PAIA Manual | Big Five Group Africa

This is the manual of Big Five Foods (Pty) Ltd, trading as Big Five Group, under the Promotion of Access to Information Act 2 of 2000 (“PAIA”). It explains what records we hold, how to ask for access to them, and how we process personal information under the Protection of Personal Information Act 4 of 2013 (“POPIA”).

1. Introduction and purpose

PAIA gives effect to the constitutional right of access to information held by another person where that information is required for the exercise or protection of any rights. Section 51 of PAIA requires every private body to make available a manual that describes the records it holds and explains how to request access to them.

This manual:

describes the categories of records we hold and the subjects they cover;
sets out the procedure for requesting access to a record and the fees that may apply;
explains the grounds on which a request may be refused and the remedies available; and
describes how we process personal information, as required by section 51 read with POPIA.

2. Company details

Name: Big Five Foods (Pty) Ltd
Trading as: Big Five Group (bigfivegroup.africa)
Registration number: 2025/108507/07
VAT number: 4280321847
Address: 21A Old Howick Road, Pietermaritzburg, KwaZulu-Natal, South Africa
Email: craig@bigfivegroup.africa
Website: bigfivegroup.africa

3. Information Officer

Requests for access to records, and any questions about this manual or about how we process personal information, should be sent to our Information Officer:

Information Officer: Dr Craig Ross Muller
Email: craig@bigfivegroup.africa
Address: 21A Old Howick Road, Pietermaritzburg, KwaZulu-Natal, South Africa

4. The Information Regulator's Guide

In terms of section 10 of PAIA, the Information Regulator has updated and made available a Guide on how to use PAIA and POPIA (the “Guide”). The Guide contains the information a person needs to exercise any right under PAIA or POPIA, including how to request access to records and the remedies available. It is available in each of the official languages of South Africa.

The Guide can be obtained:

from the Information Regulator's website: inforegulator.org.za/paia;
from the Information Regulator, on request using Form 1 (available on the Regulator's PAIA forms page); or
on request from our Information Officer.

Information Regulator contact details

Physical address: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191
Telephone: 010 023 5200 · Toll free: 0800 017 160
General enquiries: enquiries@inforegulator.org.za
PAIA complaints: PAIAComplaints@inforegulator.org.za
POPIA complaints: POPIAComplaints@inforegulator.org.za
Website: inforegulator.org.za

5. Categories of records we hold

The categories below describe the kinds of records a company such as ours typically holds. Listing a category does not mean that access to records in it will be given: every request is considered under PAIA, including the grounds for refusal in section 11 of this manual.

Statutory and company records: incorporation documents, memorandum of incorporation, registers of directors and securities, resolutions and minutes, and records filed with the Companies and Intellectual Property Commission.
Financial and tax records: accounting records, annual financial statements, bank records, invoices, asset registers, and income tax and VAT records.
Human resources records: employment contracts, personnel files, remuneration and payroll records, leave records, and records kept under labour legislation.
Customer, partner and investor records: agreements, correspondence, enquiries, customer feedback, partnership and programme records, and investor relations records.
Supplier and service provider records: supplier agreements, orders, invoices and correspondence.
Marketing and communications records: newsletter subscriptions and consent records, published content, and press and media material.
Information technology records: website and system records, portal account and access records, and agreements with technology service providers.

6. Records available without a request

Content published on our website, bigfivegroup.africa, is available to anyone without a PAIA request. This includes our published pages, updates, press material, our Privacy Policy, Terms and this manual. We have not published a notice under section 52 of PAIA.

7. Records held in terms of legislation

We keep records as required by the legislation that applies to us. To the extent that they apply, this includes:

Basic Conditions of Employment Act 75 of 1997
Broad-Based Black Economic Empowerment Act 53 of 2003
Companies Act 71 of 2008
Compensation for Occupational Injuries and Diseases Act 130 of 1993
Consumer Protection Act 68 of 2008
Electronic Communications and Transactions Act 25 of 2002
Employment Equity Act 55 of 1998
Foodstuffs, Cosmetics and Disinfectants Act 54 of 1972
Income Tax Act 58 of 1962
Labour Relations Act 66 of 1995
Occupational Health and Safety Act 85 of 1993
Promotion of Access to Information Act 2 of 2000
Protection of Personal Information Act 4 of 2013
Skills Development Act 97 of 1998
Skills Development Levies Act 9 of 1999
Tax Administration Act 28 of 2011
Unemployment Insurance Act 63 of 2001
Unemployment Insurance Contributions Act 4 of 2002
Value-Added Tax Act 89 of 1991

This list is not exhaustive. Where a record is held in terms of legislation, access to it is still subject to PAIA.

8. Processing of personal information (POPIA)

More detail on how we handle personal information, including how long we keep it, is in our Privacy Policy.

