Promotion of access to the information act manual for
PH MARKETING PTY LTD Prepared in accordance with section 51 of The Promotion of
Access to Information Act.

  1. INTRODUCTION AND PURPOSE OF THE MANUAL
    This manual is published in terms of Section 51 of the Promotion of Access to Information
    Act, 2000 (Act 2 of 2000 – “the Act”). The Act gives effect to the provisions of section 32 of the
    Constitution of South Africa, which provides that “everyone hasthe right of accessto any information
    held by another person and that is required for the exercise and/or protection of any rights. Where a
    request is made in terms of the Act, the body to which therequest is made is obliged to release the
    information, except where the Act provides that the information may or must not be released.
    1.1 The reference to any information in addition to thatspecifically required in terms of Section 51 ofthe
    Act does not create any right or entitlement (contractual or otherwise) to receive such requested
    information, other than in terms of the Act.
    1.2 Itis important to note that the Actrecognizes certain limitations to the right of accessto information,
    including, but not limited to, limitations aimed at the reasonable protection of privacy, commercial
    confidentiality, and effective and good governance, and in a manner which balances that right with
    any other Information Officer named below is appointed gets, including such rights contained in the
    Bill of Rights in the Constitution. Any request for access to information may be refused on the grounds
    asset outin Chapter 4 of Part 3 ofthe Act.
  2. SCOPE OF APPLICATIONS
    2.1 Thismanual has been prepared in respect of PH MARKETING PTY LTD
    The Information Officer named below is appointed in respect of PH MARKETING PTY LTD
  3. INFORMATION REQUIRED UNDER SECTION 51(1)( a)
    Name of Private Body : PH MARKETING PTY LTD
    Registration Number: 2013/019232/07
    Information Officer: Kem Barron
    Email address of Information Officer: Kem@phmarketing.co.za
    Deputy Information Officer: Harini Dhawakieram CEO
    Postal Address P.O.Box 1925, Mulbarton, 2059
    Physical Address: 22 Hennie Alberts Street, Brackenhurst, Alberton, 1448
    Phone Number : 011 867 6767
    Fax Number: 011 867 0155
    Website: www.phmarketing.co.za
    A DESCRIPTION OF GUIDE REFERRED TO IN SECTION 10: SECTION 5l(l)(b)
    3.1 A guide has been prepared by the South African Human Rights Commission in accordance with Section
    10 of the Act. The guide contains such information asmay be reasonably required by a person who
    wishes to exercise any right contemplated in the Act.
    3.2 The guide is available from the SAHRC at their address as detailed.
  4. CATEGORIES OF INFORMATION AVAILABLE WITHOUT REQUEST IN TERMS OF
    SECTION 51(1)( c)
    4.1 No notice in terms of Section 52(2)of the Act,regarding the categories of records of CHA Group,
    which are available withoutrequest, has been published.
    4.2 The information as regarding PH MARKETING PTY LTD is accessible at www.phmarketing.co.za without
    request. The website contains various categories of information relating to PH MARKETING PTY LTD
  5. RECORDS AVAILABLE IN TERMS OF OTHER LEGISLATION: SECTION 51(1)(d)
    5.1 PH MARKETING PTY LTD keep records in accordance with the following legislation, all of which are
    available, subjectto such legislation andthe Act:
    • Basic Conditions of EmploymentAct,No 75 of 1997
    • Close Corporation ActNo. 69of 1984
    • Compensation for Occupational Injuries andHealth Diseases Act,No.130 of 1993
    • Income Tax Act, No:95 of 1967
    • Labour Relations Act,No. 66 of 1995
    • Occupational Health& Safety Act,No. 85 of 1993
    • Promotion of Access to Information Act,No.2 of 2000
    • Skills Development Act’. No. 97 of 1998
    • Skills Development Levies Act,No. 9 of1999
    • Unemployment Contributions Act,No. 4 of 2002
    • Unemployment Insurance Act,No.63 of 2001
    • Value Added Tax Act,No.90 of 1991
  6. CATEGORIES OF RECORDS HELD IN TERMS OF SECTION 51(1)(e)
    The Following are the subject and categories of records held:
    6.1 Human Resources
    • Personal records ofthe personnel
    • Employment contracts
    • Medical Aid records
    • Pension fund and retirement benefitrecords
    • Disciplinary records
    • Salary records
    • Training Records
    • Correspondence relating to personnel
    • Leave Records
    • UIF Records
    • Internal policies and procedures
    6.2 Secretarial
    • CK Registration Form
    • Minutes of Members
    • Association Agreements
    • Recordsrelating to the appointment ofMembers and Financial Officer
    • Resolutions Minute Book
    6.3 Financial and Administration
    • VAT Records
    • PAYE Records
    • Fixed Assets Registers
    • Banking Records
    • Management Reports
    • Invoices
    • Debtors and Creditors
    • Information
    6.4 Information Management and Technology
    • Services Level Agreements
    • Equipment Register
    • Policies, Procedures, and Guidelines
    • Licensing Agreements
    6.5 Marketing and Communication
    • Marketing Strategies
    • Communications Strategies
    • Agreements
    6.6 Operations
    • Access ControlRecords
    • Archival Administration
    • Documentation
    • Insurance
    • Arrangements, Policies and Claims
    • Asset Register
    6.7 Safety Records
    • Safety Manuals
    • Occupational Health and Safety Records
    • Records of Incidents in the Workplace
    6.8 Customer/Clients andThird Parties Related Records
    • Contracts with Clients.
