PAIA Manual

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

This Manual applies to Zinia ISP (Pty) Ltd, Zinia Connect (Pty) Ltd and Zinia Devworks (Pty) Ltd, collectively trading as Zinia.

References to “Zinia” throughout this Manual include all three entities unless the context indicates otherwise.

Collectively referred to in this Manual as “Zinia”.

Date of Compilation: April 2026
Date of Revision: June 2026

TABLE OF CONTENTS

1. List of Acronyms and Abbreviations
2. Purpose of the PAIA Manual
3. Key Contact Details for Access to Information
4. Guide on How to Use PAIA
5. Categories of Records Available Without a Formal Request
6. Records Available in Accordance with Other Legislation
7. Description of Subjects on Which Records Are Held
8. Processing of Personal Information
9. Availability of the Manual
10. Updating of the Manual

1. LIST OF ACRONYMS AND ABBREVIATIONS

2. PURPOSE OF THE PAIA MANUAL

This Manual is prepared in accordance with Section 51 of PAIA and assists members of the public to:

• Understand the categories of records held by Zinia
• Understand how to request access to records held by Zinia
• Access the contact details of the Information Officer and Deputy Information Officer
• Understand how personal information is processed by Zinia in accordance with POPIA
• Understand the categories of information held by Zinia
• Understand the recipients or categories of recipients to whom personal information may be supplied
• Understand whether personal information may be transferred outside South Africa
• Understand the security measures implemented to protect personal information

3. KEY CONTACT DETAILS FOR ACCESS TO INFORMATION

The Information Officer and Deputy Information Officer act on behalf of Zinia ISP (Pty) Ltd, Zinia Connect (Pty) Ltd and Zinia Devworks (Pty) Ltd, collectively trading as Zinia.

3.1 Information Officer

Name: Francis James Mullen
Position: Information Officer
Telephone: +27 11 462 0900
Email: privacy@zinia.co.za

3.2 Deputy Information Officer

Name: Julie Davis
Position: Deputy Information Officer
Telephone: +27 11 462 0900
Email: privacy@zinia.co.za

3.3 Access to Information Contact

Email: privacy@zinia.co.za

3.4 Head Office

Postal Address: Same as physical.

Physical Address: Block 10, Longmorn East, Kildrummy Office Park, Cnr Witkoppen &, Umhlanga Ave, Paulshof, Sandton, 2056

Telephone: +27 11 462 0900

Email: info@zinia.co.za

Website: www.zinia.co.za

4. GUIDE ON HOW TO USE PAIA

The Information Regulator has published a guide on exercising rights under PAIA and POPIA.

The Guide contains information relating to:

• The purpose and objectives of PAIA and POPIA
• How to request access to records
• How to lodge a complaint with the Information Regulator
• Available remedies under PAIA and POPIA
• Applicable fees payable in terms of PAIA
• The responsibilities of Information Officers and Deputy Information Officers

The Guide may be obtained:

Information Regulator (South Africa)

Website: https://www.justice.gov.za/inforeg/

Email: enquiries@inforegulator.org.za

Members of the public may also request assistance from Zinia’s Information Officer.

5. CATEGORIES OF RECORDS AVAILABLE WITHOUT A FORMAL REQUEST

6. RECORDS AVAILABLE IN ACCORDANCE WITH OTHER LEGISLATION

7. DESCRIPTION OF THE SUBJECTS ON WHICH ZINIA HOLDS RECORDS

Records may be held by one or more of the Zinia entities, depending on the nature of the service, contractual relationship, employment relationship, or business activity in question.

8. PROCESSING OF PERSONAL INFORMATION

8.1 Purpose of Processing Personal Information

Zinia processes personal information for:

• Service delivery and support
• Contract administration
• Client relationship management
• Supplier management
• Recruitment and employment administration
• Financial and accounting administration
• Marketing communications where consent has been obtained or another lawful basis applies
• Compliance with legal and regulatory obligations
• Information security and fraud prevention

8.2 Categories of Data Subjects and Personal Information Processed

8.3 Recipients or Categories of Recipients

8.4 Planned Transborder Flows of Personal Information

Zinia makes use of cloud-based technologies and service providers, which may process or store personal information outside South Africa.

Personal information may be transferred to countries where cloud hosting, backup, productivity, communication, cybersecurity, customer relationship management and other business services are provided.

Such transfers are subject to appropriate contractual, technical and organisational safeguards to ensure compliance with POPIA.

8.5 Information Security Measures

Zinia maintains reasonable technical and organisational measures to protect personal information, including:

• Access control and user authentication
• Multi-factor authentication where applicable
• Encryption of sensitive information
• Endpoint protection and anti-malware controls
• Firewalls and network security controls
• Data backup and disaster recovery measures
• Security monitoring and incident management processes
• Employee awareness and security training
• Supplier and third-party security assessments where appropriate

9. AVAILABILITY OF THIS MANUAL

A copy of this Manual is available:

• On the Zinia website at www.zinia.co.za
• At the Zinia head office during normal business hours
• Upon written request to the Information Officer
• To the Information Regulator upon request

A reasonable fee may be charged for printed copies in accordance with applicable regulations.

UPDATING OF THE MANUAL

Zinia reserves the right to review and update this Manual from time to time in order to ensure ongoing compliance with applicable legislation and business requirements.

Issued by:

Francis James Mullen

Information Officer

Zinia