
Client complaints and support records
Project completion and handover records

Access to client records may be restricted by confidentiality, privacy, intellectual property and contractual obligations.

6.4 Intellectual property and creative records

These may include:

Logos
Brand identities
Design concepts
Draft designs
Website designs
Source and working files
Advertising concepts
Campaign concepts
Written copy
Photographs
Videos
Animations
Illustrations
Presentations
Publications
Templates
Marketing plans
Research
Creative strategies
Internal methodologies
Portfolio materials
Licensed stock assets
Intellectual property licences and permissions

Some of these records may belong to ZenZero Agency, its clients, licensors or other third parties.

6.5 Marketing and business-development records

These may include:

Enquiry records
Prospective-client information
Mailing lists
Marketing consent records
Newsletter records
Campaign performance reports
Social media records
Website analytics
Advertising platform information
Competition and promotional records
Event attendee information
Business-development correspondence
Customer relationship management records
Market research

6.6 Website and technology records

These may include:

Website content
Website forms and submissions
Hosting information
Domain records
Website analytics
Internet Protocol address information
Cookie records
Security logs
Access logs
System records
Software licence information
Backup records
Technical support records
Cybersecurity records
Incident reports
Email and cloud-service records
User account records
Website maintenance records

Access to certain technology and security records may be restricted where disclosure could compromise security or expose confidential technical information.

6.7 Employee and human-resources records

These may include:

Employee contact details
Employment contracts
Identity information
Payroll information
Tax information
Leave records
Attendance records
Performance records
Disciplinary records
Training records
Qualifications
Employment equity information
Occupational health and safety records
Benefit records
Confidentiality agreements
Restraint agreements
Exit records
Internal correspondence

Employee records will only be disclosed where permitted or required by law.

6.8 Recruitment records

These may include:

Job applications
Curriculum vitae
Identity and contact information
Qualifications
Employment histories
Reference information
Interview notes
Assessment results
Salary expectations
Availability information
Background or verification information
Recruitment correspondence

6.9 Supplier, contractor and service-provider records

These may include:

Supplier contact details
Supplier agreements
Contractor agreements
Confidentiality agreements
Service-level agreements
Quotations
Invoices
Payment records
Performance records
Supplier due-diligence records
Tax and registration information
Correspondence
Access and security records

6.10 Legal and compliance records

These may include:

Contracts
Legal correspondence
Complaints
Claims
Dispute records
Litigation records
Regulatory correspondence
Compliance reviews
Risk assessments
Privacy impact assessments
Data-processing agreements
Security compromise records
Internal investigations
Legal opinions
Records protected by legal professional privilege

6.11 Health and safety records

These may include:

Workplace health and safety policies
Incident reports
Emergency procedures
Injury records
Health and safety training records
Contractor safety records
Records required under occupational health and safety legislation

6.12 Communications records

These may include:

Emails
Letters
Telephone notes
WhatsApp or messaging records
Social media communications
Meeting records
Internal communications
Client communications
Supplier communications
Complaint and support correspondence

7. Records held in terms of other legislation

ZenZero Agency may hold records in accordance with legislation applicable to its business and operations.

Depending on the company’s activities and circumstances, this may include records held under the following legislation:

Basic Conditions of Employment Act 75 of 1997
Broad-Based Black Economic Empowerment Act 53 of 2003
Companies Act 71 of 2008
Compensation for Occupational Injuries and Diseases Act 130 of 1993
Consumer Protection Act 68 of 2008
Copyright Act 98 of 1978
Electronic Communications and Transactions Act 25 of 2002
Employment Equity Act 55 of 1998
Income Tax Act 58 of 1962
Labour Relations Act 66 of 1995
Occupational Health and Safety Act 85 of 1993
Promotion of Access to Information Act 2 of 2000
Protection of Personal Information Act 4 of 2013
Skills Development Act 97 of 1998
Skills Development Levies Act 9 of 1999
Tax Administration Act 28 of 2011
Trade Marks Act 194 of 1993
Unemployment Insurance Act 63 of 2001
Unemployment Insurance Contributions Act 4 of 2002
Value-Added Tax Act 89 of 1991

This list is not exhaustive.

