www.smoolink.co.za  
woza@smoolink.co.za  
+27 11 568 3734  
POPIA AND PAIA MANUAL  
Prepared in terms of section 51 of the  
Promotion of Access to Information Act 2  
of 2000 (as amended), and to address  
requirements of the Protection Of Personal  
Information Act 2013  
This manual applies to  
SmooLink Forwarding (Pty) Ltd.  
Registration number: 2023/270638/07  
DATE OF COMPILATION: 01/10/2021  
DATE OF REVISION: 01/10/2021  
SmooLink Forwarding (Pty) Ltd | Registration No: 2023/270638/07  
10240 Ext 7B, Bear Crescent Street, Orange Farm, 1841 Johannesburg, South Africa  
www.smoolink.co.za  
woza@smoolink.co.za  
+27 11 568 3734  
1. BACKGROUND  
The Promotion of Access to Information Act, No. 2of 2000 (the “Act) was enacted on 3  
February 2000, giving effect to the constitutional right in terms of section 32 of the Bill of  
Rights contained in the Constitution of the Republic of South Africa 108 of 1996 (the  
“Constitution”) of access to any information held by the state and any information that is  
held by another person and that is required for the exercise or protection of any rights. In  
terms of section 51 of the Act, all Private Bodies are required to compile an Information  
Manual (“PAIA Manual”).  
The Protection of Personal Information Act, 2013 (Act No. 4 of 2013) (the POPIA), provides for  
eight protection principles that companies must comply with to protect the Personal  
Information of all Data Subjects. Companies must implement a manual that must comply  
with section 14 and 51 of PAIA and is required to make it available to persons who want  
access to the companies’ Personal Information.  
Where a request is made in terms of the Act, the body to whom the request is made is  
obliged to release the information, subject to applicable legislative and / or regulatory  
requirements, except where the Act expressly provides that the information may be adopted  
when requesting information from a public or private body.  
2. THE PURPOSE OF THE POPIA IS TO -  
(a) give effect to the constitutional right to privacy, by safeguarding personal information  
when processed by a responsible party, subject to justifiable limitations that are aimed  
at—  
(i) balancing the right to privacy against other rights, particularly the right of access  
to information; and  
(ii) protecting important interests, including the free flow of information within the  
Republic and across international borders;  
(b) regulate the manner in which personal information may be processed, by establishing  
conditions, in harmony with international standards, that prescribe the minimum  
threshold requirements for the lawful processing of personal information;  
SmooLink Forwarding (Pty) Ltd | Registration No: 2023/270638/07  
10240 Ext 7B, Bear Crescent Street, Orange Farm, 1841 Johannesburg, South Africa  
www.smoolink.co.za  
woza@smoolink.co.za  
+27 11 568 3734  
(c) provide persons with rights and remedies to protect their personal information from  
processing that is not in accordance with the POPIA; and  
(d) establish voluntary and compulsory measures, including the establishment of an  
Information Regulator, to ensure respect for and to promote, enforce and fulfil the  
rights protected by the POPIA.  
The POPIA and the PAIA hold a special relationship. Both can be seen as "information" laws,  
and are each on one end of a continuum. On the one end, PAIA is an "Access" law, all about  
Freedom of Information. POPIA on the other end, is about Privacy - prevention of exposure of  
information. They should not be seen as competing, rather, both are there to help ensure that  
information is managed correctly. The requirements to access records as set out in PAIA  
remains in place.  
3. THE PURPOSE OF THE PAIA MANUAL  
The purpose of PAIA is to promote the right of access to information, to foster a culture of  
transparency and accountability within SmooLink Forwarding (Pty) Ltd by giving the right to  
information that is required for the exercise or protection of any right and to actively  
promote a society in which the people of South Africa have effective access to information  
to enable them to exercise and protect their rights.  
In order to promote effective governance of private bodies, it is necessary to ensure that  
everyone is empowered and educated to understand their rights in relation to public and  
private bodies. Section 9 of the Act recognizes that the right to access information cannot be  
unlimited and should be subject to justifiable limitations, including, but not limited to:  
(a) Limitations aimed at the reasonable protection of privacy;  
(b) Commercial confidentiality; and  
(c) Effective, efficient and good governance;  
and in a manner which balances that right with any other rights, including such rights  
contained in the Bill of Rights in the Constitution.  
SmooLink Forwarding (Pty) Ltd | Registration No: 2023/270638/07  
10240 Ext 7B, Bear Crescent Street, Orange Farm, 1841 Johannesburg, South Africa  
www.smoolink.co.za  
woza@smoolink.co.za  
+27 11 568 3734  
This PAIA Manual complies with the requirements of guide mentioned in section 10 of the  
Act and recognizes that upon commencement of the Protection of Personal Information Act  
4 of 2013, that the appointed Information Regulator will be responsible to regulate  
compliance with the Act and its regulations by private and public bodies.  
4. AVAILABILITY OF THE MANUAL  
A copy of the Manual is made available in terms of section 4 of the POPIA regulation, on the  
website, https://smoolink.co.za/ and at SmooLink Forwarding (Pty) Ltd’s office, situated at  
10240 Extension 7B, Orange Farm 1841, Johannesburg, for public inspection during normal  
business hours, and copies can be made to any person upon request and upon the payment  
of a reasonable prescribed fee; and to the Information Regulator upon request. A fee for a  
copy of the Manual, as contemplated in annexure B of the Regulations, shall be payable per  
each A4-size photocopy made.  
5. ABOUT THE COMPANY  
SmooLink Forwarding (Pty) Ltd, with registration number: 2023 / 270638 / 07, is a privately  
owned B-BBEE Level 1 Import and Export Freight Forwarding and Customs Clearing  
Business, offering General Cargo Shipping solutions, comprehensively from door to door  
and itemized options, tailored to your unique requirements, such as: Customs clearance  
only or haulage service from port to door, or vice versa. We handle shipments of any size; to  
and from anywhere in the world, by Sea; Air; Road, including National and Direct Cross-  
Border Import and Export haulage; Rail Freight and manage all Customs Clearing  
Formalities.  
