MANUAL OF BEYOND IMAGINATION CONSULTING (PTY) LTD
Prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000
Draft prepared for attorney review. Drafted 09/09/2026. Risk rating R2. 🔴 Beyond does not currently have a PAIA manual, and every private body has been required to have one since 1 January 2022 — the exemption that covered smaller companies expired on 31 December 2021 and was not renewed. This draft closes that gap. It must be published on beyondic.co.za and made available at the registered address before it counts as compliance; sitting in a repository it does nothing.
Version 1.0 · Effective 9 September 2026
1. PARTICULARS OF THE PRIVATE BODY
| Registered name | Beyond Imagination Consulting (Pty) Ltd |
| Trading as | Beyond Imagination |
| Registration number | 2023/885807/07 |
| Registered and physical address | Waterford Court Office Park, 236 Glover Ave, Die Hoewes, Centurion, 0163, Gauteng |
| Postal address | As above |
| Telephone | +27 12 111 9164 |
| Info@beyondic.co.za | |
| Website | www.beyondic.co.za |
Head of the private body
In terms of section 1 of PAIA, the head of a private body that is a juristic person is its chief executive officer or equivalent officer, or their duly authorised delegate.
| Head / Information Officer | Antonie Holtzhausen |
| Contact | Info@beyondic.co.za · +27 12 111 9164 |
| Postal | As the address above, marked for the attention of the Information Officer |
🔴 Registration with the Information Regulator is outstanding. Section 55 of POPIA requires the Information Officer to be registered with the Regulator before performing their duties. It is free and done through the Regulator's online portal. Until it is done, this manual names an officer who is not yet registered, and that should be corrected before publication.
2. THE GUIDE PUBLISHED BY THE INFORMATION REGULATOR
Section 10 of PAIA requires the Information Regulator to publish a guide, in each official language, on how to use the Act. It explains how to request a record, how to appeal a refusal, and what the Act contains.
The guide is available from:
The Information Regulator (South Africa) JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001 PO Box 31533, Braamfontein, Johannesburg, 2017 Telephone: +27 10 023 5200 Email: inforeg@justice.gov.za · Enquiries: PAIAComplaints.IR@justice.gov.za Website: www.inforegulator.org.za
3. RECORDS AVAILABLE WITHOUT A PAIA REQUEST
3.1 Automatically available
The following are available on www.beyondic.co.za without any request:
- information about Beyond's services;
- the Terms and Conditions;
- the Privacy Policy;
- this manual;
- contact details.
3.2 Available in terms of other legislation
Certain records are accessible under other laws, and a PAIA request is not the route to them. These include records available under the Companies Act 71 of 2008 (section 26 — access to company records), the Basic Conditions of Employment Act 75 of 1997, the Labour Relations Act 66 of 1995, the Tax Administration Act 28 of 2011 and the Value-Added Tax Act 89 of 1991.
4. CATEGORIES OF RECORDS HELD
Records are held in electronic and, where necessary, paper form. Listing a category here does not mean access will be granted — every request is assessed against the grounds for refusal in Chapter 4 of PAIA, summarised in section 7 below.
| Category | Records included |
|---|---|
| Company secretarial | Certificate of incorporation, Memorandum of Incorporation, share register, director records, CIPC filings |
| Financial | Annual financial statements, management accounts, invoices issued and received, bank records, tax returns and assessments |
| Client and contract | Proposals, quotations, service agreements, service level agreements, correspondence, project records |
| Marketing and creative | Campaign material, designs, artwork, brand assets, analytics reports |
| Software products | Source code, technical documentation, product specifications, release records, architecture decisions |
| Employee and contractor | Employment contracts, contractor agreements, personnel records, payroll records, leave records, performance records |
| Supplier | Supplier agreements, purchase records, correspondence |
| Statutory and regulatory | Records kept under the Companies Act, the Income Tax Act 58 of 1962, the Tax Administration Act, and labour legislation |
| Data protection | This manual, privacy policies, operator agreements, records of data subject requests, records of any personal information breach |
| Insurance and risk | Policies, claims, risk assessments |
| Information technology | System documentation, access records, audit trails, backup records, security records |
4.1 Records held on behalf of somebody else
Beyond holds records on behalf of its software customers — their business and employee data, inside their own workspace.
Beyond will not release those records on a PAIA request made to Beyond. They belong to the customer, who is the responsible party for them. A request for them must be made to that business. Beyond will, where lawful, tell the customer that a request has been received.
5. HOW TO REQUEST A RECORD
5.1 The form
A request must be made on the prescribed form — Form C of the Regulations, published under GN R757 in Government Gazette 44658 of 24 June 2021 — available from www.inforegulator.org.za or from Beyond on request.
