Crossbow Marketing Consultants Proprietary Limited

(Registration no. 1993/00742/07)

PAIA MANUAL

Prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 (as amended)

DATE OF COMPILATION: 27/06/2021
DATE OF REVISION: 01/10/2025

TABLE OF CONTENTS

1 LIST OF ACRONYMS AND ABBREVIATIONS
2 PURPOSE OF PAIA MANUAL
3 KEY CONTACT DETAILS FOR ACCESS TO INFORMATION
4 GUIDE ON HOW TO USE PAIA AND HOW TO OBTAIN ACCESS TO THE GUIDE
5 CATEGORIES OF RECORDS AVAILABLE WITHOUT A PERSON HAVING TO REQUEST ACCESS
6 DESCRIPTION OF RECORDS AVAILABLE IN ACCORDANCE WITH OTHER LEGISLATION
7 DESCRIPTION OF SUBJECTS ON WHICH THE BODY HOLDS RECORDS AND CATEGORIES OF RECORDS HELD ON EACH SUBJECT
8 PROCESSING OF PERSONAL INFORMATION
9 AVAILABILITY OF THE MANUAL
10 UPDATING OF THE MANUAL
1. LIST OF ACRONYMS AND ABBREVIATIONS
1.1 “CEO” Chief Executive Officer
1.2 “DIO” Deputy Information Officer
1.3 “IO” Information Officer
1.4 “Minister” Minister of Justice and Correctional Services
1.5 “PAIA” Promotion of Access to Information Act No. 2 of 2000 (as Amended)
1.6 “POPIA” Protection of Personal Information Act No. 4 of 2013
1.7 “Regulator” Information Regulator
1.8 “Republic” Republic of South Africa
2. PURPOSE OF PAIA MANUAL

This PAIA Manual is useful for the public to –

2.1 check the categories of records held by a body which are available without a person having to submit a formal PAIA request;
2.2 have a sufficient understanding of how to make a request for access to a record of the body, by providing a description of the subjects on which the body holds records and the categories of records held on each subject;
2.3 know the description of the records of the body which are available in accordance with any other legislation;
2.4 access all the relevant contact details of the Information Officer and Deputy Information Officer who will assist the public with the records they intend to access;
2.5 know the description of the guide on how to use PAIA, as updated by the Regulator and how to obtain access to it;
2.6 know if the body will process personal information, the purpose of processing of personal information and the description of the categories of data subjects and of the information or categories of information relating thereto;
2.7 know the description of the categories of data subjects and of the information or categories of information relating thereto;
2.8 know the recipients or categories of recipients to whom the personal information may be supplied;
2.9 know if the body has planned to transfer or process personal information outside the Republic of South Africa and the recipients or categories of recipients to whom the personal information may be supplied; and
2.10 know whether the body has appropriate security measures to ensure the confidentiality, integrity and availability of the personal information which is to be processed.
3. KEY CONTACT DETAILS FOR ACCESS TO INFORMATION OF CROSSBOW MARKETING CONSULTANTS
3.1. Chief Information Officer

Name: Elton-Brett Harding (Managing Director)
Tel: 021 271 0150
Email: @crossbowmarketing.co.za
Fax Number: N/A
3.2. Deputy Information Officer

Name: N/A
Tel: N/A
Email: N/A
Fax Number: N/A
3.3. Access to Information General Contacts

