Tentpole endorses the spirit of the Promotion of Access to Information Act, No. 2 of 2000 (“the Act”) and believes that this Manual will assist requesters in exercising their rights. The Act seeks, inter alia, to give effect to the constitutional right of access to any information held by the state or by any other person where such information is required for the exercise or protection of any right.

This PAIA Manual was compiled in terms of Section 51 of the Act to facilitate access to records held by Tentpole. It contains information required by a person wishing to exercise any right, contemplated by the Act. It is available in English.

A copy of this Manual is available to the public in a PDF (“Portable Document Format”) version on the website of Tentpole or on request from the Information Officer referred to in this Manual.



Tentpole Data Sciences is a South African based, BBBEE Level 2 organization with multiple specializations, including both Deferred and Real Time Analytics, Large Scale Data Orchestration, Visualization, Compliance and Benchmarking.  We pride ourselves in our responsiveness, quality of service and driving the relevance of data into your industry and everyday business practices. Through the deployment of our specialized and technically capable and qualified staff, Tentpole Data Sciences will deliver an optimized solution which will deliver operational enablement and efficiencies into your business.

Tentpole offers a focused array of services and products for Consulting, Anutomation, Data Scinces, Dashboarding and similar related services.  Our solution are based either on site or in the cloud and offered through shared or dedicated resources.

Tentpole is committed to conducting its business in a manner that ensures long-term sustainability for the benefit of communities and all stakeholders. Sustainability is a continuous journey and requires a multi-disciplinary approach. Good governance, sound risk management, stakeholder engagement, corporate social investment, minimizing the Tentpole’s impact on the environment all form part of Tentpole’s vision to be a leading emerging markets ICT player.


Tentpole (Pty) Ltd Registration Number: 2017/257055/07

Physical Address:                 17 Muswell Road South, Bryanston, 2021

Postal Address:                    17 Muswell Road South, Bryanston, 2021




The Managing Director of Tentpole Limited is:

Name:                                                        Mr. Grant Spindler

Physical Address:                                    17 Muswell Road South, Bryanston, 2021




This Manual has been prepared in respect of the Tentpole of Companies, which includes  the following related entities:

  • Tentpole (Pty) Ltd

The scope of this Manual exclude Tentpole’s operations outside the Republic of South Africa and will serve to provide a reference regarding the records held by Tentpole at its Registered Office and various operations within the borders of the Republic of South Africa.



Tentpole will protect the confidentiality of information provided to it by third parties, subject to Tentpole’s obligations to disclose information in terms of any applicable law or regulation or a court order requiring disclosure of information. If access is requested to a record that contains information about a third party, Tentpole is obliged to attempt to contact such third party to inform him/her/it of the request.

Tentpole will give the third party an opportunity of responding by either consenting to the access or by providing reasons why the access should be denied. In the event that the third-party furnishing reasons for the support or denial of access, the Information Officer will consider these reasons in determining whether access should be granted to the requestor or not.



At this stage, no notice(s) has/have been published in terms of section 52 of the Act on the categories of records that are automatically available without a person having to request access in terms of the Act.

Records that are is automatically available at the registered office of Tentpole on payment of the prescribed fee for reproduction:

  • Records of Tentpole lodged in terms of government requirements such as the Registrar of
  • Documentation and information relating to Tentpole which is held by the Companies and Intellectual Properties Commission in accordance with the requirements set out in
  • section 25 of the Companies Act 71 of
  • Product and Services
  • News and other Marketing Information; and
  • Extracts from the annual integrated report and any other shareholder communications prior to 24th August 2015 as published on Tentpole’s website

Certain other information relating to Tentpole is also made available on their website from time to time.



Records are kept in accordance with such other legislation as applicable to Tentpole, which includes, but is not limited to:

  • Arbitration Act 42 of 1965
  • Banks Act 94 of 1990
  • Basic Conditions of Employment Act 75 of 1997
  • Broad-Based Black Economic Empowerment Act 53 of 2003
  • Companies Act 61 of 1973
  • Compensation for Occupational Injuries and Diseases Act 130 of 1993
  • Competition Act 89 of 1998
  • Constitution of South Africa Act 108 of 1996
  • Consumer Protection Act 68 of 2008
  • Copyright Act 98 of 1987
  • Criminal Procedure Act 51 of 1977
  • Currency and Exchanges Act 9 of 1933
  • Customs and Excise Act 91 of 1964
  • Debt Collectors Act 114 of 1998
  • Deeds Registries Act 47 of 1937
  • Electronic Communications and Transactions Act 25 of 2002
  • Employment Equity Act 55 of 1998
  • Environmental Laws Rationalization Act 51 of 1997
  • Finance Act 35 of 2000
  • Financial Intelligence Centre Act 38 of 2001
  • Firearms Control Act 60 of 2000
  • Income Tax Act 58 of 1962
  • ICASA Act 13 of 2000
  • Insider Trading Act 135 of 1998
  • Insolvency Act 24 of 1936
  • Insurance Act 27 of 1943
  • Intellectual Property Laws Amendments Act 38 of 1997
  • Labour Relations Act 66 of 1995
  • Long-Term Insurance Act 52 of 1998
  • Magistrates Court Act 32 of 1944
  • Marketable Securities Act 32 of 1948
  • National Environmental Management Act 107 of 1998
  • National Water Act 36 of 1998
  • Occupational Health and Safety Act 85 of 1993
  • Patents Act 57 of 1987
  • Pension Funds Act 24 of 1956
  • Preferential Procurement Policy Framework Act of 2000
  • Promotion of Access to Information Act 2 of 2000
  • Protected Disclosures Act 26 of 2000
  • Prevention of Organized Crime Act 14 of 1998
  • Promotion of Equality and Prevention of Unfair Discrimination Act No 4 of 2000
  • Regulation of Interception of Communications and Provision of Communication Related Information Act 70 of 2002
  • Short Term Insurance Act 53 of 1998
  • Skills Development Act 97 of 1998
  • Skills Development Levies Act 9 of 1999
  • South African Revenue Service Act 34 of 1997
  • Statistics Act 6 of 1999
  • Stock Exchange Control Act 1 of 1985
  • Trademarks Act 194 of 1993
  • Transfer Duty Act 40 of 1949
  • Unemployment Contributions Act 4 of 2002
  • Unemployment Insurance Act 63 of 2001
  • Value Added Tax Act 89 of 1991

While Tentpole has used its best endeavors to supply you with a list of applicable legislation it is possible that the above list may be incomplete. Wherever it comes to Tentpole’s attention that existing or new legislation allows a requester access on a basis other than that set out in the Act, we shall update the list accordingly



  • On 9 March 2001, the Act came into effect. The Act seeks to advance a culture of transparency and accountability in both public and private bodies. The legislation was enacted as a direct response to Section 32(2) of the Constitution of South Africa – the right of access to information – which requires that the Government implements laws in an effort to make information pertaining to public and private bodies more accessible to
  • The Act gives effect to the constitutional right of access to any information held by the State and any information that is held by another person and that is required for the exercise or protection of any Where a request is made in terms of the Act, the body to whom the request is made is obliged to release the information, except where the Act expressly provides that the information may or must not be released.
  • One of the main requirements specified in the Act is the compilation of a manual that provides information on both the types and categories of records held by the public or private In terms of the Act, Tentpole is regarded as a “private body” and therefore the requirements regarding access must be in compliance with the provisions of the Act relevant to private bodies and more in particular Section 51 of the Act.
  • In compliance with Section 51 of the Act this PAIA Manual sets out the following details:
  • Tentpole’s contact details including, physical and postal addresses, telephone and fax numbers, electronic mail address of the person tasked in terms of this Code of
  • Information on how to obtain and access this Code of Conduct and a guide on how to use it;
  • Categories of information held by Tentpole that is available without a person having to formally request such details in terms of the
  • Categories of information held by Tentpole that is available in accordance with other legislation and which, subject to the Act, may be made available by Tentpole on receipt of and consideration of a formal request, made in terms of the Act;
  • Sufficient information to facilitate a request for access to records and a description of the subjects on which records are available from
  • Adherence to these requirements entails not only compilation of the external manual but also compliance with the general provisions stated in the


10. GUIDE ON HOW TO USE THE ACT – [Section 10]

  • The Human Rights Commission has been tasked with the administration of the
  • In terms of Section 10 of the Act, the Human Rights Commission has compiled a guide which is intended to assist users in the interpretation of the Act and how to access the records of private and public bodies and the remedies available in law regarding a breach of any of the provisions of the
  • Should any person have queries or concerns relating to their rights and in particular their right to access information from a private or public body, such queries should be directed to:

The South African Human Rights Commission PAIA Unit Private Bag X2700

Houghton, 2041

Republic of South Africa

Business phone: +27 11 877 3600

Fax: +27 11 403 0625

Email address:



The list(s) below depict records of information which Tentpole has available in terms of laws applicable to Tentpole Limited and its subsidiary companies listed under section 5   above (jointly referred to as Tentpole).  These will only be supplied in the correct situation, for the correct reasons and where deemed necessary by all parties.