5.2 Where to send it
The Information Officer, Beyond Imagination Consulting (Pty) Ltd Waterford Court Office Park, 236 Glover Ave, Die Hoewes, Centurion, 0163, Gauteng Info@beyondic.co.za, with the subject line "PAIA Request"
5.3 What the request must contain
- Enough detail to identify the record and the Information Officer who must deal with it.
- The form of access required.
- Your postal address or electronic address in the Republic.
- If you want to be told about the outcome in any manner other than in writing, how and where.
- The right you are seeking to exercise or protect, and an explanation of why the record is required to exercise or protect it. Section 50(1)(a) of PAIA makes this the substantive test for a private body: a requester is entitled to a record only where it is required for the exercise or protection of any rights. A request that does not explain this will be refused.
- If the request is made on somebody else's behalf, proof of your authority.
5.4 Fees
| Request fee | R140.00, payable on submission, before the request is processed. Not payable by a personal requester requesting a record about themselves. |
| Access fee | Charged where access is granted, calculated per the prescribed tariff, covering reproduction, search and preparation time, and postage. |
| Deposit | Where search and preparation is estimated to exceed 6 hours, a deposit of one third of the access fee is payable. |
Fees are as prescribed in the PAIA Regulations and change when those change. Beyond will give a written estimate before work begins where an access fee is likely.
5.5 Timeframes
| Decision on the request | 30 days of receipt |
| Extension | A further 30 days where the request is for a large number of records or requires a search of records held elsewhere. You will be told in writing, with reasons. |
| Notice of the decision | In writing, with reasons where access is refused, and with the right to relief |
6. FORM OF ACCESS
Where access is granted, it may be given by: inspection; a copy; a transcript; or, for an electronic record, a printout or a copy in a format Beyond can reasonably produce. Where the requested form would unreasonably interfere with Beyond's operations or damage the record, another form may be given, with reasons.
7. GROUNDS ON WHICH ACCESS MAY OR MUST BE REFUSED
Chapter 4 of PAIA sets these out. In summary, access must or may be refused where the record contains:
| Ground | Section |
|---|---|
| Personal information about a third party, the disclosure of which would be unreasonable | s63 |
| Commercial information of a third party — trade secrets, financial or commercial information that could harm them, or information supplied in confidence | s64 |
| Information that would breach a duty of confidence owed to a third party | s65 |
| Information that could endanger the life or physical safety of an individual, or prejudice the security of property or a system | s66 |
| Records privileged from production in legal proceedings | s67 |
| Beyond's own commercial information — trade secrets, or information whose disclosure could harm its commercial or financial interests | s68 |
| Research information of a third party or of Beyond, where disclosure would seriously prejudice the research | s69 |
Section 70 — the public interest override. Access must be granted despite any of the above where disclosure would reveal a substantial contravention of the law or an imminent and serious public safety or environmental risk, and the public interest in disclosure clearly outweighs the harm.
Severance. Where only part of a record may be withheld, the rest is released with the protected part severed.
8. IF ACCESS IS REFUSED
There is no internal appeal against the decision of the head of a private body.
A requester who is dissatisfied may:
- Complain to the Information Regulator under section 77A of PAIA, within 180 days of the decision; or
- Apply to a court under section 78 of PAIA — a Magistrate's Court designated for the purpose, or the High Court having jurisdiction — within 180 days.
9. PROCESSING OF PERSONAL INFORMATION
Beyond processes personal information in accordance with POPIA. The purposes, categories, recipients, retention periods, cross-border position and data subject rights are set out in Beyond's privacy policies:
- beyondic.co.za/privacy — Beyond's marketing and agency business;
- the Beyond Software Privacy Policy — Beyond's software products, which also explains where Beyond acts as an operator for a business customer rather than as the responsible party.
10. AVAILABILITY OF THIS MANUAL
This manual is available:
- on www.beyondic.co.za, free of charge;
- at the registered address during business hours, for inspection free of charge;
- from the Information Regulator; and
- by email on request.
Copies are available in English. It is updated whenever a material change requires it, and each version carries an effective date.
For the attorney reviewing this
- Section 5.4, the fees. Stated per the PAIA Regulations as at the drafting date. Please confirm the current prescribed amounts, since these change by Gazette and a manual quoting a superseded tariff is worse than one quoting none.
- Section 4.1. Beyond declines PAIA requests for records held inside a customer's workspace on the ground that they belong to the customer. Please confirm that is the correct treatment, or whether Beyond must process such a request and refuse it under section 64 or 65 instead.
- The Information Officer's registration with the Regulator is outstanding and flagged in section 1. This manual should not be published until it is done.
- Section 8. Section 77A was inserted by the Protection of Personal Information Act's amendments to PAIA. Please confirm the complaint route and the 180-day period as currently in force.
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