Introduction
This manual is published by Chovia Accounting (Pty) Ltd under section 51 of the Promotion of Access to Information Act, 2 of 2000 ("PAIA"). It explains what records we hold and how you can ask for access to them.
PAIA gives effect to the constitutional right of access to information held by private bodies where that information is required to exercise or protect a right. It does not give an automatic right to every record, and access may be refused on the grounds set out in PAIA.
Company details and contact person
| Name of private body | Chovia Accounting (Pty) Ltd |
|---|---|
| Registration number | 2025/861103/07 |
| Head of the private body and Information Officer | Takudzwa Ashwell Muraicho, Director |
| Street address | D94 Arnold Street, Villa Arnoldo, Strand, Cape Town, 7140 |
| Postal address | D94 Arnold Street, Villa Arnoldo, Strand, Cape Town, 7140 |
| Telephone | 061 510 2140 |
| tmuraicho@choviaaccounting.com | |
| Website | choviaaccounting.com |
Our Information Officer is registered with the Information Regulator.
The Information Regulator's guide
The Information Regulator has published a guide, in each official language, explaining how to use PAIA and POPIA and how to exercise the rights they give you, as section 10 of PAIA requires. You can get the guide from the Information Regulator's website, or ask us for a copy.
Information Regulator (South Africa)
Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191
PO Box 31533, Braamfontein, Johannesburg, 2017
Website: inforegulator.org.za
Records available without a request
The following records are available without a formal PAIA request:
- This PAIA manual
- Our privacy notice
- Information published on our website
Records kept by CIPC that are open to the public, such as our company registration details, can be obtained from CIPC.
Records kept under other laws
We keep records as required by, among others, the following laws. Where a law gives a person access to a record, that access will be provided as the law sets out.
- Companies Act, 71 of 2008
- Tax Administration Act, 28 of 2011
- Income Tax Act, 58 of 1962
- Value-Added Tax Act, 89 of 1991
- Basic Conditions of Employment Act, 75 of 1997
- Labour Relations Act, 66 of 1995
- Employment Equity Act, 55 of 1998
- Unemployment Insurance Act, 63 of 2001, and Unemployment Insurance Contributions Act, 4 of 2002
- Skills Development Levies Act, 9 of 1999
- Compensation for Occupational Injuries and Diseases Act, 130 of 1993
- Consumer Protection Act, 68 of 2008
- Occupational Health and Safety Act, 85 of 1993
- Protection of Personal Information Act, 4 of 2013
- Promotion of Access to Information Act, 2 of 2000
Subjects and categories of records we hold
| Subject | Categories of records |
|---|---|
| Company records | Memorandum of Incorporation, CIPC registration documents, securities register, beneficial ownership register, directors' resolutions |
| Financial and tax records | Accounting records, bank statements, invoices, annual financial statements, tax returns and SARS correspondence |
| Client records | Engagement letters and proposals, client contact and identity details, client accounting, tax, payroll and CIPC records and working papers, correspondence |
| Supplier records | Supplier details, contracts and invoices, including software providers |
| Employee and contractor records (where applicable) | Contracts, payroll and tax records, leave records |
| Website and enquiries | Contact form submissions and enquiry correspondence |
| Compliance records | Information Regulator registration, PAIA and POPIA records |
Client records are confidential. Access to them by anyone other than the client will generally be refused under the grounds in section 12 of this manual, unless the client consents or the law requires disclosure.
Processing of personal information
Purpose of processing
To provide accounting, tax, payroll, CIPC compliance and reporting services to clients; to comply with our legal obligations; to respond to enquiries; and to manage our practice.
Categories of data subjects and their information
| Data subjects | Personal information processed |
|---|---|
| Clients and their owners, directors, members, shareholders and beneficial owners | Names, ID or passport numbers, contact details, addresses, tax reference numbers, financial and banking information, CIPC information |
| Employees of clients (for payroll services) | Names, ID numbers, tax numbers, bank details, remuneration, leave and deductions |
| People who contact us | Names, contact details and the content of their messages |
| Suppliers and service providers | Contact details, banking details, contracts and invoices |
| Our employees and contractors (where applicable) | Identity, contact, tax, banking and employment information |
Recipients of personal information
SARS, CIPC, the Department of Employment and Labour, banks and lenders (on a client's instruction), professional advisers, and the software providers we use to deliver our services: Xero, Dext, Hubdoc, SimplePay and Google (email and Google Drive).