Corporate Secretariat and Governance:

  • Minutes of Shareholders’ Meeting
  • Committee Meetings
  • Memoranda of Incorporation
  • Applicable Statutory Documents
  • Codes of Conduct
  • Policies and Procedures
  • Compliance Certification
  • Records relating to the appointment of directors/auditor/ secretary/public officer and other officers
  • Fraud alerts and whistle blowing
  • Share Certificates
  • Health & Safety Records
  • Share Register and other statutory registers
  • Legal Compliance Records
  • Statutory Returns to Relevant AuthoritiesAnnual Reports

    Finance and Taxation:

    • Accounting Records
    • Leases
    • Annual Financial Statements
    • Management Reports
    • Asset Register
    • Monthly expenses
    • Audit Reports
    • Paid Cheques
    • Banking Records Bank Statements
    • PAYE Records
    • Business Plan and Budgets
    • Payment Terms
    • Capital Expenditure Records
    • Records of payments made to SARS on behalf of employees
    • Debtors and Creditors Statements and Invoices
    • Rental Agreements
    • Documents issued to employees for income tax purposes
    • Risk Management and Insurance
    • Electronic banking records
    • Tax Records and Returns
    • Financial Policies and Procedures
    • Transaction Records
    • General Ledger and Sub Ledgers
    • Treasury Dealing
    • General Ledger Reconciliations
    • All other statutory compliancesIncome Tax Returns
    • Skills Development Levies Returns
    • UIF Returns
    • VAT Returns
    • Workmen’s Compensation Returns


      • CV’s, application details
      • Letters of Appointment and Employment
      • Disciplinary Code and Records
      • Medical Aid Records
      • Disciplinary Procedures and CCMA matters
      • Organizational Structures
      • Education and Training Record
      • PAYE Returns
      • Employee Benefit Records
      • Payroll Reports
      • Employee Relation
      • Pension and Retirement Funding Records
      • Employment Contracts
      • Performance Records
      • Employment Equity Plan
      • Personal Records
      • Employee Information
      • Remuneration Policy
      • Forms and Applications
      • SETA Records
      • Grievance Procedure
      • Skills Development
      • Group HR Policies and Procedures
      • Social Responsibility
      • Incentives and Bonuses
      • Study Assistance Scheme/s
      • IRP5
      • Time Management
      • Job Profiles
      • Training and Development
      • Leave Records
      • UIF Returns

        Information Technology and Infrastructure:

        • Call Desk Agent Schedule
        • License Agreements
        • Device Management
        • Maintenance Plans
        • Disaster Recovery Policy and Plans
        • Network Topologies/Diagrams
        • E and Voice mail
        • Operating Systems
        • Equipment Specifications
        • Performance of Client Call Desk
        • Facilities
        • Performance of IT Infrastructure
        • Faults, Troubleshooting and Reporting Root Cause Analyses
        • Hardware and Software Manuals
        • Security Access
        • ICT Policies, Standards, Procedures and Templates
        • Information, Communication and Technology Policies
        • Software Licenses
        • Supplier Agreements/ Vendor Agreements
        • Internal Systems Support and Programming
        • System/Application landscape Diagrams
        • ISAE3402 Audit Reports
        • System documentation and manuals

        Intellectual Property:

        • Agreements relating to intellectual property
        • Patents
        • Copyrights Agreements
        • Trademark applications
        • Licenses
        • Know-how
        • Designs

        Corporate Affairs and Investor Relations / Communications:

        • Client Events
        • Newsletters and Publications
        • Corporate Social Investment
        • Public Corporate Records
        • Media Releases
        • SENS releases (Prior to 24th August 2015)


        • Agreement and Contracts
        • Records of Stolen Goods
        • Competition Notifications
        • Subpoenas
        • Documents pertaining to commercial disputes, litigation, arbitration, or regulatory
        • Title deeds and leases
        • Health and Safety Records
        • Trademark Registration Documentation
        • Police investigations and cases

        Sales, Marketing and Communication:

