Uni-E Distributors — PAIA & POPIA Manual

Sep 25, 2026 · @Chris Rossouw

Manual prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA), incorporating the information required by the Protection of Personal Information Act 4 of 2013 (POPIA). Draft for review by Uni-E and its legal adviser before publication.

1. Introduction

PAIA gives everyone the right to request access to records held by a private body where the record is required to exercise or protect a right. POPIA regulates how Uni-E Distributors collects, uses, stores, shares and deletes personal information.

This manual explains:

• who to contact at Uni-E Distributors about access to records or personal information;
• which records Uni-E Distributors holds and which are available without a formal request;
• how to submit a request, what it costs and how long it takes;
• the grounds on which a request may be refused, and what you can do if it is;
• how Uni-E Distributors processes personal information, and your rights as a data subject.

In this manual, “Uni-E”, “we” and “us” mean Uni-E Distributors as described in section 2.

2. Company details

3. Information Officer

All PAIA requests and all POPIA queries, objections and complaints go to the Information Officer.

The Information Officer’s duties include encouraging compliance with POPIA, dealing with requests made under PAIA and POPIA, working with the Information Regulator on any investigation, and keeping this manual up to date.

4. The Information Regulator’s PAIA Guide

The Information Regulator publishes a Guide (section 10 of PAIA) that explains how to use PAIA and POPIA to exercise your rights. It is available in all official languages from the Regulator’s website and offices, and a copy can be inspected at Uni-E’s head office during business hours.

5. Records available without a request

Uni-E has not published a section 52 notice. The following records are freely available without a PAIA request:

• information published on www.uni-e.co.za, including product information, prices, datasheets and brochures;
• marketing and promotional material;
• this manual;
• Uni-E’s Privacy Policy and Website Terms of Use.

Publicly available company information (such as registration details) can also be obtained from the Companies and Intellectual Property Commission (CIPC).

6. Records held in terms of other legislation

Uni-E keeps records as required by the following legislation, where it applies to Uni-E’s business. Some of these records may be available only to the persons specified in that legislation.

This list is not exhaustive and will be updated as legislation or Uni-E’s business changes.

7. Subjects and categories of records held

Records marked “Request” may be requested under PAIA and are subject to the grounds of refusal in section 11. “Public” records are available without a request.

8. Processing of personal information (POPIA)

Uni-E processes personal information only for lawful, specific purposes, collects only what it needs, and keeps it no longer than necessary.

8.1 Purposes of processing

• responding to product, sales and general enquiries and preparing quotations;
• supplying products, handling deliveries, warranty claims and after-sales support;
• assessing, approving and administering Apium installer registrations;
• communicating with installers about products, technical updates and training;
• sending marketing by email and/or WhatsApp only to people who have opted in to that channel;
• recruiting, employing and managing staff;
• managing suppliers and manufacturers;
• keeping accounting, tax and statutory records;
• operating, securing and improving the website;
• complying with law and protecting Uni-E’s legal rights.

8.2 Categories of data subjects and personal information

8.3 Recipients of personal information

Personal information is shared only as needed for the purposes above, with:

• Uni-E staff who need it for their work;
• service providers acting as operators under written agreements, including website hosting (xneelo, South Africa), email delivery and IT support [CONFIRM providers];
• manufacturers or brand owners where needed to process a warranty claim;
• courier and logistics companies for deliveries;
• professional advisers (auditors, attorneys) under confidentiality;
• regulators, SARS and law-enforcement bodies where required by law.

Uni-E does not sell personal information.

8.4 Cross-border transfers

The website and its databases are hosted in South Africa. Some service providers (for example email platforms or website security and content-delivery services) may store or route data outside South Africa [CONFIRM]. Any transfer will take place only in line with section 72 of POPIA — to countries or recipients bound by adequate data-protection laws or agreements, or with the data subject’s consent.

8.5 Security measures

Uni-E protects personal information with appropriate, reasonable technical and organisational measures, including:

• access limited to authorised staff by role, with two-factor authentication for website administrators;
• encrypted connections (HTTPS) for all website traffic;
• installer documents stored in a private location that cannot be reached by a public web address, downloadable only by authorised staff;
• firewall, spam and abuse protection on website forms;
• regular software updates and off-site backups;
• confidentiality obligations for staff and written operator agreements with service providers;
• deletion of supporting documents after the retention periods in section 8.6.

8.6 Retention

Personal information is kept only as long as needed for the purpose it was collected for (POPIA section 14), or longer where a law requires it (for example, tax records for five years under section 29 of the Tax Administration Act).

Installer documents are deleted automatically by the website when the period ends. Paper and backup copies are destroyed in the same way. Records may be kept longer only where the law requires it or a legal dispute is pending.

9. How to request access to a record

1. Complete the prescribed Form 2 (Request for Access to Record) under the PAIA Regulations, 2021. It is available from the Information Regulator’s website or from the Information Officer.
2. Send it to the Information Officer by email (colette@uni-e.co.za), post or hand delivery.
3. Describe the record in enough detail to identify it, state the form of access you want, and state the right you want to exercise or protect and why the record is needed.
4. If you ask on behalf of someone else, attach proof of your authority to act for them.
5. Pay the request fee (section 10) if you are not asking for your own personal information. We will tell you if a deposit or access fee is payable.

Timelines. We will decide on your request within 30 days of receipt and notify you. We may extend this once by up to 30 days if the request involves a large number of records, a search at another location or consultation with third parties; we will tell you why. If we do not respond in time, the request is regarded as refused.

Third parties. If a record contains information about another person or company, we must notify them and give them an opportunity to make representations before we decide.

Form of access. Access is given in the form you request (copy, inspection or electronic copy) where reasonably possible.

10. Prescribed fees

Fees are set by the PAIA Regulations, 2021 for private bodies. A requester asking only for their own personal information does not pay the request fee. VAT may be added.

Transcription or copying of visual images is outsourced and charged at the service provider’s quoted cost. Sources: Information Regulator — PAIA fees structure; Michalsons — fees for private bodies.

11. Grounds for refusal and remedies

Uni-E may or must refuse access on the grounds in Chapter 4 of Part 3 of PAIA, including where access would:

• unreasonably disclose personal information about a third party (s63);
• disclose a third party’s trade secrets or confidential commercial information (s64);
• breach a duty of confidence owed to a third party (s65);
• endanger the life or physical safety of a person, or the security of property (s66);
• disclose records privileged from production in legal proceedings (s67);
• disclose Uni-E’s own trade secrets or commercial information that could harm its competitive position (s68);
• disclose research information of Uni-E or a third party (s69).

Despite these grounds, access must be granted where disclosure would reveal a serious contravention of the law or an imminent and serious public-safety or environmental risk, and the public interest clearly outweighs the harm (s70). Requests that are manifestly frivolous or vexatious, or would unreasonably divert resources, may also be refused.

Remedies. PAIA provides no internal appeal against a private body. If you are unhappy with a decision (including a refusal, fees or an extension), you may within 180 days of being notified:

• lodge a complaint with the Information Regulator (section 77A, using the Regulator’s prescribed form); or
• apply to a court with jurisdiction (section 78).

12. Your rights under POPIA

We will respond to POPIA requests within a reasonable time and in line with the timelines in PAIA.

13. Availability and review of this manual

This manual is available:

• on the Uni-E website at www.uni-e.co.za/paia-manual/;
• for inspection at Uni-E’s head office in Bloemfontein during business hours, free of charge;
• from the Information Officer on request (a copy may be subject to the prescribed copy fee);
• to the Information Regulator on request.

Uni-E reviews this manual at least once a year and whenever its business, systems or the law change materially.