Email: @crossbowmarketing.co.za
3.4. National or Head Office

Postal Address: P O Box 324, Steenberg, 7947

Physical Address:
2nd Floor, PAMA House
299 Main Road, Retreat Industrial, 7945

Telephone: 021 271 0150
Email: @crossbowmarketing.co.za
Website: www.kindhearted.co.za
4. GUIDE ON HOW TO USE PAIA AND HOW TO OBTAIN ACCESS TO THE GUIDE
4.1. The Regulator has, in terms of section 10(1) of PAIA, as amended, updated and made available the revised Guide on how to use PAIA (“Guide”), in an easily comprehensible form and manner, as may reasonably be required by a person who wishes to exercise any right contemplated in PAIA and POPIA.
4.2. The Guide is available in each of the official languages and in braille.
4.3. The aforesaid Guide contains the description of–
4.3.1. the objects of PAIA and POPIA;
4.3.2. the postal and street address, phone and fax number and, if available, electronic mail address of–
4.3.2.1. the Information Officer of every public body; and
4.3.2.2. every Deputy Information Officer of every public and private body designated in terms of section 17(1) of PAIA¹ and section 56 of POPIA²;
4.3.3. the manner and form of a request for–
4.3.3.1. access to a record of a public body contemplated in section 11³; and
4.3.3.2. access to a record of a private body contemplated in section 50⁴;
4.3.4. the assistance available from the IO of a public body in terms of PAIA and POPIA;
4.3.5. the assistance available from the Regulator in terms of PAIA and POPIA;
4.3.6. 4.3.6. all remedies in law available regarding an act or failure to act in respect of a right or duty conferred or imposed by PAIA and POPIA, including the manner of lodging
4.3.6.1. an internal appeal;
4.3.6.2. a complaint to the Regulator; and
4.3.6.3. an application with a court … or a decision of the head of a private body;
4.3.7. the provisions of sections 14⁵ and 51⁶ requiring … how to obtain access to a manual;
4.3.8. the provisions of sections 15⁷ and 52⁸ providing for the voluntary disclosure …
4.3.9. the notices issued in terms of sections 22⁹ and 54¹⁰ regarding fees …; and
4.3.10. the regulations made in terms of section 92¹¹.
4.4. Members of the public can inspect or make copies of the Guide from the offices of the public and private bodies, including the office of the Regulator, during normal working hours.
4.5. The Guide can also be obtained–
4.5.1. upon request to the Information Officer;
4.5.2. from the website of the Regulator (https://www.justice.gov.za/inforeg/).

¹ Section 17(1) of PAIA- For the purposes of PAIA, each public body must, subject to legislation governing the employment of personnel of the public body concerned, designate such number of persons as deputy information officers as are necessary to render the public body as accessible as reasonably possible for requesters of its records.
² Section 56(a) of POPIA- Each public and private body must make provision, in the manner prescribed in section 17 of the Promotion of Access to Information Act, with the necessary changes, for the designation of such a number of persons, if any, as deputy information officers as is necessary to perform the duties and responsibilities as set out in section 55(1) of POPIA.
³ Section 11(1) of PAIA- A requester must be given access to a record of a public body if that requester complies with all the procedural requirements in PAIA relating to a request for access to that record; and access to that record is not refused in terms of any ground for refusal contemplated in Chapter 4 of this Part.

⁴ Section 50(1) of PAIA- A requester must be given access to any record of a private body if-
a) that record is required for the exercise or protection of any rights;
b) that person complies with the procedural requirements in PAIA relating to a request for access to that record; and
c) access to that record is not refused in terms of any ground for refusal contemplated in Chapter 4 of this Part.
⁵ Section 14(1) of PAIA- The information officer of a public body must, in at least three official languages, make available a manual containing information listed in paragraph 4 above.

⁶ Section 51(1) of PAIA- The head of a private body must make available a manual containing the description of the information listed in paragraph 4 above.
⁷ Section 15(1) of PAIA- The information officer of a public body, must make available in the prescribed manner a description of the categories of records of the public body that are automatically available without a person having to request access
⁸ Section 52(1) of PAIA- The head of a private body may, on a voluntary basis, make available in the prescribed manner a description of the categories of records of the private body that are automatically available without a person having to request access
⁹ Section 22(1) of PAIA- The information officer of a public body to whom a request for access is made, must by notice require the requester to pay the prescribed request fee (if any), before further processing the request.
¹⁰ Section 54(1) of PAIA- The head of a private body to whom a request for access is made must by notice require the requester to pay the prescribed request fee (if any), before further processing the request.

¹¹ Section 92(1) of PAIA provides that –“The Minister may, by notice in the Gazette, make regulations regarding-
(a) any matter which is required or permitted by this Act to be prescribed;
(b) any matter relating to the fees contemplated in sections 22 and 54;
(c) any notice required by this Act;
(d) uniform criteria to be applied by the information officer of a public body when deciding which categories of records are to be made available in terms of section 15; and
(e) any administrative or procedural matter necessary to give effect to the provisions of this Act.”