        • Actual Sales
        • Media and Advertising
        • Branding
        • Point of Sale (POS)
        • Commission
        • Press releases / Communique
        • Customer Orders and Delivery Notes
        • Products and Services Brochures
        • External Publications
        • Proposals and Tenders
        • Marketing Brochures
        • Media and Advertising

        Business Interactions with other entities:

        • Agreements with third parties (Clients, Vendors and Suppliers)
        • Licensing and Maintenance Agreements
        • Contractual disputes with third parties
        • Payment History
        • Customer Credit vetting
        • Service Level Agreements
        • Customer Satisfaction Surveys


        • Insurance Policies
        • Insurance Claim Files


        • Impact Assessment
        • Records of disposal of equipment
        • Maintenance Records
        • Standards


        • Applications
        • Permits
        • Exemptions
        • Registrations
        • Licenses
        • Submissions

        Logistics and Procurement:

        • Dispatch
        • Statements of Work
        • Inspection
        • Stock Records
        • Procurement Policy
        • Supplier and Contractor Agreements
        • Purchase Orders
        • Suppliers and Manufacturers Details
        • Standard Terms and Conditions of Supply of Tender Documentation and Services.
        • Correspondence with internal and external parties



        Records of Tentpole which are not automatically available must be requested in terms of the procedure set out in section 8 of this PAIA Manual and which may be subject to the restrictions and right of refusal to access as provided for in the Act.



        • Any person making a request for access to records of Tentpole is referred to as a “requester”.
        • The requester must comply with all the procedural requirements contained in the Act relating to the request for access to
        • The requester must complete the prescribed form application form attached hereto marked Form C and submit the form as well as payment of the request fee and a deposit, if applicable, to the Managing Director of Tentpole at the electronic mail address as stated

        The prescribed form must be filled in with sufficient particulars to at least enable the Information Officer of Tentpole to identify:

        • The record or records
        • The identity of the
        • Which form of access is required if the request is granted; and
        • The postal address, telephone number and fax number of the
        • The requester must state that he/she requires the information to exercise or protect her/his right and clearly state what the nature of the right is to be exercised or protected. In addition, the requester must clearly specify why the records are necessary to exercise or protect such a
        • Such request must be processed within 30 (thirty) days after the request has been
        • The requester shall be informed whethder the access has been granted or denied within 30 (thirty) days of receipt of the request and give notice with reasons to that
        • The 30 (thirty) day period within which the company has to decide whether to grant or refuse the request, may be extended for a further period of not more than 30 (thirty) days if the request is for a vast amount of information, or the information cannot reasonably be obtained within the original 30 (thirty) day period. The Information Officer will notify the requester in writing should an extension be
        • If the request for access is granted, the Information Officer of Tentpole must advise the requestor: the access fee (if any) to be paid upon, the form in which access will be given; and, that the requester may lodge an application with a court against the access fee to be paid or the form of access granted, and the procedure, including the period allowed, for lodging the
        • If the request for access is refused, the Information Officer of Tentpole must: state adequate reasons for the refusal, including the provisions of this Act relied on; exclude, from any such reasons, any reference to the content of the record; and state that the requester may lodge an application with a court against the refusal of the request, and the procedure (including the period) for lodging the
        • In terms of Section 54 of the Act, if all reasonable steps have been taken to find the record requested and there are reasonable grounds to believe that the record is in possession of Tentpole but cannot be found, and if it does not exist, then the Information Officer of Tentpole must notify by way of affidavit or affirmation, the requester that it is not possible to give access to that
        • If after notice is given, the record in question is found, the requester must be given access thereto unless the ground for the refusal of access
        • If the request is declined for any reason the notice must include adequate reasons for the decision, together with the relevant provisions of the Act relied upon and provide the procedure to be followed should the requester wish appeal the
        • Section 59 provides that the Information Officer of Tentpole may serve a record and grant access only to that portion which the law does not prohibit access
        • The requester must pay the prescribed fee, before any further processing can take


