Promotion of Access to Information Act (PAIA) Manual

DC Lab

Prepared in accordance with section 51 of the Promotion of Access to Information Act 2 of 2000, and read together with the Protection of Personal Information Act 4 of 2013.

Registration number: 2021/990063/07

Date of compilation: 2026/06/10

Version: 1.0

1. Introduction

The Promotion of Access to Information Act 2 of 2000 (PAIA) gives effect to the constitutional right of access to information held by public and private bodies, where that information is required for the exercise or protection of any rights. This manual is published in compliance with section 51 of PAIA and the Protection of Personal Information Act 4 of 2013 (POPIA).

This manual sets out the records DC Lab (Pty) Ltd (DC Lab) holds, how a person can request access to them, the fees that may apply, and the requirements a request must meet. The right of access is not unlimited and is subject to justifiable limits, including the protection of privacy, commercial confidentiality, and good governance.

This manual must be read together with the DC Lab Privacy Policy.

2. The Information Regulator

The Information Regulator promotes and monitors the right of access to information and compliance with POPIA. The Regulator has published a Guide on how to use PAIA, available in the official languages on its website.

Information Regulator (South Africa)

Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001

Website: https://inforegulator.org.za

General enquiries: enquiries@inforegulator.org.za

PAIA complaints: PAIAComplaints@inforegulator.org.za

POPIA complaints: POPIAComplaints@inforegulator.org.za

Telephone: 010 023 5200

3. About DC Lab

DC Lab is a digital marketing agency operating from South Africa. Its services include paid media, social media management, content creation, video production, direct marketing, and gamification. DC Lab acts as the Responsible Party under POPIA for the personal information it processes in the course of its business and marketing activities.

Registered address: 129 Golden Mile Blvd, Golden Mile, St Helena Bay, 7390, South Africa.

4. Contact Details and Information Officer

All requests for access to records, and any questions about this manual, must be addressed to the Information Officer in writing.

Information Officer

Name: Gareth Monkley

Email: gareth@dclab.co.za

Telephone: 084 452 0893

Address: 129 Golden Mile Blvd, Golden Mile, St Helena Bay, 7390, South Africa

5. Records Held by DC Lab

5.1 Records automatically available

The following records are available without a formal PAIA request. They may be obtained from the DC Lab website or on request by email. A reproduction fee may apply where copies are made.

Marketing and promotional material intended for public viewing.

Service and product information published on the website.

This PAIA Manual and the DC Lab Privacy Policy.

Clients and leads may access their own personal information held by DC Lab without lodging a formal PAIA request, subject to identity verification and the grounds for refusal in section 8.

5.2 Categories of records

DC Lab generates or holds records in the following categories. These records are not automatically available and may be requested through the procedure in section 7.

Leads and clients - Names, contact details and addresses; enquiry and quote records; consent and marketing preference records; correspondence; project and campaign files.
Marketing operations - Campaign data; analytics and reporting; advertising account records; creative and content assets; lead lists and suppression lists.
Company administration - Company registration and statutory records; contracts; insurance; internal policies and procedures.
Finance - Invoices, financial records, bank records and tax records.
Human resources - Employee records, contracts, payroll and related personnel records.
Suppliers and partners - Supplier and contractor agreements, contact details and correspondence.
Technology - Website, hosting and system records; access logs and security records.

6. Processing of Personal Information (POPIA)

6.1 Purposes of processing

DC Lab processes personal information to:

Respond to enquiries and provide the services requested.

Manage relationships with clients and prospective clients.

Send marketing communications where the person has opted in.

Measure and improve website and marketing performance, including advertising and remarketing.

Comply with legal obligations and protect DC Lab's legitimate interests.

6.2 Categories of data subjects and personal information

Leads and prospective clients - Name and surname, email address, phone number, postal or physical address, enquiry details, marketing and consent preferences, and technical data such as IP address, browser, device, pages viewed and timestamps.
Clients - All of the above, plus project, billing and contract information.
Employees - Names, contact details, contracts, payroll and related personnel information.
Suppliers and partners - Representative contact details, banking details and contract information.
Website visitors - IP address, device and browser information, cookie identifiers and usage data.

6.3 Sharing of personal information

DC Lab does not sell personal information. It is shared only with operators who process it on DC Lab's instructions (for example analytics, email delivery and advertising platforms), with legal or regulatory bodies where required by law, and in the event of a business transfer. Sharing takes place only where there is a lawful basis under section 11 of POPIA.

