1. Introduction

This manual explains how Eunifin (Pty) Ltd t/a Republik (”Republik”) complies with the Promotion of Access to Information Act (PAIA), enabling transparent access to certain company records. All requests for access to records in terms of PAIA must be in writing in terms of this PAIA Manual and must be addressed at the contact details below. This PAIA Manual may be updated periodically, with amendments published on our website.

2. Contact Details 

Information Officer: Chesznokov Zungu

Postal address: 155 West Street, 2nd Floor, Sandton, Gauteng, South Africa, 2196 

Physical address: 155 West Street, 2nd Floor, Sandton, Gauteng, South Africa, 2196 

Email: chesznokov@republik.africa

3. Guides

In terms of Section 10 of PAIA (as amended), the South African Human Rights Commission (SAHRC) initially published a guide to assist individuals in exercising their rights under PAIA. This guide has since been revised and updated by the Information Regulator. Its purpose is to provide the necessary information to any person wishing to exercise their right of access to records under PAIA. 

Copies of PAIA and the relevant regulations and guides to this act, can be obtained from the SAHRC or the Information Regulator and queries should be directed to: 

The South African Human Rights Commission: 
Phone number: +27 (11) 877 3600 
E-mail:
complaints@sahrc.org.za 
Website:
http://www.sahrc.org.za 

The Information Regulator (South Africa): 
Phone number: +27 (0)10 023 5200 
E-mail:
POPIAComplaints@inforegulator.org.za / PAIAComplaints@inforegulator.org.za 
Website:
https://inforegulator.org.za

4. Records Availability

4.1 These records are openly accessible and do not require a request: 

● Promotional and marketing materials intended for public distribution. 
● General information relating to Republik products and services publicly available on our website. 

4.2 These types of records require submission of a formal request before access can be granted, under PAIA: 

● Customer records:
 I. Records submitted by customers or third parties acting on their behalf. 
 II. Records created by Republik relating to customer transactions, account details, or service usage. 

● Private records:
  I. Internal company policies and procedures. 
 II. Financial and operational documents. 
III. Databases and IT system information. 
IV. Internal and external correspondence. 
V. Records maintained in compliance with statutory obligations.

5. Legislation Applicable to Records Retention 

We retain records as required by relevant legislation, including but not limited to: 

● Protection of Personal Information Act, 4 of 2013 
● Basic Conditions of Employment Act, 75 of 1997 
● Companies Act, 71 of 2008 
● Financial Intelligence Centre Act, 38 of 2001 
● Labour Relations Act, 66 of 1995 
● Value-Added Tax Act, 58 of 1962

6. Core Principles 

Republik complies with both the PAIA and the Protection of Personal Information Act (POPIA) in all its record-keeping and disclosure practices. While PAIA is designed to promote transparency and access to information, POPIA focuses on protecting personal information and preventing unauthorized disclosure.This integrated approach fosters both accountability and privacy protection in our operations. 

In the course of business, personal information may be shared with certain authorized recipients or third parties, but always on a need-to-know basis and in line with POPIA’s conditions for lawful processing. Such recipients might include service providers or contractors who assist in our operations, affiliated business partners, or regulators and authorities when we are legally compelled to do so. Importantly, any third party handling personal data on Republik’s behalf is contractually obligated to protect that information. We only disclose personal data to third parties under proper agreements that ensure confidentiality and compliance with data protection laws. 

6.1 Information Security Measures 

We maintain robust technical and organizational security measures to protect personal information under our control. Republik has implemented measures such as two-factor authentication,access controls, encryption, secure data storage and regular monitoring of our systems to prevent loss, unauthorized access or misuse of personal data. In accordance with our policy, personal data is treated as confidential and safeguarded to ensure its integrity and availability. We continually assess and update our security practices to address new threats and to remain compliant with POPIA’s requirement to keep personal information secure.