6. COMPANY CONTACT DETAILS [PAIA Section 51(1)(a)]  
Operations Controller:  
Registered Address:  
Thato Shoto  
10240 Extension 7B, Orange Farm  
1841, Johannesburg.  
As above  
+27 11 568 3734  
https://smoolink.co.za  
Postal Address:  
Telephone Number:  
Website:  
SmooLink Forwarding (Pty) Ltd | Registration No: 2023/270638/07  
10240 Ext 7B, Bear Crescent Street, Orange Farm, 1841 Johannesburg, South Africa  
www.smoolink.co.za  
woza@smoolink.co.za  
+27 11 568 3734  
Contact Details of the Information Officer  
Thato Shoto  
Email: woza@smoolink.co.za  
7. SOUTH AFRICAN HUMAN RIGHTS COMMISSION [PAIA Section 51(1)(b)]  
The ACT grants a requester access to records of a private body, if the record is required for  
the exercise or protection of any rights. If a public body lodges a request, the public body  
must be acting in the public interest.  
Requests in terms of the ACT shall be made in accordance with the prescribed procedures,  
at the rates provided. The forms and tariff are dealt with in paragraphs 6 and 7 of the Act.  
Requesters are referred to the Guide in terms of Section 10 which has been compiled by the  
South African Human Rights Commission, which will contain information for the purposes of  
exercising Constitutional Rights. The Guide is available from the SAHRC.  
The contact details of the Commission are:  
The South African Human Rights Commission  
Physical Address:  
PAIA Unit  
29 Princess of Wales Terrace  
Cnr York and Andrew Streets  
Parktown  
Postal Address:  
Telephone Number:  
E-Mail:  
Private Bag 2700, Houghton 2041  
+27 11 877 3600  
PAIA@sahrc.org.za  
www.sahrc.org.za  
Web Site:  
8. PUBLICATION AND AVAILABILITY OF INFORMATION AND RECORDS  
8.1  
Records Available without a Request to Access in terms of the Act Records of a  
public nature, typically those disclosed on the SmooLink Forwarding (Pty) Ltd’s  
website, may be accessed without the need to submit a formal application. Other  
SmooLink Forwarding (Pty) Ltd | Registration No: 2023/270638/07  
10240 Ext 7B, Bear Crescent Street, Orange Farm, 1841 Johannesburg, South Africa  
www.smoolink.co.za  
woza@smoolink.co.za  
+27 11 568 3734  
non-confidential records, such as statutory records maintained at CIPC, may also be  
accessed without the need to submit a formal application, however, please note that  
an appointment to view such records will have to be made with the Information  
Officer.  
8.2 Where applicable to its operations, SmooLink Forwarding (Pty) Ltd also retains  
records and documents in terms of below legislation. Unless disclosure is prohibited  
in terms of legislation, regulations, contractual agreement or otherwise, records that  
are required to be made available in terms of these acts shall be made available for  
inspection by interested parties in terms of the requirements and conditions of the  
Act; the below mentioned legislation and applicable internal policies and procedures,  
should such interested parties be entitled to such information. A request to access  
must be done in accordance with the prescriptions of the Act.  
Legislations applicable to SmooLink Forwarding (Pty) Ltd:  
(a) Basic Conditions of Employment Act, No 75 of 1997;  
(b) Broad- Based Black Economic Empowerment Act, No 75 of 1997;  
(c) Companies Act, No 71 of 2008;  
(d) Copyright Act, No 98 of 1978;  
(e) Customs & Excise Act, 91 of 1964;  
(f) Electronic Communications Act, No 36 of 2005;  
(g) Electronic Communications and Transactions Act, No 25 of 2002;  
(h) Employment Equity Act, No 55 of 1998;  
(i) Identification Act, No. 68 of 1997;  
(j) Income Tax Act, No 58 of 1962;  
(k) Intellectual Property Laws Amendment Act, No 38 of 1997;  
(l) Labour Relations Act, No 66 of 1995;  
SmooLink Forwarding (Pty) Ltd | Registration No: 2023/270638/07  
10240 Ext 7B, Bear Crescent Street, Orange Farm, 1841 Johannesburg, South Africa  
www.smoolink.co.za  
woza@smoolink.co.za  
+27 11 568 3734  
(m) Promotion of Access to Information Act, No 2 of 2000;  
(n) Protection of Personal Information Act, No. 4 of 2013;  
[Note: although SmooLink Forwarding (Pty) Ltd used its best endeavours to provide a  
list of the latest applicable legislation, the list may be incomplete or outdated, due to  
changes in legislation. Kindly consult with the information officer concerning the  
applicability of any legislation, or if you believe that a right of access to a record  
exists in terms of other legislation listed above or any other legislation, the  
Requester must indicate what legislative right the request is based on, to allow the  
Information Officer the opportunity of considering the request in light thereof.]  
8.3 Records held by SmooLink Forwarding (Pty) Ltd [(PAIA Section 51 (1)(d)]  
Records may be available in three ways, namely: (a) Freely if publicly available, like -  
information and records available on https://smoolink.co.za (b) Made available but  
subject to copyright, or (c) Made available but subject to limited disclosure. A person  
may only request information from SmooLink Forwarding (Pty) Ltd as a private body  
if the requested information is required for the exercise or protection of a right. Note  
that the accessibility of the records may be subject to the grounds of refusal set out  
in this PAIA manual. Amongst other, records deemed confidential on the part of a  
third party, will necessitate permission from the third party concerned, in addition to  
normal requirements, before SmooLink Forwarding (Pty) Ltd will consider access.  