6.4 Transborder flows of personal information

Some operators are located outside South Africa, including in the United States. Where personal information is transferred across borders, DC Lab applies the safeguards required by section 72 of POPIA, including reliance on standard contractual terms or comparable protection by the recipient.

6.5 Security and storage measures

DC Lab applies reasonable technical and organisational measures to protect personal information, including access controls, encryption where supported by its tools, secure authentication, restriction of access to staff who need it, and secure deletion or anonymisation when information is no longer required.

7. Procedure to Request Access to Records

7.1 Types of requester

Personal requester. A person seeking access to a record about their own personal information. They do not pay a request fee, although a reproduction fee may apply. Identity must be verified before access is given.

Other requester. Any other person requesting access to records, including records about a third party. The prescribed request fee applies, and where a third party's information is involved, the procedure in sections 71 to 73 of PAIA is followed.

7.2 Voluntary access

Records listed in section 5.1 can be obtained from the website or by email without the formal procedure. A reproduction fee may apply where copies are made.

7.3 Request procedure

The requester completes the prescribed PAIA request form (Form 2 under the PAIA Regulations) and submits it to the Information Officer at gareth@dclab.co.za, with proof of identity. Where the request is made on behalf of another person, proof of authority must be attached.
The form must contain enough detail to identify the record, the identity of the requester, the form of access required, and a contact address. A requester seeking records other than their own must identify the right they wish to exercise or protect, and explain why the record is required for that purpose.
Once the required information and any applicable fee are received, DC Lab responds within 30 days. This may be extended once by a further period of up to 30 days where the request is large or complex, with written notice to the requester.
Where the request concerns a third party's information, that third party is given 21 days to make representations or consent before a decision is made.
The requester is notified in writing of the outcome, in a form substantially similar to Form 3 under the PAIA Regulations. A refusal states the reasons and the relevant provisions of PAIA, and explains the right to complain or to approach a court.

If required information is missing or the right to be protected is not adequately explained, the request is not treated as valid until the missing information is provided.

7.4 Fees

The following prescribed fees apply. Confirm the current amounts in the PAIA Regulations, as they are updated from time to time.

Request fee (other requesters only; not charged to personal requesters) - R140.00
Photocopy or printed A4 page - R2.00 per page
Copy on flash drive (provided by requester) - R40.00
Search and preparation, per hour after the first hour - R145.00
Deposit where search exceeds six hours - One third of the access fee
Postage, email or electronic transfer - Actual cost

The request fee is payable before the request is processed. Where access is granted, an access fee for reproduction, search and preparation may apply, and the requester is notified of the amount in advance. A deposit is refunded if access is refused.

8. Refusal of Access

DC Lab may refuse access on the grounds set out in PAIA, including:

Protection of the privacy of a third party who is a natural person.

Protection of the commercial information or trade secrets of a third party or of DC Lab.

Information disclosed in confidence, or that is privileged in legal proceedings.

Protection of the safety of individuals or of property.

Requests that are clearly frivolous or vexatious, or that would involve an unreasonable diversion of resources, may be refused.

DC Lab does not operate an internal appeal procedure. A requester who is dissatisfied may, within 180 days, lodge a complaint with the Information Regulator or approach a court with jurisdiction.

9. Records That Cannot Be Found or Do Not Exist

Where DC Lab has taken all reasonable steps to find a record and it cannot be found or does not exist, the Information Officer notifies the requester by affidavit or affirmation, setting out the steps taken. This is treated as a decision to refuse access.

10. Disposal of Records

Records are retained and disposed of in line with the DC Lab Records and Retention Schedule. Personal information is kept only for as long as necessary for the purpose for which it was collected, or as required by law, and is then securely deleted or anonymised. Requesters are advised where a requested record has already been disposed of.

11. Availability of the Manual

This manual is available in English on the DC Lab website and on request from the Information Officer.

12. Updates

This manual is reviewed and updated as required. The current version applies from the date of compilation shown on the cover.

Annexure: Prescribed Forms

The current prescribed forms:

Form 2: Request for Access to Record of Private Body (completed by the requester).

Form 3: Outcome of Request and of Fees Payable (completed by the Information Officer).

These forms are published in the PAIA Regulations and are available on the Information Regulator website at https://inforegulator.org.za/paia.