Republik has implemented a comprehensive Privacy Policy that governs how we collect, use, store and share personal information. For more detailed information, the full Republik Privacy Policy is available on our website at:
https://www.eunifin.com/parivacy-policy-2 

7. Access Request

There are two different types of requesters: 
1. Personal requesters 
Personal requester is a requester who is seeking access to a record that relates to their personal information. 

2. Other requesters 
Other requester is a requester who is seeking access to a record that relates to third parties. 

The requester must fulfil the prerequisite requirements for access in terms of PAIA before Republik will consider a request for access to records. 

If a public body lodges a request, the public body must be acting in the public interest and provide details of the public interest that it is seeking to protect. 

To obtain access to Republik records under PAIA, a requester must follow these steps: 

● Submit a formal request: Complete the prescribed PAIA request form and submit it to Republik’s Information Officer via email at
info@republik.africa. The request must be in writing and comply with PAIA’s procedural requirements. 

● Provide required details: Ensure the request form contains sufficient detail to identify the specific record(s) being requested, proof of the requester’s identity, the preferred form of access (e.g. paper copy, electronic copy, or inspection), and the requester’s postal or email address for correspondence. 

● State the purpose (Right exercised or protected): Indicate which right you seek to     exercise or protect by obtaining the information, and explain why the requested record is necessary for exercising or protecting that right (PAIA requires this information for requests to private bodies). 

● If applicable – third-party or representative requests: If you are making the request on behalf of someone else, clearly state this and provide proof of your authority or capacity to act for that person (for example, a power of attorney). 

● Pay the prescribed fee: Pay the required request fee (if applicable) and any other applicable fees. Republik will not begin processing the request until any prescribed fee is paid in full. 

PAIA provides for two types of fees, namely: 
1. a request fee, which will be a standard fee; and 
2. an access fee, which must be calculated by considering reproduction costs, search and preparation time and cost, as well as postal costs. 

8. Decision

Republik will, within 30 calendar days of receiving a valid PAIA request and any applicable fees, decide whether to grant or refuse access to the requested record. The requester will be notified of the outcome via email. Where applicable, reasons for the decision will be provided. This 30-day period may only be shortened in exceptional circumstances as permitted under the Act. 

The 30-day period may also be extended by a further period not exceeding 30 calendar days in instances where: 

● The request involves a large volume of information, or 
● Consultation is required within different divisions of Republik, or with another private body, and 
● The information cannot reasonably be obtained within the original period. 

Should an extension be necessary, Republik will notify the requester using the contact method specified above.

9. Appeals Procedure

● Internal procedure: Republik does not have internal appeal procedures. As such, the decision made by the information officer is final within Republik and the requester will have to exercise external remedies at their disposal if the request for information is refused and the requester is not satisfied with the answer supplied by the information officer. 

● External appeal: A requester who is dissatisfied with our  information officer’s refusal to disclose information may, within 180 days of notification of the decision, lodge a complaint with the Information Regulator for relief. The requester has 180 days from being informed of the Information Regulator’s decision to approach a competent court. The court may then review the matter and, if justified, order that the requested record be made available or grant other appropriate relief in accordance with PAIA. 

All appeals should be initiated promptly. By following this procedure, requesters ensure compliance with PAIA and enable Republik to handle access requests and any appeals in an efficient, lawful manner. 

Where a requester submits a complaint to the Republik and the requester is not satisfied with the outcome, or if the complaint is not resolved, the requester may lodge a complaint with the National Financial Ombud Scheme (NFO). 

10. Third-party records 

Where a requester has requested access to information of a third-party, the third-party concerned must be given 21 days: 

● to make representations to refuse access; or 
● to give written consent for the disclosure of the record to the requester. 

11. Records not found 

If all reasonable steps have been taken to find a record and such record cannot be found or the record does not exist, then Republik will notify the requester, by way of an affidavit or affirmation, that it is not possible to give access to the requested record. 

The affidavit or affirmation will provide a full account of all the steps taken to find the record or determine its existence, including details of all communications by us with every person who conducted the search. The above notice will be regarded as a decision to refuse a request for access. 

Download PAIA Request Form