PAIA Information
Prepared in accordance with section 51 of the Promotion of Access to Information Act 2 of 2000, as amended.
Interim PAIA information: This page explains how to enquire about access to RefineX records. It is not the completed, approved private-body PAIA Manual. Company-specific particulars and record schedules are being confirmed.
1. Purpose of this manual
This manual explains how a person may request access to records of The Gold and Diamond Dealer (Pty) Ltd trading as RefineX (the “Company”). It is intended to identify the Company’s relevant contact point, categories of records, information available without a formal request, records maintained in terms of legislation, and the process for requesting access under PAIA.
The manual also addresses personal-information processing, relevant categories of data subjects and recipients, potential cross-border transfers and safeguarding arrangements under the Protection of Personal Information Act 4 of 2013 (POPIA).
PAIA provides access to records of a private body where the requirements of the Act are met, including the need for the record in the exercise or protection of a right, the procedural requirements and any applicable grounds of refusal. A description of a category of records does not mean that every record in the category exists or that access will automatically be granted.
2. Definitions and abbreviations
- Company: the legal private body identified in the final approved version of this manual.
- Data subject: a person to whom personal information relates.
- Information Officer (IO): the person who exercises the Information Officer duties for the private body under the applicable legislation.
- Deputy Information Officer (DIO): a person designated to assist the Information Officer, if applicable.
- PAIA: Promotion of Access to Information Act 2 of 2000, as amended.
- POPIA: Protection of Personal Information Act 4 of 2013.
- Regulator: the Information Regulator of South Africa.
- Record: recorded information held by or on behalf of a body, regardless of the form or medium, within the meaning of PAIA.
- Requester: a person who requests access to a record under PAIA.
3. Particulars of the private body and access contacts
Trading name: RefineX.
Legal entity: The Gold and Diamond Dealer (Pty) Ltd. Company registration number: 2026/263142/07.
Website: https://refinex.org/
General business and preliminary access enquiries: info@refinex.org
Public telephone shown on the website: 010 101 1024 — ownership and routing to be confirmed.
4. Guide on how to use PAIA
The Information Regulator has published a guide explaining how PAIA works, which bodies hold records, how requests are made and what legal remedies may be available. The guide and related information can be obtained from the Information Regulator, including https://inforegulator.org.za/paia/. The prescribed Form 2 — Request for Access to Record and Form 3 — Outcome of Request and Fees Payable are provided through the Regulator’s resources.
5. Records available without a formal PAIA request
The following information is currently available through the RefineX website without submitting Form 2:
| Category | Examples | How accessed |
|---|---|---|
| Public website information | Service descriptions, general enquiries, contact channels | Website https://refinex.org/ |
| Website policies | Privacy Policy, Website Terms, Cookie Policy, Disclaimer | Public legal centre at https://refinex.org/legal/ |
| Customer information | General customer-acceptance information | Website legal centre; a particular transaction agreement must be requested separately |
Additional records made automatically available under section 52 of PAIA, whether through the website, public inspection or another channel, must be confirmed and scheduled by the Company. Public website availability does not remove applicable restrictions on other records.
6. Records available under other legislation
Depending on the Company’s confirmed activities, employee arrangements and legal obligations, records may be held under legislation such as:
- the Companies Act 71 of 2008 for applicable corporate and statutory records;
- the Promotion of Access to Information Act 2 of 2000 for the PAIA manual and access records;
- the Protection of Personal Information Act 4 of 2013 for applicable processing and privacy records;
- legislation governing tax, employment, occupational health and safety, and financial or accounting records where relevant; and
- sector-specific legislation affecting regulated precious metals, second-hand goods, environmental management and related activities, only to the extent that each is relevant to the Company’s actual activities and authorisations.
7. Subjects and categories of records
The Company’s record inventory should describe the following subjects to the extent records are actually held:
| Subject | Illustrative categories to validate |
|---|---|
| Corporate governance | Registration documents, constitutional records, shareholder and management resolutions, statutory registers |
| Finance, accounting and taxation | Accounting books, financial statements, invoices, payment records, tax submissions and supporting schedules |
| Customers and business development | Enquiries, quotations, correspondence, signed agreements, customer account records |
| Material intake and transactions | Delivery records, provenance and authority documents, lot registers, weights, sampling/assay records, settlement and handover documents, if the processes are operated |
| Suppliers, carriers and partners | Supplier agreements, purchase orders, delivery and service-provider correspondence |
| Human resources | Employee records, contracts, payroll and policies, if the Company employs personnel |
| Operations and quality | Applicable operating procedures, technical records, asset and maintenance records, compliance documentation |
| Website, privacy and security | Website enquiry correspondence, policies, access-control records, incidents and system logs where retained |
Record access depends on the purpose of the request, the applicable law and any rights of customers, employees, suppliers and third parties. The completed record register must identify actual holdings, not simply reproduce this suggested list.