8.1 Purposes of processing

to respond to enquiries and manage relationships with customers, partners, investors and donors;
to provide, operate and improve our products, programmes, website and portals;
to procure goods and services and manage suppliers;
to recruit, employ and manage staff and contractors;
to send newsletters and updates to people who have opted in;
to keep accounting, tax and company records; and
to comply with the law and to establish, exercise or defend legal claims.

8.2 Categories of data subjects and their personal information

Employees, job applicants and contractors: names, contact details, identity numbers, employment history, qualifications, remuneration, bank and tax details.
Customers, partners, investors and donors: names, contact details, organisation and role, correspondence, agreements, feedback and transaction records.
Suppliers and service providers: names of contact persons, contact details, company and VAT details, bank details and agreements.
Website visitors, enquirers and newsletter subscribers: names, contact details, enquiry content, subscription preferences, consent records and portal sign-in records.

8.3 Recipients of personal information

We may share personal information, where needed for the purposes above, with:

service providers (operators) that process information on our behalf, such as website hosting, email and analytics providers;
professional advisers, such as accountants, auditors and lawyers;
banks and payment processors;
the South African Revenue Service, regulators and other public bodies where the law requires it; and
other persons with your consent.

We do not sell personal information.

8.4 Cross-border transfers

Some of our service providers, such as cloud hosting and email providers, may store or process personal information on servers outside South Africa. Where personal information is transferred outside South Africa, we do so only as permitted by section 72 of POPIA.

8.5 Security measures

As required by section 19 of POPIA, we take appropriate, reasonable technical and organisational measures to protect personal information against loss, damage and unauthorised access or processing. These include limiting access to authorised persons, sign-in controls on our portals, and requiring service providers that process information for us to keep it confidential and secure.

9. How to request access

Complete Form 2(Request for Access to Record), prescribed by the PAIA Regulations and available on the Information Regulator's PAIA forms page.
Send the completed form to our Information Officer at craig@bigfivegroup.africa, or deliver it to 21A Old Howick Road, Pietermaritzburg, KwaZulu-Natal, South Africa.
Give enough detail to identify the record and yourself, state the form of access and language you prefer, and state how you would like to be told of our decision.
Identify the right you want to exercise or protect, and explain why the record is required for that purpose (section 53 read with section 50 of PAIA).
If you are making the request on behalf of someone else, provide proof of the capacity in which you are making it.

We will decide on a request within 30 days of receiving it. We may extend this period once, by up to a further 30 days, in the circumstances allowed by section 57 of PAIA, and will tell you if we do. If we do not respond within the required period, the request is regarded as refused.

If you want access to your own personal information, you may also make the request under section 23 of POPIA using the same procedure.

10. Fees

Fees are those prescribed by the PAIA Regulations (Annexure B) for private bodies. As published by the Information Regulator, the request fee payable by a requester is R140.00. A requester asking for their own personal information (a personal requester) does not pay the request fee.

If access is granted, an access fee may be payable for reproduction, for search and preparation time, and for postage or electronic transfer, at the rates prescribed in the Regulations. If searching for and preparing the record will take more than six hours, we may ask for a deposit of up to one third of the access fee before continuing. Access will be given once the fees have been paid. The full schedule is on the Information Regulator's PAIA fees page.

11. Grounds for refusal

We may, or must, refuse access to a record on the grounds set out in Chapter 4 of Part 3 of PAIA. These include:

protecting the privacy of a third party who is a natural person (section 63);
protecting the commercial information of a third party (section 64);
protecting confidential information of a third party (section 65);
protecting the safety of individuals and the protection of property (section 66);
records privileged from production in legal proceedings (section 67);
protecting our own commercial information, such as trade secrets and financial, commercial or technical information (section 68); and
protecting research information of a third party or of our own (section 69).

We will disclose a record despite these grounds where section 70 of PAIA requires it in the public interest. Where only part of a record may be refused, we will give access to the rest. If a record cannot be found or does not exist, we will tell you by affidavit or affirmation, as section 55 of PAIA requires.

12. Remedies

We do not have an internal appeal procedure. If you are not satisfied with our decision on a request (including a refusal, the fees charged, an extension of time, or the form of access), you may:

lodge a complaint with the Information Regulator using Form 5, for example by email to PAIAComplaints@inforegulator.org.za; or
apply to a court with appropriate jurisdiction for relief,

generally within 180 days of being notified of the decision, as provided in sections 77A to 78 of PAIA.

13. Availability of this manual

This manual is available:

on our website at bigfivegroup.africa/paia;
for inspection at 21A Old Howick Road, Pietermaritzburg, KwaZulu-Natal, South Africa, during normal business hours; and
on request from our Information Officer at craig@bigfivegroup.africa.

We will update this manual when our details or practices change. This version is dated 29 September 2026.