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    Legal

    PAIA Manual

    Prepared in accordance with Section 51 of the Promotion of Access to Information Act, No. 2 of 2000 (PAIA) and the Protection of Personal Information Act, No. 4 of 2013 (POPIA).

    Version v2.0 · Revised

    1. Head of the private body and Information Officer (s51(1)(a))

    • Private body: Memories Made in Motion (Pty) Ltd (Reg. 2022/850950/07)
    • Head of the Private Body, Information Officer and Director: Sean FitzGerald
    • Street address: 48 5th Street, Wynberg, Sandton, 2090, South Africa
    • Postal address: Same as the street address — we do not maintain a separate post box.
    • Telephone: +27 61 518 1374
    • Email: admin@memoriesmotion.com
    • Website: memoriesmotion.co.za

    2. Guide of the Information Regulator (s10)

    The Information Regulator has published a Guide on how to use the Promotion of Access to Information Act. The Guide explains how to exercise the rights conferred by PAIA, and is available in the official languages from the Regulator’s website and on request from the Regulator at the address below.

    3. Categories of records held (s51(1)(c) and s51(1)(e))

    The following categories of records are held by Memories Made in Motion (Pty) Ltd. Records in these categories are not automatically available: access must be requested in terms of section 4 below, and may be refused on the grounds set out in section 6.

    Category of recordSubject the record relates toTypical contents
    Statutory and company recordsThe company, its directors and shareholdersCIPC registration documents, MOI, share register, director and shareholder details, statutory registers and resolutions.
    Financial, tax and VAT recordsThe company, clients, suppliers, SARSManagement accounts, annual financial statements, bank records, VAT returns and supporting invoices, tax submissions.
    Personnel recordsEmployees and contractorsEmployment contracts, payroll and remuneration records, leave records, disciplinary records, statutory employment returns.
    Client contracts, quotations, invoices and event briefsClients and prospective clientsSigned contracts and service agreements, quotations, invoices and statements, event briefs, run sheets, site plans and production schedules.
    Supplier and subcontractor recordsSuppliers, subcontractors, venues and freelancersSupplier agreements, purchase orders, subcontractor briefs, hire and logistics records, insurance and compliance certificates.
    Marketing and lead recordsProspective clients and website enquirersEnquiry and quote-request submissions, lead-magnet downloads, marketing consent records and consent version history.
    Website analytics and chat transcriptsWebsite visitorsAggregated page-view and performance telemetry, cookie-consent records, AI Concierge conversation transcripts.
    Payment recordsClients making paymentPayment references, payment status and reconciliation records held with our payment processor. We do not store full card numbers.

    The following are published on this website and may be accessed without a PAIA request: our services and capability information, public portfolio and marketing material, our Terms & Conditions, our Privacy & POPIA Notice, our Cookie Policy and this Manual.

    4. How to request access to a record

    1. Complete Form 2 of Annexure A to the PAIA Regulations, 2021 (Request for Access to Record of Private Body). The form is available from the Information Regulator at inforegulator.org.za.
    2. Attach proof of identity. Where you act on behalf of another person, attach proof of your authority to do so.
    3. Specify the record requested with enough detail for us to identify it, and state the form of access required (for example an electronic copy, a photocopy, or inspection).
    4. State the right you are seeking to exercise or protect, and why the record is required to exercise or protect it.
    5. Submit the completed form to the Information Officer at admin@memoriesmotion.com, or by delivery to 48 5th Street, Wynberg, Sandton, 2090.
    6. Pay the prescribed request fee where it applies (see section 5).

    Timelines. We must decide on a request within 30 days of receipt (PAIA s56). That period may be extended once, by up to a further 30 days (PAIA s57), where the request is for a large number of records or requires a search through records held at premises other than our office. We will notify you in writing of any extension and of our decision, in the manner you requested.

    A request under POPIA to correct or delete your personal information (POPIA s24), or to object to processing (POPIA s11(3)), is not a PAIA access request and does not carry the 30-day PAIA period. Those requests may be submitted through our POPIA request form.

    5. Prescribed fees

    The fees below are those prescribed for a private body in the PAIA Regulations, 2021 (Annexure B). We do not charge any fee that is not prescribed.

    • Request fee: R140.00, payable before the request is processed.
    • No request fee for a personal requester: a personal requester — a person requesting access to a record containing their own personal information — pays no request fee.
    • Photocopies and printed pages: R2.00 per A4 photocopy or printed page.
    • Electronic copies, transcriptions and copies onto electronic media: at the rates prescribed in PAIA Regulations, 2021 (Annexure B).
    • Search and preparation time: charged at the prescribed hourly rate for the time reasonably required to search for and prepare the record for disclosure, excluding the prescribed number of hours that are provided free of charge.
    • Deposit: where we reasonably estimate that preparation will exceed the prescribed free hours, a deposit of the prescribed proportion of the access fee is payable before the record is prepared.
    • Postage: at actual cost, where a copy is posted to you.

    The Information Officer will notify you in writing of the amount payable before the request is processed, and you may lodge a complaint or apply to court against that decision. The current prescribed amounts are published by the Regulator at inforegulator.org.za.