8. Processing of personal information
8.1 Purposes of processing
The Company’s website receives personal information needed to answer enquiries. Depending on a separately agreed commercial activity, the Company may process information to assess customers and material, correspond about quotations, manage transactions, keep records, address complaints, meet legal obligations and protect the operation of its services.
8.2 Categories of data subjects and information
| Category | Information potentially relevant |
|---|---|
| Website enquirers | Name, email, telephone, metal category, enquiry text, communication history |
| Customers and their representatives | Business and contact details, proof of authority, transaction and payment information as lawfully required |
| Suppliers and service-provider contacts | Contact and contract details, service records, billing information |
| Employees and candidates (if applicable) | Employment, payroll, identity, qualification and related records in line with law |
| Other third parties | Information provided in correspondence or records relevant to a lawful enquiry or transaction |
This schedule must be reconciled with actual systems and data collection practices. Sensitive data or identity documents should not be assumed to be collected through the general website form.
8.3 Recipients or categories of recipients
Recipients may include authorised Company personnel, the website and email host, relevant technical or security providers, professional advisers, transaction service providers and competent authorities where lawful. Actual recipient categories, operator relationships and information-sharing processes must be confirmed in the final manual.
8.4 Transborder processing
The location of the website, email, backup, cloud and messaging providers must be established. Where personal information is transferred or accessed outside South Africa, the Company will assess the relevant POPIA section 72 conditions and safeguards. The completed manual must describe actual transborder arrangements, rather than listing countries or recipients without evidence.
8.5 Security measures
Measures appropriate to the nature of information may include authorised-access controls, system maintenance, protected communications, secure handling of documents, incident procedures and service-provider protections. The final manual must describe controls that actually operate and are supported by evidence.
9. Making a request for access to a record
A person requesting access to records of a private body should:
- Identify the record sought as accurately as possible, including dates, account/transaction identifiers or other details that help locate it.
- Explain the right to be exercised or protected and why the record is required for that right, as relevant under PAIA section 50.
- Complete the prescribed Form 2 using the current form available from the Information Regulator.
- Address the form to the verified Information Officer / head of the private body through the contact details in the completed manual.
- Provide a suitable response address and any necessary evidence of authority if requesting on another person’s behalf.
A request may require verification of identity or authority, and the Company may ask for appropriate clarification necessary to locate the record or process the request. A person seeking access to their own personal information may also have relevant rights under POPIA.
10. Fees, decisions and processing period
A requester may be required to pay prescribed request, access, search, preparation or reproduction fees where applicable under the current PAIA regulations. Fees are statutory, not charges invented by RefineX. The Company will give the required notice of fees and of the decision on the request, including the prescribed Form 3 where applicable.
PAIA sets out time periods for responding to requests and limited circumstances in which extensions are permitted. The Company will apply the applicable statutory times and notify the requester where required. It will not promise a shorter or longer blanket processing period in place of the Act.
11. Grounds for refusing access
Access may be refused where a lawful PAIA ground applies, including circumstances involving protected personal information, third-party commercial information, confidentiality duties, privileged information, safety, certain research or other protections set out in the Act. The Company will assess the requested records and give reasons for refusal where legally required. A record is not automatically withheld simply because it is described as confidential in a commercial agreement, nor is every record available merely because a request is made.
12. Complaints and external remedies
A requester who disagrees with a decision, delay or failure to respond should consider the remedies provided under PAIA, including the right to complain to the Information Regulator and, in appropriate circumstances, seek relief from a court. The Regulator provides guidance and prescribed complaint forms at https://inforegulator.org.za/paia/. The statutory conditions and time limits for complaints apply.
13. Availability, languages and updates
The approved manual must be available through the channels and in the languages required by law, including the website and appropriate physical inspection arrangements. The Company will review the manual when its organisational particulars, record holdings, information practices, legislation or statutory obligations change.
14. Supporting forms and further information
Official PAIA request forms and guidance can be obtained from the Information Regulator. For enquiries about the company-specific manual or access to records, contact info@refinex.org.