The inclusion of legislation in this Manual does not mean that every provision of that legislation applies to ZenZero Agency or that every record held under that legislation will be made available.

8. How to request access to a record

A person requesting access to a record held by ZenZero Agency must complete the prescribed Form 2: Request for Access to a Record.

The completed form must be submitted to ZenZero Agency’s Information Officer using the contact details in section 3 of this Manual.

The requester must provide sufficient information to allow the Information Officer to:

Identify the requester
Identify the requested record
Locate the requested record
Understand the preferred form of access
Communicate with the requester
Identify the right the requester seeks to exercise or protect
Understand why the record is required to exercise or protect that right

A request should relate to an existing record. PAIA does not ordinarily require ZenZero Agency to create a new record, answer general questions, provide an explanation or conduct research on behalf of a requester.

9. Requests made on behalf of another person

Where a request is made on behalf of another person, the requester must provide satisfactory proof that they are authorised to make the request.

The Information Officer may require:

Written authorisation
A power of attorney
Proof of guardianship
Proof of executorship
A court order
Other documents reasonably required to verify the requester’s authority

10. Assistance to requesters

A person who requires assistance completing a PAIA request may contact the Information Officer.

Where a request does not comply with the prescribed requirements, the Information Officer may notify the requester and provide reasonable assistance to correct the request.

Assistance by the Information Officer does not guarantee that access will be granted.

11. Form of access

Where access is granted, a requester may ask to receive the record through an available method such as:

Inspection
A printed copy
An electronic copy
Email
A transcript
Another reasonably available format

The form of access requested may not be provided where doing so would:

Unreasonably interfere with ZenZero Agency’s operations
Damage or compromise the record
Infringe copyright
Expose confidential or protected information
Be technically impossible or unreasonable

Where possible, an alternative form of access may be offered.

12. Fees

A requester may be required to pay the fees prescribed under PAIA.

These may include:

A request fee
Reproduction or copying fees
Search and preparation fees
Postal or delivery costs
Other prescribed access fees

ZenZero Agency will notify the requester of any fee payable before processing or providing access to the record.

Where the search and preparation of a record is expected to exceed the period prescribed in the PAIA Regulations, ZenZero Agency may require a deposit.

The requester may apply for an exemption from paying a fee where permitted under PAIA or the applicable Regulations.

The fees payable will be those prescribed by law at the time the request is processed.

ZenZero Agency will not impose a fee for a requester seeking access to their own personal information where POPIA or another applicable law provides that access must be provided free of charge.

13. Timeframes

ZenZero Agency will ordinarily decide whether to grant or refuse a PAIA request within 30 days after receiving a properly completed request, unless:

The period is extended as permitted under PAIA
Additional information is required from the requester
A required fee has not been paid
Third-party notification procedures must be followed
Another lawful reason for delay applies

Where the response period is extended, the requester will be notified.

14. Decision on a request

The requester will be informed in writing whether the request has been:

Granted
Partially granted
Refused
Deferred pending payment or further information

Where access is granted, ZenZero Agency will advise the requester of:

The applicable access fee
The form in which access will be provided
Any conditions relating to access
The expected availability of the record

Where access is refused, ZenZero Agency will provide reasons for the refusal, subject to any limitation permitted by law.

15. Grounds for refusing access

ZenZero Agency may refuse access to a record where PAIA requires or permits refusal.

This may include circumstances involving:

The privacy of another person
Confidential commercial information belonging to ZenZero Agency or a third party
Confidential information supplied by a third party
Safety risks to an individual
Security risks to property, systems or methods
Records protected by legal professional privilege
Research information
Trade secrets
Financial, commercial, scientific or technical information
Copyright restrictions
Information that could prejudice ZenZero Agency in commercial negotiations or competition
Records that cannot be found or do not exist
Requests that are manifestly frivolous or involve an unreasonable diversion of resources

Access may also be refused where disclosure would breach a confidentiality obligation, violate another person’s rights or be prohibited by law.

Where only part of a record is protected, ZenZero Agency will consider whether the remainder may reasonably be disclosed.