8.4 Categories of information that SmooLink Forwarding (Pty) Ltd holds:  
Subject  
Category  
Availability  
Personnel Records  
Employment Records  
Disciplinary Code and  
Records;  
May not be disclosed to the  
public. Limited disclosure to  
employees for own  
Performance Appraisals  
Training records  
employment records  
Staff agreements.  
SmooLink Forwarding (Pty) Ltd | Registration No: 2023/270638/07  
10240 Ext 7B, Bear Crescent Street, Orange Farm, 1841 Johannesburg, South Africa  
www.smoolink.co.za  
woza@smoolink.co.za  
+27 11 568 3734  
Public Affairs  
Public Company Information  
Website information  
Public policies and manuals  
Articles  
Freely available on website  
May not be disclosed  
Companies Act Records Statutory Company Records  
Shareholder agreements and  
certificates  
Corporate structure and  
associations  
Document of incorporation  
Business agreements  
Intellectual property Statutory  
returns  
Company policy and manuals  
Financial Records  
Accounting Records;  
Annual Financial Statements  
Asset Registers;  
May not be disclosed  
Bank Statements;  
Banking details and bank  
accounts;  
Debtors / Creditors  
statements and invoices; Tax  
Records  
Income Tax Records  
PAYE Records;  
Records of payments made to  
SARS on behalf of employees;  
All other statutory  
compliances:  
May not be disclosed  
VAT  
SmooLink Forwarding (Pty) Ltd | Registration No: 2023/270638/07  
10240 Ext 7B, Bear Crescent Street, Orange Farm, 1841 Johannesburg, South Africa  
www.smoolink.co.za  
woza@smoolink.co.za  
+27 11 568 3734  
Skills Development Levies  
Workmen’s Compensation  
Operations  
Standard Terms and  
Conditions for supply of  
services;  
May not be disclosed  
Client and supplier  
agreements;  
Lists of suppliers, services  
and Policies and Procedures.  
Client database;  
Correspondences with clients;  
Fees structure;  
FICA documents;  
Sales performance records.  
Information Technology  
IT services agreements;  
IT systems and facilities;  
Software licensing;  
May not be disclosed  
IT record keeping; Back-up  
and restore records  
9. REQUESTS TO ACCESS INFORMATION AND RECORDS [PAIA Section 51(1)(e)]  
9.1  
The requester must comply with all the procedural requirements contained in the Act  
relating to the request for access to a record. The requester must complete the  
prescribed form enclosed herewith, and submit same as well as payment of a request  
fee and a deposit (if applicable) to the Information Officer at the postal address, or  
electronic mail address as noted in clause 7 above. The prescribed from must be filled  
in with sufficient information to enable the Information Officer to identify: (a) the  
record or records requested; and (b) the identity of the requester.  
SmooLink Forwarding (Pty) Ltd | Registration No: 2023/270638/07  
10240 Ext 7B, Bear Crescent Street, Orange Farm, 1841 Johannesburg, South Africa  
www.smoolink.co.za  
woza@smoolink.co.za  
+27 11 568 3734  
9.2  
9.3  
The requester should indicate which form of access is required and specify a postal  
address or fax number of the requester in the Republic; The requester must state that  
he/she requires the information in order to exercise or protect a right, and clearly  
state what the nature of the right is, in order to be exercised or protected. The  
requester must clearly specify why the record is necessary to exercise or protect  
such a right [PAIA Section 53(2)(d)]  
SmooLink Forwarding (Pty) Ltd will process the request within 30 (thirty) days,  
unless the requester has stated special reasons to the satisfaction of the Information  
Officer that circumstances dictate that the above time periods not be complied with.  
The requester shall be advised whether access is granted or denied in writing. If, in  
addition, the requester requires the reasons for the decision in any other manner, the  
requester will be obliged to state which manner and the particulars required. If a  
request is made on behalf of another person, then the requester must submit proof of  
the capacity in which the requester is making the request to the reasonable  
satisfaction of the Information Officer [PAIA Section 53(2)(f)].  
9.4 If an individual is unable to complete the prescribed form because of illiteracy or  
disability, such a person may make the request orally. The requester must pay the  
prescribed fee, before any further processing can take place. All information as listed  
in this clause should be provided and failing which the process will be delayed until  
the required information is provided. The prescribed time periods will not commence  
until the requester has furnished all the necessary and required information. The  
Information Officer shall sever a record, if possible, and grant only access to that  
portion requested and which is not prohibited from being disclosed.  
10. ACCESS TO RECORDS HELD BY SMOOLINK FORWARDING (Pty) LTD  
Prerequisites for Access by Personal/Other Requester: Records held by SmooLink  
Forwarding (Pty) Ltd may be accessed by requests only once the prerequisite requirements  
for access have been met. There are two types of requesters: (a) Personal Requester and  
(b) Other Requester  
a. A personal requester is a requester who is seeking access to a record containing  
personal information about own self. SmooLink Forwarding (Pty) Ltd will voluntarily  
provide the requested information, or give access to any record with regard to the  
SmooLink Forwarding (Pty) Ltd | Registration No: 2023/270638/07  
10240 Ext 7B, Bear Crescent Street, Orange Farm, 1841 Johannesburg, South Africa  
www.smoolink.co.za  
woza@smoolink.co.za  
+27 11 568 3734  
requester's personal information. The prescribed fee for reproduction of the information  
requested will be applicable.  
b. Other Requester is any other person, rather than a personal requester, that is entitled to  
request access to information on third parties. In considering such a request, SmooLink  
Forwarding (Pty) Ltd will adhere to the provisions of the Act. Section 71 requires that  
the Information Officer take all reasonable steps to inform a third party to whom the  
requested record relates of the request, informing him/her that he/she may make a  
written or oral representation to the Information Officer why the request should be  
refused or, where required, give written consent for the disclosure of the Information.  
SmooLink Forwarding (Pty) Ltd is not obliged to voluntarily grant access to such records.  
