1. Introduction

The Promotion of Access to Information Act, 2000 (“PAIA”) gives effect to the constitutional right of access to information held by another party that is required for the exercise or protection of any rights. Handmade Media (Pty) Ltd (Registration Number: 2016/505241/07) is committed to the principles of transparency, accountability, and the protection of personal information as mandated by both PAIA and the Protection of Personal Information Act, 2013 (“POPIA”).

 

This Manual is published in terms of Section 51 of PAIA and addresses the requirements of POPIA. Its primary purpose is to provide a clear and accessible framework for the public, our clients, our employees, and other stakeholders to understand the nature of the records held by Handmade Media (Pty) Ltd and the procedures for requesting access to such records.

By maintaining this Manual, Handmade Media (Pty) Ltd ensures that it remains compliant with South African legislation regarding the processing of data, the rights of data subjects, and the formal channels through which information may be lawfully requested. We recognize that our business involves the management of client brand assets, marketing performance insights, and stakeholder databases; therefore, we treat all information—whether belonging to our agency or our clients—with the highest standard of integrity and security.

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Scope of the Manual

This Manual applies to all records held by Handmade Media (Pty) Ltd and serves as a guide for any person or entity seeking access to information in accordance with the provisions of the law. It clarifies our organizational commitment to the “Act with Integrity” behavior by outlining our internal governance regarding data collection, usage, and access.

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2. Company Contact Details and Information Officer

In accordance with the provisions of the Promotion of Access to Information Act (PAIA) and the Protection of Personal Information Act (POPIA), Handmade Media (Pty) Ltd has formally designated an Information Officer to facilitate compliance and oversee requests for access to records.

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• Company Name: Handmade Media (Pty) Ltd

• Registration Number: 2016/505241/07

• Physical Address: Unit 6 - 202, Monument Office Park, 71 Steenbok Ave, Monument Park, Pretoria, Gauteng, 0181, South Africa

• Website: www.handmademedia.co.za

• Information Officer: Nanette Dreyer

• IO Email Address: nanette@handmademedia.co.za

• IO Phone Number: 083 226 6386

 

All requests for access to information held by the company should be directed to the Information Officer via the email address provided above. Please ensure that all formal correspondence includes the subject line “PAIA Request” to ensure timely processing and attention.

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3. The SAHRC Guide on How to Use PAIA

In terms of Section 10 of the Promotion of Access to Information Act (PAIA), the South African Human Rights Commission (SAHRC) is required to compile and maintain a guide that provides assistance to any person who wishes to exercise any right contemplated in PAIA.

The guide is available in all official languages and contains the necessary information for a person to understand their rights and the procedures to follow when requesting information from a public or private body. It includes information on how to:

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• Understand the objects of PAIA and the scope of its application.

• Identify the Information Officer of a public or private body.

• Obtain access to the records of a body.

• Seek legal assistance and remedies where access is refused.

• Lodge a complaint with the Information Regulator.

 

Accessing the Guide

Any person may inspect or request a copy of the guide during normal business hours from the offices of the SAHRC or from the Information Regulator. The guide is also available on the official websites of the SAHRC and the Information Regulator.

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• Website: https://inforegulator.org.za/

• Complaints Email: PAIAComplaints@inforegulator.org.za

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4. Processing of Personal Information as per POPIA

Handmade Media (Pty) Ltd is committed to the protection of personal information in accordance with the Protection of Personal Information Act (POPIA). We process personal information solely for the purposes of conducting our business and delivering professional marketing services to our clients.

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4.1 Purpose of Processing

We collect and process personal information for the following specific purposes:

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• Client Service Delivery: To execute marketing strategies, manage social media accounts, and maintain website backends on behalf of our clients.

• Performance Tracking: To access and analyze sales and marketing data to optimize campaign performance and report on business outcomes.

• Lead Generation: To utilize client-provided databases for the creation of targeted advertising audiences.

• Financial Administration: To facilitate accurate accounting, invoicing, and contract management.

• Human Resources: To manage employee records, payroll, and internal operational requirements.

• Communication: To manage interactions with leads and inquiries from website visitors.