16. Third-party information

Where a requested record contains information relating to a third party, ZenZero Agency may be required to notify that third party and allow them an opportunity to make representations.

This may result in a delay while the third-party procedure required by PAIA is followed.

The final decision remains with ZenZero Agency’s Information Officer, subject to PAIA.

17. Records that cannot be found

Where ZenZero Agency has taken reasonable steps to locate a requested record and the record:

Cannot be found
Does not exist
Has lawfully been destroyed
Is not held by ZenZero Agency

the Information Officer may provide the requester with an affidavit or affirmation explaining the steps taken to locate the record.

18. Personal information processed under POPIA

ZenZero Agency processes personal information for legitimate business, contractual, administrative, legal, marketing, employment and service-delivery purposes.

18.1 Categories of data subjects

ZenZero Agency may process personal information relating to:

Clients
Prospective clients
Former clients
Client customers and audiences
Website visitors
Enquirers
Newsletter subscribers
Social media users
Employees
Former employees
Job applicants
Directors and shareholders
Suppliers
Contractors
Freelancers
Consultants
Business partners
Event attendees
Competition entrants
Professional advisers
Regulators
Members of the public
Other persons who communicate or interact with ZenZero Agency

18.2 Categories of personal information

ZenZero Agency may process:

Names and surnames
Identity information
Company names
Registration information
Job titles
Contact details
Physical and postal addresses
Email addresses
Telephone numbers
Billing and payment information
Tax information
Employment information
Qualifications and curriculum vitae
Salary and payroll information
Performance and disciplinary information
Correspondence
Client briefs
Project information
Photographs
Videos
Audio recordings
Social media information
Website-submission information
Internet Protocol addresses
Device and browser information
Website analytics
Cookie information
Marketing preferences
Consent records
Security and access information
Any other information reasonably required for ZenZero Agency’s lawful operations

18.3 Purposes of processing

Personal information may be processed to:

Respond to enquiries
Prepare quotations and proposals
Enter into and fulfil contracts
Provide agency services
Manage projects
Communicate with clients and suppliers
Process payments and maintain financial records
Manage websites, campaigns and social media accounts
Provide customer service
Conduct marketing
Manage recruitment
Administer employment relationships
Comply with legal obligations
Maintain security
Prevent fraud and misuse
Manage disputes and legal claims
Improve ZenZero Agency’s services and website
Conduct reporting and analysis
Protect ZenZero Agency’s legitimate interests

18.4 Recipients of personal information

Personal information may be shared with:

ZenZero Agency employees and authorised team members
Contractors and freelancers
Clients
Website hosts
Cloud storage providers
Email providers
Software and technology providers
Customer relationship management platforms
Project management platforms
Analytics providers
Advertising platforms
Social media platforms
Payment processors
Banks
Accountants and auditors
Legal advisers
Insurers
Recruitment providers
Printing and production suppliers
Courier and delivery providers
Government departments
Regulators
Law enforcement authorities
Other parties where disclosure is lawful and necessary

18.5 Cross-border transfers

ZenZero Agency may use service providers, platforms, contractors or storage facilities located outside South Africa.

Personal information may therefore be transferred to or stored in another country.

Where this occurs, ZenZero Agency will take reasonable steps to ensure that the transfer complies with POPIA. This may include:

Confirming that the recipient is subject to an appropriate law
Implementing contractual safeguards
Obtaining consent where necessary
Relying on another lawful basis permitted under POPIA

18.6 General description of security safeguards

ZenZero Agency uses reasonable technical and organisational measures to protect personal information against loss, misuse, unauthorised access, destruction, alteration or disclosure.

Safeguards may include:

Password protection
Access restrictions
User authentication
Secure hosting
Cloud-security controls
Antivirus and security software
Backups
Software updates
Confidentiality agreements
Staff training
Data-processing agreements
Security incident procedures
Controlled disposal of records
Physical security measures

No electronic system can be guaranteed to be completely secure. ZenZero Agency regularly reviews its safeguards and updates them where reasonably appropriate.