The requester must fulfil the prerequisite requirements, in accordance with the  
requirements of the Act and as stipulated in Chapter 5; Part 3, including the payment of a  
request and access fee.  
11. FEES PAYABLE [PAIA Section 51 (1)(f)]  
The Act provides for two types of fees, namely: (a) A request fee, which is a form of  
administration fee to be paid by all requesters except personal requesters, before the  
request is considered and is not refundable; and (b) An access fee, which is paid by all  
requesters in the event that a request for access is granted. This fee is inclusive of costs  
involved by the private body in obtaining and preparing a record for delivery to the  
requester.  
When the request is received by the Information Officer, such officer shall by notice require  
the requester, other than a personal requester, to pay the prescribed request fee, before  
further processing of the request [PAIA Section 54(1)].  
If the search for the record has been made and the preparation of the record for disclosure,  
including arrangement to make it available in the requested form, requires more than the  
hours prescribed in the regulations for this purpose, the Information Officer shall notify the  
requester to pay as a deposit the prescribed portion of the access fee which would be  
payable if the request is granted. The Information Officer shall withhold a record until the  
requester has paid the fees as indicated below.  
SmooLink Forwarding (Pty) Ltd | Registration No: 2023/270638/07  
10240 Ext 7B, Bear Crescent Street, Orange Farm, 1841 Johannesburg, South Africa  
www.smoolink.co.za  
woza@smoolink.co.za  
+27 11 568 3734  
A requester whose request for access to a record has been granted, must pay an access  
fee that is calculated to include, where applicable, the request fee, the process fee for  
reproduction and for search and preparation, and for any time reasonably required in  
excess of the prescribed hours to search for and prepare the record for disclosure  
including making arrangements to make it available in the request form.  
LIST OF FEES PAYABLE:  
GENERAL  
An upfront Request Fee before a request will be processed in terms of  
Regulation 11(2)  
R50,00  
Fees for the manual as contemplated in Regulation 9(2)(c) payable for every  
photocopy of an A4-size page or part thereof.  
Reproduction of Information Fees, referred to in Regulation 11(1)  
Information in an A-4 size page photocopy or part thereof  
A printed copy of an A4-size page or part thereof  
A copy in computer-readable form on:  
R1,10  
R l,10  
R 0,75  
Stiffy disc  
R7,50  
Compact disc  
R 70,00  
R 40,00  
R 60,00  
R 20,00  
R 30,00  
A transcription of visual images, in an A4-size page or part thereof  
A copy of visual images  
A transcription of an audio record for an A4-size page or part thereof  
A copy of an audio record  
Access of Information Fees referred to in Regulation 11(3)  
Information in an A-4 size page photocopy or part thereof  
A printed copy of an A4-size page or part thereof  
A copy in computer-readable format, for example:  
Stiffy disc  
R 1,10  
R 0,75  
R 7,50  
Compact disc  
R 70,00  
R 40,00  
R 60,00  
R 20,00  
R 30,00  
R30,00  
A transcription of visual images, in an A4-size page or part thereof  
A copy of visual images  
A transcription of an audio record for an A4-size page or part thereof  
A copy of an audio record  
To search for and prepare the record for disclosure, the fee for each hour or  
SmooLink Forwarding (Pty) Ltd | Registration No: 2023/270638/07  
10240 Ext 7B, Bear Crescent Street, Orange Farm, 1841 Johannesburg, South Africa  
www.smoolink.co.za  
woza@smoolink.co.za  
+27 11 568 3734  
part of an hour required for such search and preparation.  
For purposes of section 54(2), the following applies:  
6 hours as the hours to be exceeded before a deposit is payable  
1/3rd of the access fee is payable as a deposit by the requester  
Actual postal fee is payable, where a copy of a record must be posted to the Requester.  
12. REFUSAL OF ACCESS TO RECORDS  
Chapter 4 of PAIA provides for several grounds on which a request for access to personal  
information must be refused.  
a. Grounds for refusal of request includes the following:  
(a) Mandatory protection of the privacy of a third party who is a natural person or a  
deceased person (section 63) or a juristic person, as included in the Protection of  
Personal Information Act 4 of 2013, which would involve the unreasonable disclosure  
of personal information of that natural or juristic person;  
(b) Mandatory protection of personal information and for disclosure of any personal  
information to, in addition to any other legislative, regulatory or contractual  
agreements, comply with the provisions of the Protection of Personal Information  
Act 4 of 2013;  
(c) Mandatory protection of the commercial information of a third party (section 64) if  
the record contains: trade secrets of the third party; financial, commercial, scientific  
or technical information which disclosure could likely cause harm to the financial or  
commercial interests of that third party; information disclosed in confidence by a  
third party to SmooLink Forwarding (Pty) Ltd, if the disclosure could put that third  
party at a disadvantage in negotiations or commercial competition;  
(d) Mandatory protection of confidential information of third parties (section 65) if it is  
protected in terms of any agreement;  
(e) Mandatory protection of the safety of individuals and the protection of property  
(section 66);  
SmooLink Forwarding (Pty) Ltd | Registration No: 2023/270638/07  
10240 Ext 7B, Bear Crescent Street, Orange Farm, 1841 Johannesburg, South Africa  
www.smoolink.co.za  
woza@smoolink.co.za  
+27 11 568 3734  
(f) Mandatory protection of records which would be regarded as privileged in legal  
proceedings (section 67).  
b. The commercial activities (section 68) of a private body, such as SmooLink Forwarding  
(Pty) Ltd, which may include: (a) trade secrets of SmooLink Forwarding (Pty) Ltd; (b)  
financial, commercial, scientific or technical information which disclosure could likely  
cause harm to the financial or commercial interests of SmooLink Forwarding (Pty) Ltd;  
(c) information which, if disclosed could put SmooLink Forwarding (Pty) Ltd at a  
disadvantage in negotiations or commercial competition; (d) a computer program which  
is owned by SmooLink Forwarding (Pty) Ltd, and which is protected by copyright.  
c. All requests for information will be assessed on their own merits and in accordance  
with the applicable legal principles and legislation. Requests for information that are  
clearly frivolous or vexatious, or which involve an unreasonable diversion of resources  
shall be refused.  