 

4.2 Categories of Data Subjects

Handmade Media (Pty) Ltd processes information relating to the following categories of data subjects:

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• Employees and prospective employees

• Clients (Business entities and their representatives)

• Suppliers and service providers

• Sales leads

• Website visitors

• Social media audiences

 

4.3 Categories of Personal Information

The information processed by the Company may include:

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• Contact Details: Names, email addresses, phone numbers, and physical business addresses.

• Brand Elements: Proprietary brand guides, creative assets, and intellectual property provided by clients.

• Performance Data: Business sales data and marketing analytics.

• Client Databases: Customer contact lists used for marketing segmentation and lead generation.

 

4.4 Recipients of Personal Information

Personal information is handled with strict confidentiality and is shared only with authorized recipients:

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• Internal Employees: Personnel who require access to perform their professional duties.

• Marketing Sub-Contractors: Vetted third-party service providers who operate under strict non-disclosure and confidentiality agreements.

 

Data Security in Targeted Advertising

When utilizing client datasets for targeted advertising on platforms such as Meta, we employ rigorous security protocols. Datasets are pseudonymized or “scrambled” (hashed) by the platform before transmission, ensuring that the personal identifiers of client customers are protected against unauthorized access and cannot be extracted from the platform after the audience has been loaded.

 

5. Transborder Information Flows

In the course of providing digital marketing and creative services, Handmade Media (Pty) Ltd utilizes various international cloud-based software platforms and service providers. Consequently, personal information may be transferred across the borders of South Africa to jurisdictions where these third-party providers operate or store their data.

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The primary international platforms and categories of technology utilized by our agency include:

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• Cloud Productivity and Communication: Google Workspace

• Marketing Automation and Email: Mailchimp

• Social Media Management: Social Pilot

• Project Management and Operations: Monday.com

• Artificial Intelligence and Generative Tools: ChatGPT, Spock, and other integrated AI assistance platforms.

 

In alignment with Section 72 of the Protection of Personal Information Act (POPIA), Handmade Media (Pty) Ltd takes reasonable and practicable steps to ensure that the recipients of personal information located in foreign countries are subject to a law, a binding corporate rule, or a binding agreement that provides an adequate level of protection.

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6. Information Security Measures

Handmade Media (Pty) Ltd adopts a “security by design” approach to the management of personal and confidential information. We have implemented a comprehensive suite of technical and organizational measures to ensure the integrity, availability, and confidentiality of the data we process.

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6.1 Technical Safeguards

• Robust Access Control: Access is granted based on the principle of “least privilege,” ensuring employees only have access to the specific data required for their designated roles.

• Mandatory Authentication: Where supported by our service providers, we mandate the use of Multi-Factor Authentication (MFA) or Two-Factor Authentication (2FA).

• Encrypted Storage: We utilize reputable, encrypted cloud storage solutions for the retention of client files and internal records.

 

6.2 Organizational and Physical Safeguards

• Physical Access Controls: Our office premises at Monument Office Park are secured with access control measures to prevent unauthorized physical entry.

• Confidentiality Agreements: All employees are contractually bound to confidentiality agreements and receive training on data privacy.

• Continuous Monitoring: Handmade Media (Pty) Ltd conducts periodic reviews of its security posture and engages with our technical partners to update our security frameworks.

 

7. Access Request Procedure

To initiate a request for access to records, the Requester must use the prescribed Form 2: Request for Access to Record. This form must be submitted to our Information Officer via email: nanette@handmademedia.co.za.

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• Fees: A non-refundable request fee may be payable as determined by the Information Regulator.

• Timeframes: We will process all requests within 30 days of receipt, unless an extension is required by law.

 

8. Availability of this Manual

This manual is available through the following channels:

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• Digital Access: Available for free download on our website at www.handmademedia.co.za.

• Physical Access: Available for inspection, free of charge, during normal business hours at our office: Unit 6 - 202, Monument Office Park, 71 Steenbok Ave, Monument Park, Pretoria, 0181.

 

Compliance Statement Handmade Media (Pty) Ltd reviews this manual on an annual basis to ensure that all information remains accurate and consistent with the provisions of PAIA and POPIA.

Last Updated: June 2026