    • Any records the Client has provided to PH MARKETING PTY LTD or a third party acting for or on
    behalf of PH MARKETING PTY LTD
    • Records, Reports and the like generated by PH MARKETING PTY LTD fortheir clients.
    • Records generated pertaining to the Client, including transactional Records.
    6.9 Other Records
    Legal proceedings records
  7. DETAILS ON HOW TO MAKE REQUESTS FOR ACCESS TO RECORDS HELD BY THE
    COMPANY: SECTION 5l(l)(e)
    7.1 A requester access to information held by PH MARKETING PTY LTD must complete the prescribed
    form available from SAHRC website (www.sahrc.org.za) orthe Department of Justice and
    ConstitutionalDevelopment (www.doj.gov.za ), and submit it to the Information Office at the
    address, fax number or electronic mail address provided for above, and alsomake the payment of
    the prescribed fees.
    7.2 The prescribed formmustbe completed with enough particularity to enable the Information Office
    to Identify:
    8.2.1 the record(s)requested;
    8.2.2 the identity of the requester;
    8.2.3 indicate which formof access is required if the requestis granted;
    7.3 The requester muststate which rightshe or he is seeking to exercise or protect and provide an
    explanation of why the requested record is required forthe exercise or protection of such right.
    7.4 The requester will be informed in writing whether access has been granted or denied. If, in
    addition, the requester requires the reasons for the decision in any manner, she or he must state
    the manner and the particularsso required.
    7.5 If a requestis made on behalf of another person,then the requester mustsubmit proof of the
    capacity in which the requester is making the request to the reasonable satisfaction of the
    Information Officer.
    7.6 If an individual is unable to complete the prescribed from because of illiteracy or disability, such a
    person maymake the request orally.
    7.7 PH MARKETING PTY LTD will processthe request within 30 (thirty) days unlessthe requester has
    stated special reasons which would satisfy the Information Office that circumstances dictate that
    the above time periods do not comply with.
  8. GROUNDS FOR REFUSAL OF ACCESS TO RECORDS
    The main reason(s) why PH MARKETING PTY LTD refuse a request forinformation relatesto the:
    8.1 mandatory protection of the privacy of a third party who is a natural person, which would involve
    the unreasonable disclosure of personal information of that natural person (section 63);
    8.2 mandatory protection of the commercial information of a third party, if the records contain –
    9.2.1 trade secrets of thatthirdparty;
    9.2.2 financial, commercial, scientific or technical information which disclosure could likely cause harm to the
    financial or commercial interests ofthatthird party;
    9.2.3 information disclosed in confidence by a third party to PH MARKETING PTY LTD, if the disclosure could
    putthatthird party at a disadvantage in negotiations or commercial competition (section 64);
    8.3 mandatory protection of the safety of individuals and the protection of property (section 66);
    8.4 mandatory protection of confidential information of third partiesif it is protected in terms of any
    agreement (section 67);
    8.5 mandatory protection ofrecords which would beregarded as a privilege inlegal proceedings(section 67);
    8.6 the commercial activities of, which may include –
    9.6.1 trade secrets of PH MARKETING PTY LTD
    9.6.2 financial, commercial, scientific or technical information which disclosure of could likely cause harmto the
    financial or commercial interests of CHA Group;
    9.6.3 information which, if disclosed could putPH MARKETING PTY LTD at a disadvantage in negotiationsor
    commercial competition;
    9.6.4 a computer program which is owned by PH MARKETING PTY LTD, and which is protected by copyright
    (section 68);
    8.7 requestsforinformation thatis clearly frivolous or vexatious, orwhich involve an unreasonable diversion
    of resourcesshall be refused.
  9. REMEDIES AVAILABLE WHEN PH MARKETING PTY LTD REFUSES INFORMATION
    9.1 PH MARKETING PTY LTD does nothave aninternal appeal procedure. Assuchthedecisionmadeby the
    Information Officer isfinal, andrequesters willhave to exercise such external remedies attheir disposal if
    the request for information is refused, and the requester is not satisfied with the answer supplied by the
    Information Officer.
    9.2 External Remedies
    A requester that is dissatisfied with an Information Officer’s refusal to disclose information may within 30
    days notification of the decision apply to a relevant Court for relief. Likewise, a third party dissatisfied with
    an Information Officer’s decision to grant a request for information, may within 30 days of notification of
    the decision, apply to a courtforrelief. For purposes oftheAct, theCourtsthat have jurisdictionoverthese
    applications are the ConstitutionalCourt,theHigh Court or another court ofsimilarstatus.
    9.3 Availability of this Manual
    10.3.1 This manual is available for inspection by the general public upon request, during the office hours and free
    of charge at thephysical address of PH MARKETING PTY LTD
    10.3.2 Copies may also be requested from the SAHRC.
    10.3.3 This manual is also published on PH MARKETING PTY LTD website referred to above.