        14. FEES

        • The Act provides for two types of fees, namely: A request fee, which will be a standard fee; and
        • An access fee, which must be calculated by taking into account reproduction costs, search and preparation time and costs, as well as postal
        • When the request is received by the Information Officer of Tentpole, such person shall by notice require the requester to pay the prescribed request fee, if any, before further processing of the
        • If a requester requires access to records of his/her personal information there shall be no request fee However, the requester must pay the prescribed access and reproduction fees for such personal information.
        • If the search for the record has been made and the preparation of the record for disclosure including arrangements to make it available in the request form, requires more than the hours prescribed in the regulations for this purpose, the Information Officer of Tentpole shall notify the requester to pay as a deposit the prescribed portion of the access fee which would be payable if the request is
        • The Information Officer of Tentpole shall withhold the record until the requester has paid the fees as indicated in Annexure “B”
        • A requester whose request for access to a record has been granted, must pay an access fee for reproduction and for search and preparation, and for any time reasonably required in excess of the prescribed hours to search for and prepare the records for disclosure including making arrangements to make it available in the request
        • If a deposit has been paid in respect of a request for access, which is refused, then the Information Officer of Tentpole must repay the deposit to the requester with interest at the prescribed


        15. THIRD PARTIES 

        • If the request is for the record pertaining to the third party, the Information Officer of Tentpole must take all reasonable steps to inform the third party of the This must be done within 21 (twenty-one) days of receipt of the request. The manner in which this is done must be by the fastest means reasonably possible, but if orally, the Information Officer of Tentpole must thereafter give the third party a written confirmation of the notification.
        • The third party may within 21 (twenty-one) days thereafter either make representation to the company as to why the request should be refused; alternatively grant written consent to the disclosure of the
        • The third party must be advised of the decision taken by the Information Officer of Tentpole whether to grant or to decline the A third party who is dissatisfied with the Information Officer of Tentpole’s decision to grant a request for information, may within 30 (thirty) days of notification of the decision, apply to a Court for relief.



        Tentpole has the right to refuse access to information on one or more of the following grounds:

        • Mandatory protection of the privacy of a third party who is a natural person, if such disclosure would involve the unreasonable disclosure of personal information about a third party, including a deceased individual, subject to the provisions of section 63 (2).
        • Mandatory protection of the commercial information of a third party, if the record contains: Trade secrets of that Financial, commercial, scientific or technical information which disclosure could likely cause harm to the financial or commercial interest of that third Information disclosed in confidence by a third party, if the disclosure could put that third party at a disadvantage in negotiations or commercial Mandatory protection of confidential information of third parties if it is protected in terms of any
        • Mandatory protection of certain confidential information of third party, where the head of a private body must refuse a request for access to a record of the body if its disclosure would constitute an action for breach of a duty of confidence owed to a third party in terms of an
        • Mandatory protection of the safety of individuals and the protection of property, where such disclosure could endanger the life or physical safety of an individual, or prejudice or impair the security of:
          • a building, structure or any system
          • a means of transport, or
          • any other
        • Mandatory protection of records, which would be regarded as privileged from production in legal proceedings.
        • Commercial information of private body, in that a request for access to a record may be refused if the record contains:
          • trade secrets, financial, commercial, scientific or technical information of the institution, which disclosure, could likely cause harm to the financial or commercial interest of the institution;
          • A computer program which is owned by the institution and which is protected by
          • Information which, if disclosed could prejudice or put the institution at a disadvantage in negotiations or commercial competition; and
        • Mandatory protection of research information of the institution. A request will be refused if this disclosure would disclose the identity of the institution, the researcher or the subject matter of the research and would place the researcher at a serious
        • Mandatory disclosure in public interest. Despite any of the protections mentioned above, the Director of the Company shall grant a request for access to a record if:
          • the disclosure of the record would reveal evidence of-
          • a substantial contravention of, or failure to comply with, the law; or
          • imminent and serious public safety or environmental risk; and
          • the public interest in the disclosure of the record clearly outweighs the harm contemplated in the provision in


        17. APPEAL – REMEDIES [section 57(1)]

        Tentpole does not have an internal appeal procedure. As such, the decision made by the Information Officer of Tentpole is final and requesters will have to exercise such external remedies at their disposal if the request for information is refused and the requester is not satisfied with the answer supplied by the Information Officer of Tentpole.

        If a requester is aggrieved by the refusal of the Information Officer to grant a request for a record, the requester may, within thirty (30) days of notification of the Information Officer’s decision, apply to court for appropriate relief.

        The court will review the request and decide whether in fact the Information Officer of Tentpole should give the requester the information requested or not. A court hearing an application in terms of the Act may grant any order that is just and equitable including orders:

        confirming, amending or setting aside the decision which is the subject of the application;

        • requiring the Information Officer of Tentpole or relevant authority of a public body or the head of a private body to take such action or to refrain from taking such action, as the court considers necessary within the period mentioned in the court order;
        • granting an interdict, interim or specific relief, a declaratory order or compensation; or
        • granting an order as to costs.