JSHW PAIA Manual
Manual for JALTTMM (PTY) LTD, trading as JSHW, under section 51 of the Promotion of Access to Information Act, 2000 (PAIA), as amended by POPIA. Version 1, published 15 October 2026.
1. About this manual
This manual explains how to ask JALTTMM (PTY) LTD, trading as JSHW ("JSHW", "we"), for access to records we hold, and how we process personal information. Section 51 of PAIA requires every private body to compile and publish one.
It covers JSHW's business as an IT, digital-transformation and leadership-advisory consultancy based in George, Western Cape, including the websites jshwsolutions.com, jshwsolutions.net and jshw.xyz.
Use it to find out:
- which records we hold and which are available without a formal request;
- how to make a request, which forms to use and what it costs;
- who to contact, and what you can do if a request is refused;
- why we process personal information, about whom, who receives it, where it goes and how we protect it.
2. Contact details
Send every request under this manual to the Information Officer.
| Detail | Value |
|---|---|
| Registered name | JALTTMM (PTY) LTD, trading as JSHW |
| Registration number | 2013/210013/07 |
| Head of the private body | Jonathan De Graaff, Managing Director |
| Information Officer | Jonathan De Graaff, registered with the Information Regulator on 15 October 2026 |
| Deputy Information Officer | None appointed |
| Email for requests | privacy@jshwsolutions.com |
| Telephone | +27682920966 |
| Physical address | Office Suite 4-E1 York Street Blvd Shopping Centre, George, Western Cape, 6529 |
| Postal address | Office Suite 4-E1 York Street Blvd Shopping Centre, George, Western Cape, 6529 |
| Websites | jshwsolutions.com · jshwsolutions.net · jshw.xyz |
3. The Information Regulator's PAIA guide
The Information Regulator publishes a guide (section 10 of PAIA) on how to use PAIA and POPIA to get information. It is available in every official language and in braille.
You can get it:
- from the Information Regulator's website, inforegulator.org.za;
- from our Information Officer, by email, at no charge;
- for inspection at our office during business hours, in English.
4. Records available without a request
JSHW has not published a notice under section 52(2) of PAIA. The following are freely available, with no request or fee:
- this manual and our privacy policies, on our websites;
- information about our services, published articles and insights, on our websites and LinkedIn page.
Records kept under other laws
We keep records required by the laws below. Where a law gives you a right to see a record, that right applies alongside PAIA.
| Law | Records it relates to |
|---|---|
| Companies Act 71 of 2008 | Memorandum of Incorporation, director and share records, financial statements |
| Income Tax Act 58 of 1962 and Tax Administration Act 28 of 2011 | Tax returns, assessments, accounting records, payments to contractors |
| Protection of Personal Information Act 4 of 2013 | Information Officer registration, operator agreements, processing records |
| Promotion of Access to Information Act 2 of 2000 | This manual, access requests and their outcomes |
| Electronic Communications and Transactions Act 25 of 2002 | Website disclosures, electronic agreements and signatures |
| Consumer Protection Act 68 of 2008 | Client agreements and quotations, where the Act applies |
5. Records we hold
These are the subjects on which JSHW holds records. Listing a category does not mean access will be granted: each request is judged against the grounds for refusal in PAIA (section 7).
| Subject | Categories of records |
|---|---|
| Company and governance | Incorporation documents, director and share records, resolutions, CIPC filings |
| Finance and tax | Accounting records, invoices, bank records, tax returns, SARS correspondence |
| Clients | Proposals and quotations, agreements, project files and deliverables, consultation and onboarding forms, correspondence |
| Enquiries | Website enquiries, consultation requests, training-needs assessments, related emails |
| Freelance partners and suppliers | Agreements, operator agreements, invoices, correspondence |
| Training and coaching | Bookings, attendance, session notes, course materials |
| Marketing and website | Website content, analytics reports, consent records, published articles |
| Information technology | System and access records, security and website logs, backups |
| Legal and compliance | Policies, this manual, PAIA and POPIA requests and outcomes, Information Officer registration |
6. How we process personal information
This section gives the information POPIA adds to a PAIA manual (section 51(1)(c)). Our privacy policies give the detail for each website.
Purposes
- Replying to enquiries, consultation requests and training-needs assessments.
- Proposing, delivering and invoicing consulting, coaching and training services.
- Managing freelance partners and suppliers.
- Meeting legal, tax and accounting obligations.
- Understanding how our websites are used and marketing our services, including marketing emails only to people who opt in (POPIA section 69).
- Keeping our systems and websites secure.