13. DECISION  
SmooLink Forwarding (Pty) Ltd will, within 30 (thirty) days of receipt of the request, decide  
whether to grant or decline the request and give notice with reasons (if required) to that  
effect. The 30 (thirty) day period within which SmooLink Forwarding (Pty) Ltd has to decide  
whether to grant or refuse the request, may be extended for a further period of not more  
than (30) thirty days if the request is for a large number of information and the information  
cannot reasonably be obtained within the original 30 (thirty) day period. SmooLink  
Forwarding (Pty) Ltd will notify the requester in writing should an extension be sought.  
If a requested record cannot be found or if the record does not exist, the Information Officer  
shall, by way of an affidavit or affirmation, notify the requester that it is not possible to give  
access to the requested record. Such a notice will be regarded as a decision to refuse a  
request for access to the record concerned for the purpose of the Act. If the record should  
later be found, the requester shall be given access to the record in the manner stipulated by  
the requester in the prescribed form, unless the Information Officer refuses access to such  
record.  
14. REMEDIES AVAILABLE TO A REQUESTER IF ACCESS IS REFUSED  
SmooLink Forwarding (Pty) Ltd | Registration No: 2023/270638/07  
10240 Ext 7B, Bear Crescent Street, Orange Farm, 1841 Johannesburg, South Africa  
www.smoolink.co.za  
woza@smoolink.co.za  
+27 11 568 3734  
SmooLink Forwarding (Pty) Ltd does not have internal appeal procedures. The decision  
made by the Information Officer is final. Requesters will have to exercise such external  
remedies at their disposal if the request for information is refused, and the requestor is not  
satisfied with the answer supplied by the Information Officer.  
A dissatisfied requestor or third-party may within 30 (thirty) days of notification of the  
decision, apply to a Court for relief. For purposes of the Act, the Courts that have  
jurisdiction over these applications are the Constitutional Court, the High Court or another  
court of similar status and a Magistrate's Court designated by the Minister of Justice and  
Constitutional Development and which is presided over by a designated Magistrate.  
15. POPIA GUIDE AND PROCESSING OF PERSONAL INFORMATION  
Chapter 3 of POPIA provides for the minimum protection principles for Lawful Processing of  
Personal Information by a Responsible Party. These conditions may not be derogated from  
unless specific exclusions apply as outlined in POPIA.  
SmooLink Forwarding (Pty) Ltd needs Personal Information relating to both individual and  
juristic persons in order to carry out its business and organizational functions. The manner  
in which this information is Processed and the purpose for which it is Processed is  
determined by SmooLink Forwarding (Pty) Ltd. SmooLink Forwarding (Pty) Ltd is  
accordingly a Responsible Party for the purposes of POPIA and will ensure that the  
Personal Information of a Data Subject:  
15.1 is processed lawfully, fairly and transparently. This includes the provision of  
appropriate information to Data Subjects when their data is collected by SmooLink  
Forwarding (Pty) Ltd, in the form of privacy or data collection notices. SmooLink  
Forwarding (Pty) Ltd must also have a legal basis (for example, consent) to process  
Personal Information;  
15.2 is processed only for the purposes for which it was collected, and will not be  
processed for a secondary purpose unless that processing is compatible with the  
original purpose.  
15.3 is adequate, relevant and not excessive for the purposes for which it was collected; is  
accurate; kept up to date, and will not be kept for longer than necessary;  
SmooLink Forwarding (Pty) Ltd | Registration No: 2023/270638/07  
10240 Ext 7B, Bear Crescent Street, Orange Farm, 1841 Johannesburg, South Africa  
www.smoolink.co.za  
woza@smoolink.co.za  
+27 11 568 3734  
15.4 is processed in accordance with integrity and confidentiality principles; this includes  
physical and organizational measures to ensure that Personal Information, in both  
physical and electronic form, are subject to an appropriate level of security when  
stored, used and communicated by SmooLink Forwarding (Pty) Ltd, in order to  
protect against access and acquisition by unauthorized persons and accidental loss,  
destruction or damage;  
15.5 is processed in accordance with the rights of Data Subjects, where applicable. Data  
Subjects have the right to:  
(a) be notified that their Personal Information is being collected by SmooLink  
Forwarding (Pty) Ltd and also be notified in the event of a data breach;  
(b) know whether SmooLink Forwarding (Pty) Ltd holds Personal Information about  
them, and to access that information. Any request for information must be  
handled in accordance with the provisions of this Manual;  
(c) request the correction or deletion of inaccurate, irrelevant, excessive, out of  
date, incomplete, misleading or unlawfully obtained personal information;  
(d) object to SmooLink Forwarding (Pty) Ltd’s use of their Personal Information and  
request the deletion of such Personal Information (deletion would be subject to  
SmooLink Forwarding (Pty) Ltd’s record keeping requirements);  
(e) object to the processing of Personal Information for purposes of direct  
marketing by means of unsolicited electronic communications; and  
(f) complain to the Information Regulator regarding an alleged infringement of any  
of the rights protected under POPI and to institute civil proceedings regarding the  
alleged non-compliance with the protection of his, her or its personal  
information.  
16. PURPOSE OF PROCESSING THE PERSONAL INFORMATION BY THE COMPANY  
Personal Information may only be processed for a specific purpose. The purposes for which  
SmooLink Forwarding (Pty) Ltd processes or will process Personal Information is set out in  
Part 1 of Appendix 2.  
