PAIA Manual

Prepared in terms of section 51 of the Promotion of Access to Information Act 4 of 2013 (PAIA) and the Protection of Personal Information Act 4 of 2013 (POPIA). Date of compilation: 17 September 2026. Date of last revision: 17 September 2026.

1. Acronyms used in this manual

  • PAIA – Promotion of Access to Information Act 4 of 2013 (as amended)
  • POPIA – Protection of Personal Information Act 4 of 2013
  • Regulator – Information Regulator of South Africa
  • IO – Information Officer
  • “we”, “us”, “HospiTrain” – FranchiseTraining.co.za (Pty) Ltd t/a HospiTrain

2. Purpose of this manual

This manual tells you what records HospiTrain holds, how to ask for access to them, and how we process personal information. You can use it to find out which categories of records are available without a formal request, how to submit a request, what it may cost, and on what grounds a request may be refused.

3. Our contact details

  • Name of private body: FranchiseTraining.co.za (Pty) Ltd t/a HospiTrain
  • Registration number: 2026/042141/07
  • Head of body and Information Officer: Robin Jansen van Rensburg
  • Deputy Information Officer: none appointed at present
  • Physical and postal address: 655 Marine Drive, Brighton Beach, Durban 4052, South Africa
  • Telephone: +27 82 451 1604
  • Email: admin@hospitrain.com
  • Website: https://hospitrain.com

4. The Regulator’s Guide on how to use PAIA

The Regulator has published a Guide, in each official language, explaining how to use PAIA and POPIA to exercise your rights. It covers, among other things, the purpose of PAIA and POPIA, how to request a record, the help available from Information Officers and the Regulator, the fees payable, and the remedies available if a request is refused.

You can inspect or download the Guide on the Regulator’s website (www.inforegulator.org.za), or ask us for a copy by emailing admin@hospitrain.com. A copy is also available for inspection at our address above during normal business hours.

5. Records available without a formal request

The following records are freely available on our website and do not need a PAIA request:

  • Course catalogue, course descriptions and prices
  • Terms and Conditions, Refund Policy and Cancellation Policy
  • Privacy Policy
  • This PAIA Manual

6. Records kept in terms of other legislation

Where applicable to our business, we keep records in accordance with the following laws. The list is not exhaustive:

  • Companies Act 69 of 2004
  • Income Tax Act 58 of 1962
  • Value-Added Tax Act 89 of 1991 (HospiTrain is not currently VAT-registered)
  • Electronic Communications and Transactions Act 25 of 2002
  • Consumer Protection Act 68 of 2008
  • Protection of Personal Information Act 4 of 2013
  • Promotion of Access to Information Act 4 of 2013
  • Financial Intelligence Centre Act 38 of 2001 (where applicable)

7. Subjects and categories of records we hold

  • Company and statutory records: registration documents, directors’ records, share register, minutes and resolutions
  • Financial and tax records: accounting records, bank statements, invoices, payment records and tax returns
  • Customer and learner records: orders, billing details, learner names and email addresses, team (delegate) registrations, course enrolments, progress, assessment results and Certificates of Attendance
  • Supplier and service-provider records: agreements and correspondence with service providers
  • Marketing and communication records: contact form enquiries, marketing consents and correspondence
  • Information technology records: website data, security logs and system configuration
  • Course content: course materials, assessments and related intellectual property

8. Processing of personal information

8.1 Purpose of processing. We process personal information to take and process orders, create learning portal accounts, send login details, give course access, issue Certificates of Attendance, answer enquiries, send service emails, send marketing where POPIA allows it, keep financial and tax records, and improve our website.

8.2 Categories of data subjects and their personal information.

  • Customers (buyers): name, email address, phone number, billing address, order and payment records (we do not see or store card details)
  • Learners and team members: name, email address, portal username, course enrolments, progress, quiz and assessment results, certificates
  • Website visitors and enquirers: details submitted through our contact form, IP address, browser information and pages visited, cookies
  • Service providers: names, contact details, banking and contract details

8.3 Recipients of personal information. Payfast (payment processing); TalentLMS / Epignosis (learning portal hosting); our website host and email providers; Google (website statistics); an employer who registered a learner (that learner’s enrolment and progress); our accountants and auditors; and public authorities where the law requires it.

8.4 Planned transborder flows. Some service providers, including TalentLMS and Google, store information on servers outside South Africa. We only use providers that protect personal information to a standard comparable to POPIA, as section 72 of POPIA requires.

8.5 Security measures. Secure (HTTPS) connections, a website firewall, access controls and strong passwords on administrative accounts, limited staff access, and reputable service providers. We notify affected data subjects and the Regulator of any security compromise as section 22 of POPIA requires.

9. How to request access to a record

Requests must be made on the prescribed Form 2 (Request for Access to Record), available on the Regulator’s website or from us on request. Send the completed form to the Information Officer at admin@hospitrain.com or to our physical address.

  • Provide enough detail to identify the record(s) you want, and your identity (a copy of your ID).
  • State the form of access you want (for example a printed or electronic copy).
  • If you are requesting on behalf of someone else, provide proof of the capacity in which you act.
  • If you need the record to exercise or protect a right, state which right and why the record is needed.

We will decide on your request within 30 days of receiving it, and may extend this once by up to a further 30 days where PAIA allows, in which case we will tell you in writing. If you cannot read or write, or have a disability, the Information Officer will help you make the request orally and will complete the form for you.

You do not need to use PAIA to ask for your own personal information: under POPIA you may simply ask us, free of charge, by emailing admin@hospitrain.com.

10. Fees

Fees are those prescribed in the PAIA Regulations (Annexure B, for private bodies) and are subject to change by the Regulator. They currently include:

  • A request fee of R140, payable before the request is processed (not payable by a requester seeking their own personal information)
  • Access fees for reproduction, for example R2 per printed A4 page, or the cost of a USB drive or other medium
  • Search and preparation at R145 per hour, excluding the first hour, up to a maximum of R435
  • A deposit of one third of the access fee where search and preparation will take more than six hours
  • Postage, where applicable, at actual cost

We will tell you in writing of any fee payable before we process the request. You may apply to the Regulator or a court if you believe a fee is incorrect.

11. Grounds for refusal

We may refuse access to a record on the grounds set out in Chapter 4 of Part 3 of PAIA, including where access would involve the unreasonable disclosure of personal information about a third party; would disclose confidential commercial information of HospiTrain or a third party; would breach a duty of confidence; could endanger the life or safety of an individual; would disclose records privileged from production in legal proceedings; or would disclose research information. We may also refuse a request that is manifestly frivolous or vexatious. If we refuse, we will give reasons in writing.

12. Remedies

We have no internal appeal procedure. If you are not satisfied with our decision on your request, you may lodge a complaint with the Information Regulator, or apply to a court, within 180 days of being notified of the decision.

Information Regulator of South Africa
Website: www.inforegulator.org.za
General enquiries: enquiries@inforegulator.org.za
PAIA complaints: PAIAComplaints@inforegulator.org.za

13. Availability and updating of this manual

This manual is available on our website, at our address above for inspection during business hours, and to the Regulator on request. A copy can be emailed to you free of charge. We will review and update this manual regularly, and whenever our records or processing change materially.

Issued by: Robin Jansen van Rensburg, Information Officer and Director, FranchiseTraining.co.za (Pty) Ltd t/a HospiTrain