PAIA manual

Prepared under section 51 of the Promotion of Access to Information Act, 2000 · Last updated 3 November 2026 · Draft for legal review

1. Abbreviations

IO: Information Officer
PAIA: Promotion of Access to Information Act, 2000
POPIA: Protection of Personal Information Act, 2013
Regulator: the Information Regulator

2. Purpose of this manual

This manual tells you what records Clearlist Compliance (Pty) Ltd holds, how to ask for access to them, and how we process personal information.

3. Key contact details

Business	Clearlist Compliance (Pty) Ltd, registration number 2026/882062/07
Information Officer	Bilal Cassim, Director
Physical and postal address	91 Foyle Avenue, Crosby, Johannesburg, 2092
Email	hello@clearlist.co.za
Website	clearlist.co.za

4. Guide on how to use PAIA

The Regulator has published a guide explaining how to use PAIA and POPIA rights. It is available from the Regulator's website at inforegulator.org.za. You may also ask our Information Officer for a copy.

5. Records available without a request

Information on our website, including our prices, terms of service, privacy policy and this manual.

6. Records kept under other laws

Companies Act 71 of 2008: company registration documents, memorandum of incorporation, share and beneficial ownership registers.
Income Tax Act 58 of 1962 and Tax Administration Act 28 of 2011: tax records.
Consumer Protection Act 68 of 2008: records relating to the opt-out registry, where we act for clients.
Electronic Communications and Transactions Act 25 of 2002: records of electronic transactions.
Protection of Personal Information Act 4 of 2013: records of processing and data processing agreements.

7. Subjects and categories of records we hold

Subject	Categories of records
Company	Registration documents, director and shareholder records, resolutions
Finance	Invoices, payment records, bank statements, tax records
Clients	Agreements, data processing agreements, contact details, monthly cleansing reports and NCC receipts
Marketing	Lead contact details and consent records, unsubscribe records
Suppliers	Agreements and contact details of service providers

8. Processing of personal information

8.1 Purpose

To deliver opt-out registry compliance services to clients, communicate with leads and clients, invoice and get paid, and meet our legal obligations.

8.2 Data subjects and information

Leads and client contact people: name, business name, email, phone number, sector, consent records.
Individuals on clients' contact lists (processed as operator for clients): phone numbers, email addresses and similar contact details.
Suppliers: business and contact details.

8.3 Recipients

The National Consumer Commission (for opt-out registry cleansing on clients' instructions), our service providers (hosting, email, forms, payments), and authorities where the law requires.

8.4 Transborder flows

Some service providers may store information outside South Africa. We only use providers that give protection equivalent to POPIA.

8.5 Security measures

Two-step login on accounts, encrypted connections, access limited to people who need it, data processing agreements with clients and suppliers, and secure deletion of client contact lists after each cleansing.

9. How to request access

Email the Information Officer at hello@clearlist.co.za using the request form prescribed by the Regulator (Form 2), available on the Regulator's website. Fees, where they apply, are those prescribed under PAIA. We will respond within the time limits PAIA sets.

10. Availability and updates

This manual is available on our website and from the Information Officer on request, and to the Regulator on request. We update it whenever our information or processing changes.

Issued by: Bilal Cassim, Information Officer and Director