19. POPIA requests

A data subject may, subject to POPIA:

Request confirmation that ZenZero Agency holds personal information about them
Request access to their personal information
Request correction of inaccurate or outdated personal information
Request deletion or destruction of personal information that ZenZero Agency is no longer authorised to retain
Object to the processing of personal information
Withdraw consent where processing is based on consent
Object to direct marketing

The prescribed POPIA forms should be submitted to ZenZero Agency’s Information Officer.

ZenZero Agency may require reasonable proof of identity before processing a request.

20. Remedies available to a requester

A requester who is dissatisfied with ZenZero Agency’s decision or failure to respond may:

Lodge a complaint with the Information Regulator
Apply to a competent court for appropriate relief

A private body does not ordinarily have an internal appeal procedure under PAIA.

A requester does not need to complete an internal appeal before approaching the Information Regulator or a court in relation to a request made to ZenZero Agency.

21. Complaints to the Information Regulator

A complaint may be submitted to the Information Regulator using the prescribed Form 5: Complaint Regarding Interference with the Protection of Personal Information or Complaint Regarding Determination of an Adjudicator or the applicable current complaint form prescribed by the Regulator.

Current forms and complaint procedures are available from the Information Regulator.

Information Regulator of South Africa

Physical address:
Woodmead North Office Park
54 Maxwell Drive
Woodmead
Johannesburg
2191

Telephone: 010 023 5200
Toll-free number: 0800 017 160
General email: enquiries@inforegulator.org.za
PAIA complaints email: PAIAComplaints@inforegulator.org.za
Website: www.inforegulator.org.za

22. Application to court

A requester or affected third party may apply to a competent court for appropriate relief in accordance with PAIA.

Court proceedings must be instituted within the period prescribed under PAIA.

A requester should obtain independent legal advice where necessary.

23. Availability of this Manual

This Manual is available:

On ZenZero Agency’s website
At ZenZero Agency’s principal place of business for inspection during normal business hours
On request from ZenZero Agency’s Information Officer
Through any other method required by the Information Regulator

A copy of the Manual will be provided in an accessible electronic format where reasonably possible.

ZenZero Agency may charge the prescribed reproduction fee where a printed copy is requested.

24. Updating this Manual

ZenZero Agency will review and update this Manual where reasonably necessary, including when:

Company details change
The Information Officer changes
New categories of records are created
Personal-information processing activities change
Applicable legislation or regulations change
The Information Regulator issues updated guidance

The latest version will be published with an updated revision date.

25. Approval

This Manual was approved by the Information Officer of ZenZero Agency.

Information Officer: [INSERT FULL NAME]

Signature: ______________________________

Date: ______________________________

Place: ______________________________

ANNEXURE A: PAIA REQUEST PROCESS

A requester should follow these steps:

Identify the specific record required.
Identify the right that the requester seeks to exercise or protect.
Explain why access to the record is reasonably required to exercise or protect that right.
Complete the prescribed PAIA Form 2.
Attach proof of identity and, where applicable, proof of authority to act for another person.
Submit the completed form to ZenZero Agency’s Information Officer.
Pay any prescribed request fee after receiving notice from the Information Officer.
Provide any further information reasonably requested to identify or locate the record.
Await the written decision.
Pay any applicable access fee before the record is provided.

ANNEXURE B: PRESCRIBED FORMS

The following official PAIA forms may be relevant:

Form 1: Request for a copy of the PAIA Guide
Form 2: Request for access to a record
Form 3: Outcome of request and fees payable
Form 5: Complaint to the Information Regulator

The current prescribed forms should be downloaded from the Information Regulator’s official website and attached to, or linked alongside, this Manual.

The forms should not be recreated or altered unless permitted by the applicable regulations.

ANNEXURE C: FEE SCHEDULE

Fees payable for access to records will be calculated according to the fee schedule prescribed under PAIA and its Regulations.

The applicable fees may include:

A request fee
Photocopying fees
Printing fees
Electronic-copy fees
Transcription fees
Search and preparation fees
Postage or delivery costs

The Information Officer will provide the requester with written notice of the applicable fees using the prescribed form.

Where the statutory fee schedule changes, the updated prescribed fees will apply automatically without requiring a formal amendment to this Manual.