5. CATEGORIES OF RECORDS OF CROSSBOW MARKETING CONSULTANTS (PTY) LTD WHICH ARE AVAILABLE WITHOUT A PERSON HAVING TO REQUEST ACCESS
5.1 In accordance with Section 52(1) of the Promotion of Access to Information Act, 2000 (“the Act”), the following categories of records are automatically available to the public from Crossbow Marketing Consultants (Pty) Ltd, without a person having to submit a formal request for access in terms of the Act. These records are available at the offices of the Company, on the Company’s website, or upon informal request from the Information Officer.
Category of Records Types of the Record Available on Website Available upon Request
Corporate Information Company Profile
Business Contact Details 		x x
Marketing & Promotional Material Product catalogues, brochures
Product pricing
Advertising and promotional material
Press releases, newsletters and media statements
Information published on the Company’s website and social media platforms 		x x
General Client and Partner Information Charities represented
General descriptions of products and services offered on behalf of charities
Testimonials and success stories approved for public release 		x x
Employment and Recruitment Advertised employment opportunities and application procedures x x
Legal and Compliance Information PAIA Manual
Privacy Policy 		x x
6. DESCRIPTION OF THE RECORDS OF CROSSBOW MARKETING CONSULTANTS (PTY) LTD WHICH ARE AVAILABLE IN ACCORDANCE WITH ANY OTHER LEGISLATION
6.1. In accordance with Section 51(1)(d) of the Promotion of Access to Information Act, Crossbow Marketing Consultants (Pty) Ltd holds records that are required to be maintained and, in some cases, made available in terms of other South African legislation applicable to its business.
6.2. Where disclosure of such records is required by law, access will be provided in accordance with the relevant legislative provisions.
6.3. The principal legislation applicable to the Company includes, but is not limited to, the following:
Category of Records Applicable Legislation
Company and Corporate Records Companies Act 71 of 2008:
Company Registration Documents, Director Information and Annual Returns
Financial and Tax Records Income Tax Act 58 of 1962:
Tax returns and related correspondence

Value-Added Tax Act 89 of 1991:
VAT records and invoices
Employment Records Basic Conditions of Employment Act 75 of 1997:
Employee contracts and employment-related records

Labour Relations Act 66 of 1995:
Disciplinary and grievance records (where applicable)

Unemployment Insurance Act 63 of 2001
and Compensation for Occupational Injuries and Diseases Act 130 of 1993:
Contribution and claim records
Marketing, Consumer and Information Laws Consumer Protection Act 68 of 2008:
Product information and consumer communications

Electronic Communications and Transactions Act 25 of 2002:
Electronic correspondence and online marketing records

Protection of Personal Information Act 4 of 2013 (POPIA):
Personal information processing and privacy compliance documentation
7. DESCRIPTION OF THE SUBJECTS ON WHICH THE BODY HOLDS RECORDS AND CATEGORIES OF RECORDS HELD ON EACH SUBJECT BY CROSSBOW MARKETING CONSULTANTS (PTY) LTD
7.1. In accordance with Section 51(1)(e) of the Promotion of Access to Information Act, the following categories of records are held by Crossbow Marketing Consultants (Pty) Ltd in respect of the subjects listed below.
7.2. Access to these records will be subject to the provisions of PAIA, other applicable legislation, and the Company’s internal policies.
Subjects on which the body holds records Categories of records
Company Administration and Governance • Company incorporation documents
• Memorandum of Incorporation and CIPC registration records
• Minutes of directors’ meetings and resolutions
• Statutory registers (shareholders, directors, etc.)
• Annual returns and compliance filings
Financial and Accounting Records • Annual financial statements and management accounts
• General ledger and trial balances
• Invoices, receipts, and payment records
• VAT and tax documentation
• Supplier and client payment information
Human Resources and Employment • Employee contracts and personnel files
• Attendance, leave, and payroll records
• Disciplinary and grievance records (where applicable)
• UIF and workmen’s compensation documentation
Marketing and Client Services • Client contracts and service agreements
• Campaign briefs, proposals, and reports
• Marketing materials, advertisements, and artwork
• Customer databases (maintained in compliance with POPIA)
• Correspondence with clients and suppliers
Legal and Compliance • Agreements with clients, suppliers, and service providers
• Insurance records and policy documents
• POPIA and data-protection compliance records
• Consumer Protection and ECTA compliance information
Information Technology and Communication • Company email and communication records
• Website content and analytics reports
• System and software licences
• Data backup and security documentation
General and Miscellaneous Records • Internal correspondence and memoranda
• Health and safety information (where applicable)
• Corporate social responsibility or sponsorship records (where applicable)
8. PROCESSING OF PERSONAL INFORMATION
8.1. Purpose of Processing Personal Information

