PAIA Manual
Prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA)
Last updated: August 2026
1. Introduction
This manual has been prepared by Figured Out (Pty) Ltd in accordance with section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA), as amended.
PAIA gives effect to the constitutional right of access to information and provides a process through which a person may request access to certain records held by a private body where the information is required for the exercise or protection of a right.
This manual explains:
• who Figured Out (Pty) Ltd is
• how to contact our Information Officer
• the categories of records we hold
• how a request for access to a record may be made
• the types of records that may be available without a formal PAIA request
• legislation under which we may hold records
• how we process personal information
• how to obtain further guidance regarding PAIA
2. About Figured Out
Business name: Figured Out (Pty) Ltd
Nature of business: Bookkeeping, accounting & advisory services, together with financial education, workshops, programmes and related capability-building services
Physical address: 1 Oosterland Avenue, Bloubosrand, Randburg, 2188, Gauteng, South Africa
Email:Shelly@figuredout.co.za
3. Information Officer
The Information Officer of Figured Out (Pty) Ltd is:
Name: Rouchelle (Shelly) Berger
Email: Shelly@figuredout.co.za
Physical address: 1 Oosterland Avenue, Bloubosrand, Randburg, 2188, Gauteng, South Africa
Requests for access to records under PAIA should be directed to the Information Officer.
4. The PAIA Guide
The Information Regulator has prepared a guide to assist members of the public in understanding and exercising their rights under PAIA.
The guide contains information about:
• the purpose of PAIA
• how to make a request for access to information
• assistance available from Information Officers
• fees that may apply
• remedies available where access is refused
• how to lodge a complaint with the Information Regulator
The guide is available from the Information Regulator of South Africa.
Further information and prescribed PAIA forms can be obtained from the Information Regulator.
5. Records that may be available without a formal PAIA request
Certain information may already be publicly available or may be provided without requiring a formal PAIA request.
This may include:
• information published on the Figured Out website
• service information
• programme and workshop information
• publicly available articles and educational content
• Privacy Policy
• Cookie Policy
• Website Terms & Conditions
• this PAIA Manual
• marketing and promotional material
• information that Figured Out is otherwise legally required to make publicly available
The availability of a record without a formal PAIA request will depend on the nature of the record and whether any legal restrictions apply.
6. Categories of records held by Figured Out
Figured Out may hold records in the following broad categories.
6.1 Company and statutory records
These may include:
• company registration records
• statutory company records
• shareholder and director records
• corporate governance records
• resolutions
• licences or registrations
• regulatory correspondence
• statutory filings
6.2 Financial and accounting records
These may include:
• accounting records
• financial statements
• management accounts
• budgets and forecasts
• invoices
• receipts
• payment records
• banking records
• tax records
• VAT records
• asset records
• supplier records
• expense records
• internal financial reports
6.3 Client records
These may include:
• client contact information
• engagement letters
• proposals and quotations
• service agreements
• client onboarding information
• bookkeeping and accounting records
• financial information
• tax-related information
• correspondence
• management reports
• advisory reports
• meeting notes
• working papers
• information provided by clients for the performance of professional services
• records relating to programmes, workshops and educational services
Client records may contain confidential or personal information and will not automatically be made available simply because a PAIA request has been submitted.
Any request for access will be assessed in accordance with PAIA and other applicable laws.
6.4 Supplier and service-provider records
These may include:
• supplier information
• contracts and agreements
• invoices
• payment records
• correspondence
• service-provider information
• software and technology agreements
6.5 Personnel and contractor records
Where applicable, these may include:
• employment or contractor agreements
• identification and contact information
• payroll information
• leave records
• performance records
• training records
• tax and statutory employment records
• disciplinary records
• confidentiality agreements
Access to these records may be restricted to protect personal information and the rights of third parties.
6.6 Marketing and website records
These may include:
• website content
• marketing material
• campaign information
• mailing lists
• enquiry records
• website analytics
• social media content
• event and workshop registrations
• consent records
• cookie and website preference information
6.7 Intellectual property and educational material
These may include:
• training material
• programme content
• workshop material
• worksheets
• guides
• templates
• frameworks
• presentations
• internal methodologies
• branding and design assets
• copyright material
Access to these records may be refused or restricted where disclosure would infringe intellectual property rights, confidential information or other rights protected under PAIA or applicable law.
6.8 Legal and compliance records
These may include:
• contracts
• engagement agreements
• legal correspondence
• regulatory correspondence
• compliance records
• privacy and information-protection records
• PAIA records
• risk-management records
• policies and procedures
7. Legislation under which records may be held
Figured Out may hold records in accordance with or as required by applicable South African legislation, depending on the nature of its activities.
This may include, among others:
• Companies Act 71 of 2008
• Income Tax Act 58 of 1962
• Tax Administration Act 28 of 2011
• Value-Added Tax Act 89 of 1991
• Basic Conditions of Employment Act 75 of 1997
• Labour Relations Act 66 of 1995
• Employment Equity Act 55 of 1998, where applicable
• Unemployment Insurance Act 63 of 2001, where applicable
• Compensation for Occupational Injuries and Diseases Act 130 of 1993, where applicable
• Protection of Personal Information Act 4 of 2013
• Promotion of Access to Information Act 2 of 2000
• Electronic Communications and Transactions Act 25 of 2002
• Consumer Protection Act 68 of 2008, where applicable
• any other legislation applicable to the nature of Figured Out’s business, services or records
This list is not necessarily exhaustive.