Planned transfers outside South Africa
Some of the cloud services above store information on servers outside South Africa. We use them only where the information is protected to a standard substantially similar to POPIA, as section 72 of POPIA requires.
Security measures
Reputable cloud systems with encryption and two-factor sign-in, access limited to those who need it, passwords and access keys stored separately from client files, and confidentiality duties on everyone who handles client information. Security compromises are reported to the Information Regulator and affected people, as section 22 of POPIA requires.
How to request access to a record
- Complete the prescribed Form 2 (Request for Access to Record) under the PAIA Regulations, 2021. You can get it from the Information Regulator's website or from us. Answer every question; write "N/A" where a question does not apply and "Nil" where there is nothing to disclose.
- Attach a copy of your identity document so that we can confirm who you are.
- Give enough detail for us to identify the record, and say how you want access (for example a copy or an inspection) and how you want to be told of our decision.
- Explain which right you are trying to exercise or protect, and why the record is needed for that.
- If you are asking on someone else's behalf, include proof of the capacity in which you are making the request.
- Send the form, with proof of payment of the request fee where it applies, to our Information Officer by email to tmuraicho@choviaaccounting.com or by post to the address above.
If you cannot complete the form because of illiteracy or a disability, you may make the request orally. Our Information Officer will complete the form for you and give you a copy.
Fees
PAIA allows a private body to charge two kinds of fees, at the tariffs set in the PAIA Regulations. We will tell you the amounts before we process your request.
Request fee
A request fee is payable when the request is made, and must be paid before we process it. It does not apply if you are asking for your own personal information.
Access fee and deposit
- If access is granted, an access fee is payable for searching for, preparing and reproducing the record, and for postage where a copy is posted to you.
- If the search and preparation will take more than six hours, we may ask for a deposit of one third of the expected access fee before we continue.
- If access is later refused, the deposit will be refunded.
- The record will be released once the access fee has been paid.
How to pay
Fees are paid by electronic transfer. Our Information Officer will give you the banking details, and proof of payment must be sent with the request or before access is given.
You may lodge a complaint with the Information Regulator, or apply to a court, about the payment of the request fee or the deposit.
Our decision on your request
- We will decide on your request within 30 days of receiving it, and tell you the decision in writing, with reasons if access is refused.
- We may extend this period once, by up to 30 more days, if the request is for a large number of records, requires a search of records held elsewhere, or needs consultation that cannot reasonably be completed in 30 days. We will tell you in writing before the original period ends, with the reasons for the extension.
- You may lodge a complaint with the Information Regulator, or apply to a court, about the extension.
- If we do not respond within the required time, the request is regarded as refused.
Requests involving third parties
Many of our records relate to our clients and their employees. If a request is for a record that contains a third party's personal information, commercial or financial information, or information given to us in confidence:
- We will take all reasonable steps to tell the third party about the request as soon as possible, and within 21 days of receiving it.
- Within 21 days of being told, the third party may explain in writing or orally why access should be refused, or give written consent to the disclosure.
- We will tell both the requester and the third party of our decision. If access is granted, the third party may lodge a complaint with the Information Regulator or apply to a court within 30 days, and access will only be given after that period has passed without a complaint or application.
Grounds for refusing access
We may, and in some cases must, refuse access to a record on the grounds set out in Chapter 4 of Part 3 of PAIA (sections 62 to 70). These include protecting:
- the privacy of third parties who are natural persons
- commercial information of a third party, including our clients' financial and tax information
- confidential information of third parties
- the safety of individuals and property
- records privileged from production in legal proceedings
- our own commercial information, and research information
If we refuse a request, we will give reasons.
Remedies
If you are unhappy with our decision on your request, or you are a third party unhappy with a decision to grant access, you may, within 180 days of being told of the decision (or within 30 days, for a third party, as set out in section 11):
- lodge a complaint in writing with the Information Regulator, which may investigate and issue an enforcement notice, or
- apply to a court, including a Magistrate's Court, for appropriate relief.
Availability and updates
This manual is available on our website and at our address above, free of charge. A copy will be given to the Information Regulator on request. We review and update this manual when our details or the records we hold change.