# PAIA Manual - Section 51

**Promotion of Access to Information Act 2 of 2000**
**Section 51 Manual for Private Bodies**

**Free Me South Africa (Pty) Ltd**
Registration Number: 2025/384802/07
Version 1.1 | Compiled: 24 August 2026

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## Part 1: Introduction

Section 51 of the Promotion of Access to Information Act 2 of 2000 ("PAIA") requires every private body to compile a manual describing the records held by that body and the procedure for requesting access to those records.

This manual is published in accordance with Section 51(1) and is available at www.freemesouthafrica.co.za/legal/paia-manual and at the FMSA registered office.

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## Part 2: Company Details

| | |
|---|---|
| **Company Name** | Free Me South Africa (Pty) Ltd |
| **Registration Number** | 2025/384802/07 |
| **Business Address** | Fountain Road, Beverley, Sandton, Gauteng, South Africa |
| **Email** | exclusions@freemesouthafrica.co.za |
| **WhatsApp** | +27 66 215 4063 |
| **Website** | www.freemesouthafrica.co.za |

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## Part 3: Information Officer

In terms of POPIA Section 1, as read with Section 55 of PAIA, the Information Officer of Free Me South Africa (Pty) Ltd is:

**Pierre van Staden**
Founder and Chief Executive Officer
exclusions@freemesouthafrica.co.za

The Information Officer is responsible for:
- Encouraging compliance with the conditions for lawful processing of personal information
- Dealing with requests made to the body pursuant to PAIA
- Working with the Information Regulator in relation to investigations conducted pursuant to POPIA Chapter 6
- Ensuring compliance with POPIA at the operational level

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## Part 4: Guide on How to Use PAIA

The South African Human Rights Commission (SAHRC) has published a guide on the use of PAIA.

Contact the SAHRC:
- Website: www.sahrc.org.za
- Email: paia@sahrc.org.za
- Phone: +27 11 877 3600

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## Part 5: Records Held by FMSA

### 5.1 Records Held in Terms of Legislation

FMSA holds the following records as required by law:

| Records | Legislation |
|---|---|
| NGB Form 1/1 (completed and signed) | National Gambling Act 7 of 2004; GG No. 26994 (12 November 2004) |
| FMSA Self-Exclusion Submission Certificate | National Gambling Act 7 of 2004 |
| Proxy Consent and Authorisation Certificate | POPIA Section 11; ECTA Section 13 |
| Immutable audit trail records | ECTA Section 15; NGA |
| POPIA processing records | POPIA Section 17 |
| Email dispatch records (NGB/PGB notifications) | NGA Section 14 |

### 5.2 Records Held for Operational Purposes

| Category | Description |
|---|---|
| User registration records | Encrypted account data for registered applicants |
| SE registration records | SE numbers, case numbers, duration, scope, status |
| NGB audit records | Record of NGB/PGB submission acknowledgements |
| Counselling referral records | Records of NRGP referrals requested through the Platform |
| Operator check logs | Log of operator identity verification queries (no PII - SHA-256 hashes only) |
| Financial records | Company financial records |
| Employment records | Staff contracts, HR records |
| Supplier contracts | Agreements with OmniCheck, LogicSMS, hosting and SMTP providers |

### 5.3 Records Voluntarily Disclosed

FMSA voluntarily discloses the following records through its website:
- These Terms and Conditions
- Privacy Policy
- ECTA Compliance Notice
- Biometric and Special Data Notice
- Cookie Policy
- Acceptable Use Policy
- Data Processing Agreement (template)
- This PAIA Manual

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## Part 6: How to Request Access to Records

### 6.1 Requestor Categories

**Category A - Personal records (data subject requests):** If you are requesting your own records under POPIA Section 23, contact the Information Officer directly at exclusions@freemesouthafrica.co.za. FMSA aims to respond within 30 days.

**Category B - Third-party requests under PAIA:** Third parties requesting access to records not pertaining to themselves must follow the formal PAIA request procedure below.

### 6.2 Formal PAIA Request Procedure

Submit a written request to the Information Officer containing:
1. Your full name and contact details
2. A description of the records requested with sufficient detail to identify them
3. The form in which access is preferred (paper copies, electronic format)
4. Reasons for the request (note: reasons are not required for personal records requests under POPIA)
5. If the request is made on behalf of a third party, written proof of authorisation

Submit to:
- Email: exclusions@freemesouthafrica.co.za (subject line: "PAIA Request")
- Post: Attention: Information Officer, Free Me South Africa (Pty) Ltd

### 6.3 Response Timeframes (PAIA Section 25)

- **Acknowledgement:** Within 2 business days
- **Decision on request:** Within 30 days (extendable by 30 days under PAIA Section 26(1))
- **Urgent requests:** Contact the Information Officer by email marked urgent

### 6.4 Fees

PAIA prescribes certain fees for access requests. Current fees are set by regulation under PAIA and are published by the Department of Justice. FMSA will provide a fee estimate before processing a paid request.

No fee is charged for access by a data subject to their own records under POPIA.

### 6.5 Grounds for Refusal

FMSA may refuse access to records on the grounds set out in PAIA Sections 33-46, including:
- Records that would unreasonably disclose personal information of a third party (PAIA Section 34)
- Records subject to legal privilege (PAIA Section 40)
- Records that would endanger safety (PAIA Section 37)
- Commercial information (PAIA Section 36)

### 6.6 Appeals

If your request is refused, you may lodge an appeal with the Information Regulator (Section 77) or apply to court for relief (PAIA Section 82).

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## Part 7: Availability of This Manual

This PAIA Manual is available:
- On the FMSA website: www.freemesouthafrica.co.za/legal/paia-manual
- Within the FMSA Self-Exclusion Platform under "Legal Documents"
- By email from the Information Officer on request

It is updated annually or when significant changes to FMSA's record-keeping obligations occur.

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*Free Me South Africa (Pty) Ltd | Reg. 2025/384802/07*
*Compiled in terms of Section 51 of the Promotion of Access to Information Act 2 of 2000*