SmooLink Forwarding (Pty) Ltd | Registration No: 2023/270638/07  
10240 Ext 7B, Bear Crescent Street, Orange Farm, 1841 Johannesburg, South Africa  
www.smoolink.co.za  
woza@smoolink.co.za  
+27 11 568 3734  
Part 2 of Appendix 2 sets out the various categories of Data Subjects that SmooLink  
Forwarding (Pty) Ltd Processes Personal Information on and the types of Personal  
Information relating thereto.  
Part 3 of Appendix 2 outlines the recipients to whom SmooLink Forwarding (Pty) Ltd may  
provide a Data Subjects Personal Information to.  
Part 4 of Appendix 2 sets out the planned cross-border transfers of Personal Information  
and the condition listed below that apply thereto. Cross-Border Flows of Personal  
Information  
Section 72 of POPIA provides that Personal Information may only be transferred out of the  
Republic of South Africa if the:  
(a) recipient country can offer such data an “adequate level” of protection. This means that  
its data privacy laws must be substantially similar to the Conditions for Lawful  
Processing as contained in POPI; or  
(b) Data Subject consents to the transfer of their Personal Information; or  
(c) transfer is necessary for the performance of a contractual obligation between the Data  
Subject and the Responsible Party; or  
(d) transfer is necessary for the performance of a contractual obligation between the  
Responsible Party and a third party, in the interests of the Data Subject; or  
(e) the transfer is for the benefit of the Data Subject, and it is not reasonably practicable to  
obtain the consent of the Data Subject, and if it were, the Data Subject, would in all  
likelihood provide such consent.  
Part 5 of Appendix 2 sets out the types of security measures to implemented by SmooLink  
Forwarding (Pty) Ltd in order to ensure that Personal Information is respected and protected.  
A preliminary assessment of the suitability of the information security measures implemented  
or to be implemented by SmooLink Forwarding (Pty) Ltd may be conducted in order to ensure  
that the Personal Information that is processed by SmooLink Forwarding (Pty) Ltd is  
safeguarded and processed in accordance with the Conditions for Lawful Processing.  
SmooLink Forwarding (Pty) Ltd | Registration No: 2023/270638/07  
10240 Ext 7B, Bear Crescent Street, Orange Farm, 1841 Johannesburg, South Africa  
www.smoolink.co.za  
woza@smoolink.co.za  
+27 11 568 3734  
17. OBJECTION TO PROCESSING OF PERSONAL INFORMATION BY DATA SUBJECT  
Section 11 (3) of POPI and regulation 2 of the POPIA Regulations provides that a Data Subject  
may, at any time object to the Processing of his/her/its Personal Information in the  
prescribed form attached to this manual as Appendix 3 subject to exceptions contained in  
POPIA.  
18. REQUEST FOR CORRECTION / DELETION OF PERSONAL INFORMATION  
Section 24 of POPI and regulation 3 of the POPI Regulations provides that a Data Subject  
may request for their Personal Information to be corrected/deleted in the prescribed form  
attached as Appendix 4 to this Manual  
19. COMPLAINTS IN TERMS OF POPIA  
A person may submit a complaint to the Regulator in the prescribed manner and form  
alleging interference with the protection of the personal information of a data subject. A  
responsible party or data subject may, in terms of section 63(3), further submit a complaint  
to the Regulator in the prescribed manner and form if he/she/it is aggrieved by the  
determination of an adjudicator.  
Contact details of the Information Regulator are as follows:  
Address: JD House, 27 Stiemens street, Braamfontein, Johannesburg, 2001  
Postage: P O Box 31533, Braamfontein, Johannesburg, 2017  
Email: complaints.IR@justice.gov.za  
Website: www.justice.gov.za  
SmooLink Forwarding (Pty) Ltd | Registration No: 2023/270638/07  
10240 Ext 7B, Bear Crescent Street, Orange Farm, 1841 Johannesburg, South Africa  
www.smoolink.co.za  
woza@smoolink.co.za  
+27 11 568 3734  
APPENDIX 1  
ACCESS REQUEST FORM  
The following proof must be submitted together with the completed and signed Access Request Request Form below to the  
Information Officer:  
1. Proof of payment of Fees (if applicable);  
2. Certified copy of the Requester's identity document;  
3. Supporting documentation (only if applicable).  
1. PARTICULARS OF PERSON REQUESTING ACCESS TO INFORMATION  
Information Officer:  
Identity number:  
Telephone number:  
Postal address:  
Email address:  
Cell phone no.  
Fax no.  
Postal code  
2. PARTICULARS OF A PERSON ON WHOSE BEHALF THE REQUEST IS MADE  
*This section must be completed ONLY if a request for information is made on behalf of another person  
Full names and surname/  
Legal entity name:  
Identity number/  
Registration.:  
3. PARTICULARS OF REQUESTED INFORMATION  
*Provide full particulars of the record to which access is requested. If the provided space is inadequate, please continue  
on a separate page and attach it to this form, The requester must sign all the additional pages.  
4. FORMAT IN WHICH INFORMATION IS REQUESTED  
*Indicate the format in which the information requested is required. Please note that the request for accessing the  
specified format may depend on the format in which the record is available and access in the requested format may be  
refused under certain circumstances.  