Crossbow Marketing Consultants (Pty) Ltd processes personal information in order to carry out its business operations as a direct marketing company. Personal information is collected and processed for the following purposes:

• To market and promote products on behalf of our fundraising clients;
• To maintain client and supplier relationships;
• To process and fulfil customer orders and related transactions;
• To communicate with clients, service providers, and customers;
• To administer employee records and comply with employment legislation;
• To comply with financial, tax, and other legal requirements; and
• To manage the Company’s operations, including billing, record keeping, and security.
8.2. Description of the categories of Data Subjects and of the information or categories of information relating thereto.
Categories of Data Subjects Personal Information that may be processed
Customers / Clients Name, address, contact numbers, order and payment details
Service Providers Names, registration number, business address, VAT number, contact details, banking information, and contractual details
Employees Names, contact details, addresses, identity numbers, qualifications, employment history, demographic information, banking details, and tax information
Website Visitors / Marketing Contacts Names, email addresses, telephone numbers, and consent records for marketing purposes
8.3. The recipients or categories of recipients to whom the personal information may be supplied.
Category of personal information Recipients or Categories of Recipients to whom the personal information may be supplied
Identity number and names for criminal checks South African Police Services
Qualifications for qualification verifications South African Qualifications Authority
Credit and payment history for credit information Credit Bureaus
Employee and payroll information SARS, Department of Labour and authorised payroll service providers.
Information required by law Regulatory authorities or law enforcement agencies, where disclosure is legally required.
8.4. Planned transborder flows of personal information

Some personal information may be transferred or stored outside the Republic of South Africa when the Company uses cloud-based service providers or communication platforms located abroad (for example, email, CRM or data storage services).

Where such transfers occur, Crossbow Marketing Consultants (Pty) Ltd ensures that appropriate data protection safeguards are in place and that the service providers are subject to data protection laws or contractual obligations substantially similar to those imposed by POPIA.
8.5. General description of Information Security Measures

Crossbow Marketing Consultants (Pty) Ltd takes appropriate, reasonable technical and organisational measures to secure the integrity and confidentiality of personal information in its possession or under its control.

These include, but are not limited to:

• CRM and client database stored locally with encryption;
• Physical access controls at business premises;
• Use of password protection and user access controls on all systems;
• Staff awareness and confidentiality undertakings;
• Secure cloud-based storage with encryption;
• Regular data backups and secure offsite storage;
• Antivirus, anti-malware, and firewall protection.
9. AVAILABILITY OF THE MANUAL
9.1. A copy of the Manual is available–

9.1.1. on the Crossbow Marketing Consultants (Pty) Ltd website, www.kindhearted.co.za;

9.1.2. at the head office of Crossbow Marketing Consultants (Pty) Ltd, for public inspection during normal business hours;

9.1.3. to any person upon request and upon the payment of a reasonable prescribed fee; and

9.1.4. to the Information Regulator upon request.
9.2. A fee for a copy of the Manual, as contemplated in Annexure B of the Regulations, shall be payable per each A4-size photocopy made.
10. UPDATING OF THE MANUAL
10.1. Crossbow Marketing Consultants (Pty) Ltd will, on a regular basis, update this manual.

Issued by

Elton-Brett Harding
Managing Director

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