    6. Grounds for refusal

    Access to a record may be refused on the grounds set out in Chapter 4 of Part 3 of PAIA. Each request is assessed on its merits. The grounds include:

    • Mandatory protection of the privacy of a third party who is a natural person (s63).
    • Mandatory protection of the commercial information of a third party (s64).
    • Mandatory protection of confidential information of a third party (s65).
    • Mandatory protection of the safety of individuals and the protection of property (s66).
    • Mandatory protection of records privileged from production in legal proceedings (s67).
    • Commercial information of the private body, including trade secrets and information that could harm our commercial or financial interests (s68).
    • Research information of a third party or of the private body (s69).
    • Where the record does not exist or cannot be found (s55).

    Access must nonetheless be granted where the public-interest override in section 70 applies.

    7. Remedies available if a request is refused

    There is no internal appeal against a decision of the head of a private body. If your request is refused, or you are dissatisfied with a fee, an extension or the form of access granted, you may:

    • Lodge a complaint with the Information Regulator within 180 days of the decision, on the prescribed complaint form, addressed to PO Box 31533, Braamfontein 2017, or by email to PAIAComplaints@inforegulator.org.za; or
    • Apply to a court for appropriate relief in terms of section 78 of PAIA.

    Consumer complaints that are not about access to information may be escalated to the Consumer Goods & Services Ombud (CGSO) (complaints@cgso.org.za, 0860 000 272).

    8. Processing of personal information (POPIA)

    This section is included as required for a private body’s manual. Our full notice is set out in our Privacy & POPIA Notice.

    8.1 Purposes of processing

    • Preparing quotations and concluding contracts.
    • Planning and delivering events, including logistics, staffing and supplier coordination.
    • Invoicing, payment collection, VAT and statutory financial reporting.
    • Marketing communications, where the recipient has consented or is an existing customer within the limits of POPIA s69.
    • Website analytics and performance measurement.
    • Operating the AI Concierge on this website.
    • Operating the client portal, where a client uses it.

    8.2 Categories of data subjects and of personal information

    • Clients and prospective clients: name, organisation, contact details, event brief and requirements, billing details, correspondence.
    • Event guests: name, dietary or accessibility requirements and seating details, where a client supplies them to us.
    • Employees and contractors: identity and contact details, contract and remuneration records, statutory employment information.
    • Suppliers and subcontractors: contact details, banking and tax details, compliance documentation.
    • Website visitors: IP-derived location, device and browser information, pages viewed, consent choices, chat transcripts.

    8.3 Recipients and categories of recipients

    Personal information may be shared with our operators and professional recipients, under contract and only to the extent needed for the purpose:

    • Operators (processors): Supabase (database, authentication and edge functions), Lovable (application hosting), Google (email delivery and analytics), Meta (advertising measurement), PostHog (product analytics), Paystack (payment processing) and our email delivery provider.
    • Professional and commercial recipients: accountants and auditors, insurers, banks, legal advisers, venues, suppliers and logistics providers engaged for a specific event.
    • Regulators and authorities: where disclosure is required by law.

    8.4 Planned transborder flows

    Some of the operators listed above process and store personal information outside South Africa, including in the European Union and the United States. Where personal information is transferred across a border, we rely on the safeguards permitted by section 72 of POPIA — binding contractual terms with the recipient that provide an adequate level of protection, or the data subject’s consent, or necessity for the performance of a contract with the data subject.

    8.5 General description of security measures

    • Encryption of personal information in transit using TLS.
    • Access controls and row-level security on the database, so records are reachable only by the roles that need them.
    • Multi-factor authentication on administrative access.
    • Written operator agreements requiring confidentiality and appropriate security from our processors.
    • Logging of administrative and data-subject-request activity for audit purposes.

    9. Records available in terms of other legislation

    Records are also held, and access to certain records is governed, in terms of the following legislation:

    • Companies Act 71 of 2008
    • Tax Administration Act 28 of 2011
    • Value-Added Tax Act 89 of 1991
    • Income Tax Act 58 of 1962
    • Basic Conditions of Employment Act 75 of 1997
    • Labour Relations Act 66 of 1995
    • Protection of Personal Information Act 4 of 2013
    • Consumer Protection Act 68 of 2008
    • Electronic Communications and Transactions Act 25 of 2002
    • Occupational Health and Safety Act 85 of 1993

    10. Availability of this Manual, version and review

    • This Manual is available on this website at memoriesmotion.co.za/paia.
    • A printed copy is kept for public inspection, free of charge, at 48 5th Street, Wynberg, Sandton, 2090 during business hours.
    • A copy is available on request by email to admin@memoriesmotion.com at no charge. A printed copy posted to you is charged at R2.00 per A4 photocopy or printed page, plus postage at actual cost.
    • This Manual has been submitted to the Information Regulator as required, and Memories Made in Motion (Pty) Ltd is registered with the Information Regulator.
    • Version v2.0, revised . We review this Manual at least annually, and whenever our records, operators or processing purposes change materially.