5. RIGHT TO BE EXERCISED OR PROTECTED  
*Indicate 1: which right is to be exercised or protected, and 2 : why the record requested is required for the exercise or  
protection of the aforementioned right:  
What right is to be  
protected  
Why the information is  
required  
6. NOTICE OF APPROVAL / REJECTION OF REQUEST  
Please note: You will be notified via email and/or post whether your request has been approved or denied. If you wish to  
be informed in another manner, please specify the manner and provide the necessary details:  
7. PAYMENT DETAILS (Only applicable to Other Requesters and not to Personal Requesters)  
The bank account details and total amount payable will be provided upon receipt of the duty completed and signed  
request for information form  
8. SIGNATURE  
Signed at:  
day of  
20  
Name of Person submitting the request  
Signature of person submitting the request  
SmooLink Forwarding (Pty) Ltd | Registration No: 2023/270638/07  
10240 Ext 7B, Bear Crescent Street, Orange Farm, 1841 Johannesburg, South Africa  
www.smoolink.co.za  
woza@smoolink.co.za  
+27 11 568 3734  
APPENDIX 2: PART 1  
POPIA GUIDE AND PROCESSING OF PERSONAL INFORMATION  
For consumers:  
1. Performing duties in terms of any agreement with consumers  
2. Make, or assist in making, credit decisions about consumers  
3. Operate and manage consumers’ accounts and manage any application, agreement or  
correspondence consumers may have with SmooLink Forwarding (Pty) Ltd  
4. Communicating with consumers by email, SMS, letter, telephone or in any other way about  
SmooLink Forwarding (Pty) Ltd’s services, unless consumers indicate otherwise  
5. To form a view of consumers as individuals and to identify, develop or improve services,  
that may be of interest to consumers  
6. Carrying out market research, business and statistical analysis  
7. Performing other administrative and operational purposes including the testing of systems  
8. Recovering any debt consumers may owe SmooLink Forwarding (Pty) Ltd  
9. Complying with SmooLink Forwarding (Pty) Ltd’s regulatory and other obligations  
10. Any other reasonable purpose relating to SmooLink Forwarding (Pty) Ltd business  
For prospective consumers:  
1. Verifying and updating information  
2. Pre-scoring  
3. Direct marketing  
4. Any other reasonable purpose relating to the processing of a prospect’s personal  
information reasonably related to SmooLink Forwarding (Pty) Ltd’s business.  
For employees:  
1. The same purposes as for consumers  
2. Verification of applicant employees’ information during recruitment process  
3. General matters relating to employees: Pension; Medical aid; Payroll; Disciplinary action,  
and Training  
4. Any other reasonably required purpose relating to the employment or possible employment  
relationship.  
SmooLink Forwarding (Pty) Ltd | Registration No: 2023/270638/07  
10240 Ext 7B, Bear Crescent Street, Orange Farm, 1841 Johannesburg, South Africa  
www.smoolink.co.za  
woza@smoolink.co.za  
+27 11 568 3734  
For vendors /suppliers /other businesses:  
1. Verifying information and performing checks;  
2. Purposes relating to the agreement or business relationship or possible agreement or  
business relationships between the parties;  
3. Payment of invoices;  
4. Complying with SmooLink Forwarding (Pty) Ltd’s regulatory and other obligations; and  
5. Any other reasonably required purpose relating to SmooLink Forwarding (Pty) Ltd’s  
business.  
APPENDIX 2: PART 2  
CATEGORIES OF DATA SUBJECTS AND CATEGORIES OF PERSONAL INFORMATION RELATING THERETO  
Employees  
1. Name and contact details  
2. Identity number and identity documents including passports  
3. Employment history and references  
4. Banking and financial details  
5. Details of payments to third parties (deductions from salary)  
6. Employment contracts  
7. Employment equity plans  
8. Medical aid records  
9. Pension Fund records  
10. Remuneration/salary records  
11. Performance appraisals  
12. Disciplinary records  
13. Leave records  
14. Training records  
Consumers and prospective consumers  
1. Postal and/or street address  
2. title and name  
3. contact numbers and/or e-mail address  
4. ethnic group  
5. employment history  
SmooLink Forwarding (Pty) Ltd | Registration No: 2023/270638/07  
10240 Ext 7B, Bear Crescent Street, Orange Farm, 1841 Johannesburg, South Africa  
www.smoolink.co.za  
woza@smoolink.co.za  
+27 11 568 3734  
6. age  
7. gender  
8. marital status  
9. nationality  
10. language  
11. financial information  
12. identity or passport number  
13. browsing habits and click patterns on SmooLink Forwarding (Pty) Ltd’s websites.  
Vendors /suppliers /other businesses:  
1. Name and contact details  
2. Identity and/or company information and directors’ information  
3. Banking and financial information  
4. Information about products or services  
5. Other information not specified, reasonably required to be processed for business  
operations  
APPENDIX 2: PART 3  
RECIPIENTS OF PERSONAL INFORMATION  
1. Any firm, organization or person that SmooLink Forwarding (Pty) Ltd uses to collect  
payments and recover debts or to provide a service on its behalf;  
2. Any firm, organization or person that/who provides SmooLink Forwarding (Pty) Ltd with  
products or services;  
3. Any payment system SmooLink Forwarding (Pty) Ltd uses;  
4. Regulatory and governmental authorities or ombudsmen, or other authorities, including tax  
authorities, where SmooLink Forwarding (Pty) Ltd has a duty to share information;  
5. Third parties to whom payments are made on behalf of employees;  
6. Financial institutions from whom payments are received on behalf of data subjects;  
7. Any other operator not specified;  
8. Employees, contractors, temporary staff, and Agents.  
SmooLink Forwarding (Pty) Ltd | Registration No: 2023/270638/07  
10240 Ext 7B, Bear Crescent Street, Orange Farm, 1841 Johannesburg, South Africa  
www.smoolink.co.za  
woza@smoolink.co.za  
+27 11 568 3734  
APPENDIX 2: PART 4  
CROSS-BORDER TRANSFERS OF PERSONAL INFORMATION  
Personal Information may be transmitted transborder to SmooLink Forwarding (Pty) Ltd’s  
suppliers in other countries, and Personal Information may be stored in data servers hosted  
outside South Africa, which may not have adequate data protection laws. SmooLink Forwarding  
(Pty) Ltd will endeavour to ensure that its suppliers and partners will make all reasonable  
efforts to secure said data and Personal Information.  
APPENDIX 2: PART 5  
DESCRIPTION OF INFORMATION SECURITY MEASURES  
SmooLink Forwarding (Pty) Ltd undertakes to institute and maintain the data protection  
measures to accomplish the following objectives outlined below. The details given are to be  
interpreted as examples of how to achieve an adequate data protection level for each objective.  