Data subjects and their information
| Data subjects | Personal information |
|---|---|
| Website visitors and enquirers | Name, email address, message, consent records (including optional consent to marketing emails); with analytics consent, device, browser, pages viewed and approximate location |
| Clients and their staff | Names, roles, contact details, business information shared during engagements, invoicing details |
| Coaching and training participants | Names, contact details, attendance, session notes |
| Freelance partners and suppliers | Names, contact details, banking and tax details, agreements |
| Directors | Identity and contact details held for company records |
Recipients
| Recipient | Why they receive it |
|---|---|
| Google (Workspace and Analytics) | Operator: email, document and spreadsheet storage; website analytics. Google Signals (advertising features) only for visitors who give marketing consent |
| Domains.co.za | Operator: hosts our websites and form handler, keeps server logs |
| MailChannels | Our hosting provider's outgoing mail relay for form notifications |
| Freelance partners, including Garden Route Innovation & Technology Hub NPC | Operators on client work, under written operator agreements |
| Accountants and auditors | Bookkeeping, tax and statutory compliance |
| SARS, CIPC, the Information Regulator and other authorities | Only where the law requires it |
Information sent outside South Africa
Google stores Workspace and Analytics data in its data centres in the Americas, Europe and Asia; it has none in Africa. We rely on section 72(1)(a) of POPIA: Google is bound by its Cloud Data Processing Addendum, which JSHW has accepted. Form notifications also pass through MailChannels outside South Africa: MailChannels is headquartered in Canada and its data centres are in the United States. That transfer is needed to deliver your enquiry to us (section 72(1)(c)).
Security measures
- Access to records is limited to the people who need it, with strong passwords and two-step verification on accounts.
- Websites are served over HTTPS; capture spreadsheets are private.
- Operators are bound by written agreements that require appropriate security safeguards (POPIA sections 19 and 21).
- Internal controls and policies govern how records are handled, backed up and destroyed.
- Security compromises are reported to the Information Regulator and affected people as POPIA section 22 requires.
How long we keep it
- Records of active clients: 62 months from the end of the engagement.
- All other personal information, including enquiries that do not become client work: 14 months.
- Records a law requires us to keep longer (for example tax and company records) are kept for the period that law sets.
Web server logs are kept for 7 to 14 days, set by our hosting provider, Domains.co.za. At the end of each period we delete or destroy the record, or de-identify it.
7. How to request access
We answer a request within 30 days. Requests go to the Information Officer by email, post or hand delivery, using the prescribed forms below.
Forms
| Form | Use it to | Who completes it |
|---|---|---|
| PAIA Form 2: Request for access to record | Ask for any record JSHW holds | You |
| PAIA Form 3: Outcome of request and of fees payable | Tell you the decision and any fees due | JSHW |
| PAIA Form 5: Complaint | Complain to the Information Regulator about a decision | You |
| POPIA Form 1: Objection to processing | Object to JSHW processing your personal information | You |
| POPIA Form 2: Request for correction or deletion | Ask us to correct, delete or destroy your personal information | You |
All forms are on the Information Regulator's website and we will email them on request. To simply ask whether we hold information about you, a plain email is enough and costs nothing (POPIA section 23(1)(a)).
Steps
- Complete Form 2. Identify the record, the form of access you want, and how we should contact you. If you are not asking for your own information, state the right you want to exercise or protect and why the record is needed for it.
- Include proof of identity, and proof of authority if you act for someone else.
- Pay the request fee (section 8), unless the request is for your own personal information.
- If the request affects a third party, we notify them within 21 days and they have 21 days to respond.
- We send our decision on Form 3 within 30 days. We may extend this once, by up to 30 days, and will tell you why.
- If access is granted, pay any access fee; records are released once payment is received.
No reply within 30 days counts as a refusal. We may refuse only on the grounds in PAIA Part 3, Chapter 4: for example, to protect a third party's privacy or confidential commercial information, legal privilege, or someone's safety.
If you disagree with a decision
Private bodies have no internal appeal. Within 180 days of the decision you may complain to the Information Regulator (Form 5) or apply to court.
8. Fees
The request fee is R140. These are the fees the PAIA Regulations prescribe for private bodies, as published by the Information Regulator. JSHW is not VAT-registered, so no VAT is added.
| Item | Fee (R) |
|---|---|
| Request fee, payable by every requester except one asking for their own personal information | 140.00 |
| Photocopy or printed black-and-white copy, per A4 page or part page | 2.00 |
| Computer-readable copy on a flash drive or CD you supply | 40.00 |
| Computer-readable copy on a CD we supply | 60.00 |
| Transcription of an audio record, per A4 page | 24.00 |
| Copy of an audio record on a flash drive or CD you supply | 40.00 |
| Copy of an audio record on a CD we supply | 60.00 |
| Transcription or copy of visual images | Service provider's quotation |
| Search and preparation, per hour or part hour after the first hour | 145.00 |
| Search and preparation, maximum | 435.00 |
| Postage, email or other electronic transfer | Actual cost |
If search and preparation will take more than six hours, we ask for a deposit of one third of the access fee before we start. If access is refused, the deposit is refunded.
9. Availability and updates
This manual is available:
- on jshwsolutions.com and jshwsolutions.net;
- at our office in George for inspection during business hours;
- to anyone on request, by email at no charge, or as a printed copy at R2.00 per page;
- to the Information Regulator on request.
We review it at least once a year and whenever our records, recipients or systems change, for example when new marketing tools or an online booking tool go live.
Issued by the Information Officer, JALTTMM (PTY) LTD t/a JSHW. Version 1, published 15 October 2026.
Sources
Checked 15 October 2026.