8. How to request access to a record
A person requesting access to a record under PAIA must use the prescribed Form 2: Request for Access to Record.
The requester must provide sufficient information to enable Figured Out to:
• identify the requester
• identify the record being requested
• locate the requested record
• understand the right the requester wishes to exercise or protect
• understand why the requested record is required for the exercise or protection of that right
• determine the preferred form of access
• communicate with the requester
Proof of identity must accompany the request.
Where a request is made on behalf of another person, appropriate proof of authority to act on that person’s behalf must also be provided.
Completed requests should be submitted to:
Information Officer: Rouchelle (Shelly) Berger
Email: Shelly@figuredout.co.za
Physical address: 1 Oosterland Avenue, Bloubosrand, Randburg, 2188, Gauteng, South Africa
The prescribed PAIA forms are available from the Information Regulator.
9. Fees
Fees may be payable in accordance with PAIA and the applicable regulations.
Where a fee is payable, Figured Out will notify the requester of the amount and any applicable requirements before processing or providing access to the record.
The fees may include:
• a prescribed request fee, where applicable
• the cost of searching for and preparing the record
• reproduction or copying costs
• costs associated with the form in which access is provided
Any exemptions provided for under PAIA will apply where relevant.
10. Decision on a request
Figured Out will consider each PAIA request in accordance with the Act.
Submitting a request does not automatically mean that access will be granted.
Access may be granted in full, granted in part or refused where PAIA permits or requires refusal.
Where access is granted, the requester will be informed of:
• the decision
• any applicable fees
• the form in which access will be provided
• any other relevant conditions
Where a request is refused, the requester will be informed of the decision and the applicable remedies available under PAIA.
11. Grounds on which access may be refused
PAIA provides circumstances in which access to a record may or must be refused.
Depending on the circumstances, these may include protection of:
• the privacy of another person
• confidential information belonging to a third party
• commercial information belonging to another party
• confidential information belonging to Figured Out
• intellectual property
• legally privileged information
• the safety or security of individuals
• information where disclosure is prohibited by law
Each request will be considered on its own facts and in accordance with PAIA.
Where only part of a record is protected from disclosure, Figured Out will consider whether the remaining portion of the record can lawfully be provided.
12. Records that cannot be found or do not exist
If reasonable steps have been taken to locate a requested record and the record cannot be found, or if the record does not exist, the requester will be informed in accordance with PAIA.
13. Protection of personal information
Figured Out processes personal information in accordance with the Protection of Personal Information Act 4 of 2013 (POPIA).
More information about our handling of personal information is available in our Privacy Policy.
13.1 Purpose of processing personal information
Figured Out may process personal information for purposes including:
• providing bookkeeping, accounting, tax and advisory services
• client onboarding and relationship management
• programme and workshop administration
• communicating with clients, prospects and participants
• maintaining accounting and tax records
• invoicing and payment administration
• meeting legal, regulatory and professional obligations
• managing suppliers and service providers
• employment and contractor administration
• marketing, where lawful
• website administration and analytics
• business administration
• fraud prevention and security
• protecting legitimate business interests
13.2 Categories of data subjects
Figured Out may process personal information relating to:
• clients
• prospective clients
• client employees, directors, shareholders or representatives
• workshop and programme participants
• website visitors
• subscribers and contacts
• employees
• contractors
• suppliers
• service providers
• professional advisers
• other individuals who interact with Figured Out
13.3 Categories of personal information
Depending on the relationship involved, personal information may include:
• names and surnames
• identity or registration numbers
• contact information
• employment information
• business information
• financial information
• bank details
• tax information
• correspondence
• transaction information
• online identifiers
• website usage information
• information required to provide professional services
13.4 Recipients of personal information
Where lawful and necessary, personal information may be shared with:
• Figured Out employees or contractors
• accounting, tax and bookkeeping software providers
• technology and cloud service providers
• payment providers
• professional advisers
• regulators
• government authorities
• SARS or other statutory bodies, where applicable
• third parties authorised by the client or data subject
• other service providers necessary for the operation of the business
Figured Out does not sell personal information.
13.5 Cross-border processing
Some service providers used by Figured Out may process or store information outside South Africa.
Where personal information is transferred internationally, Figured Out will take reasonable steps to ensure that the transfer complies with applicable data-protection requirements.
13.6 Information security measures
Figured Out takes reasonable and appropriate technical and organisational measures to protect personal information.
These may include:
• controlled access to business systems
• password protection
• multi-factor authentication where available
• secure cloud-based systems
• access restrictions
• device security
• appropriate data backup arrangements
• confidentiality requirements
• controlled sharing of information
• secure disposal or deletion of information when appropriate
• review of security measures as business systems and risks change
The specific measures used may vary according to the nature and sensitivity of the information being processed.
14. Availability of this manual
This PAIA Manual is available:
• on the Figured Out website
• electronically upon request from the Information Officer
• for inspection at the business address, subject to reasonable prior arrangement
There is no fee for inspecting the manual.
15. Complaints and further assistance
A requester who is dissatisfied with the handling of a PAIA request may have the right to lodge a complaint with the Information Regulator of South Africa or pursue another remedy available under PAIA.
Further information, including PAIA forms and guidance, is available from the Information Regulator.
16. Updates to this manual
Figured Out may update this manual where necessary to reflect changes in:
• the business
• the records held
• applicable legislation
• information-processing activities
• service providers
• PAIA or POPIA requirements
The latest version will be published on the Figured Out website.