SmooLink Forwarding (Pty) Ltd may use alternative measures and adapt to technological  
security development, as needed, provided that the objectives are achieved.  
1. Access Control of Persons –  
SmooLink Forwarding (Pty) Ltd shall implement suitable measures in order to prevent  
unauthorized persons from gaining access to the data processing equipment where data is  
processed.  
2. Data Media Control -  
SmooLink Forwarding (Pty) Ltd undertakes to implement suitable measures to prevent the  
unauthorized manipulation of media, including reading, copying, alteration or removal of the  
data media used by SmooLink Forwarding (Pty) Ltd and containing personal data of  
Customers.  
3. Data Memory Control –  
SmooLink Forwarding (Pty) Ltd undertakes to implement suitable measures to prevent  
unauthorized input into data memory and the unauthorized reading, alteration or deletion of  
stored data.  
SmooLink Forwarding (Pty) Ltd | Registration No: 2023/270638/07  
10240 Ext 7B, Bear Crescent Street, Orange Farm, 1841 Johannesburg, South Africa  
www.smoolink.co.za  
woza@smoolink.co.za  
+27 11 568 3734  
4. User Control –  
SmooLink Forwarding (Pty) Ltd shall implement suitable measures to prevent its data  
processing systems from being used by unauthorized persons by means of data  
transmission equipment.  
5. Access Control to Data –  
SmooLink Forwarding (Pty) Ltd represents that the persons entitled to use SmooLink  
Forwarding (Pty) Ltd’s data processing system are only able to access the data within the  
scope and to the extent covered by their respective access permissions (authorization).  
6. Transmission Control –  
SmooLink Forwarding (Pty) Ltd shall be obliged to enable the verification and tracing of the  
locations / destinations to which the personal information is transferred by utilization of  
SmooLink Forwarding (Pty) Ltd’s data communication equipment / devices.  
7. Transport Control –  
SmooLink Forwarding (Pty) Ltd shall implement suitable measures to prevent Personal  
Information from being read, copied, altered or deleted by unauthorized persons during the  
transmission thereof or during the transport of the data media.  
8. Organization Control –  
SmooLink Forwarding (Pty) Ltd shall maintain its internal organization in a manner that  
meets the requirements of this Manual.  
SmooLink Forwarding (Pty) Ltd | Registration No: 2023/270638/07  
10240 Ext 7B, Bear Crescent Street, Orange Farm, 1841 Johannesburg, South Africa  
www.smoolink.co.za  
woza@smoolink.co.za  
+27 11 568 3734  
APPENDIX 3  
OBJECTION TO PROCESS PERSONAL INFORMATION FORM  
The following proof must be submitted together with the completed and signed Objection to Process Personal  
Information Form to the Information Officer:  
1. Certified copy of the Requester's identity document;  
2. Affidavit and supporting documentation (only if applicable).  
1. DETAILS OF DATA SUBJECT  
Name(s) and Surname / registered name of  
data subject:  
Unique Identifier / Identity Number  
Residential, postal, or business address:  
Contact number(s):  
Fax number / Email address:  
2. DETAILS OF RESPONSIBLE PARTY  
Name(s) and Surname / registered name of  
data subject:  
Residential, postal, or business address:  
Contact number(s):  
Fax number / Email address:  
3. PROVIDE DETAILED REASON FOR:  
THE OBJECTION TO PROCESS PERSONAL INFORMATION IN TERMS OF SECTION 11(1)(d) to (f) OF POPIA  
Signed at:  
on this  
day of  
20  
Signature of Data Subject / Designated Person  
SmooLink Forwarding (Pty) Ltd | Registration No: 2023/270638/07  
10240 Ext 7B, Bear Crescent Street, Orange Farm, 1841 Johannesburg, South Africa  
www.smoolink.co.za  
woza@smoolink.co.za  
+27 11 568 3734  
APPENDIX 4  
REQUEST FOR (A) CORRECTION OF PERSONAL INFORMATION OR (B) DESTRUCTION OR DELETION OF A  
RECORD OF PERSONAL INFORMATION FORM  
The following proof must be submitted together with the completed and signed Form to the Information Officer:  
1. Certified copy of the Requester's identity document;  
2. Affidavit and supporting documentation (only if applicable).  
Mark the applicable Request below with an "X"  
1. REQUEST FOR CORRECTION OR DELETION OF PERSONAL INFORMATION  
2. REQUEST FOR DESTRUCTION OR DELETION OF A RECORD OF PERSONAL INFORMATION  
1. DETAILS OF DATA SUBJECT  
Name(s) and Surname / registered name of  
data subject:  
Unique Identifier / Identity Number  
Residential, postal, or business address:  
Contact number(s):  
Fax number / Email address:  
2. DETAILS OF RESPONSIBLE PARTY  
Name(s) and Surname / registered name of  
data subject:  
Residential, postal, or business address:  
Contact number(s):  
Fax number / Email address:  
3. PROVIDE DETAILED REASON FOR:  
(A) - CORRECTION OR DELETION OF THE PERSONAL INFORMATION ABOUT THE DATA SUBJECT IN TERMS  
OF SECTION 24(1)(a) OF POPIA, THAT IS IN POSSESSION OR UNDER CONTROL OF THE RESPONSIBLE PARTY;  
OR  
(B) - DESTRUCTION OR DELETION OF A RECORD OF PERSONAL INFORMATION ABOUT THE DATA SUBJECT IN  
TERMS OF SECTION 24(1)(b) OF POPIA, WHICH THE RESPONSIBLE PARTY IS NO LONGER AUTHORIZED TO RETAIN  
Signed at:  
on this  
day of  
20  
Signature of Data Subject / Designated Person  
SmooLink Forwarding (Pty) Ltd | Registration No: 2023/270638/07  
10240 Ext 7B, Bear Crescent Street, Orange Farm, 1841 Johannesburg, South Africa