Public document · Section 51 of PAIA · MBM-PAIA-01 · v2.0
PAIA and POPIA Manual.
What records this company holds, how to ask for them, what it costs, on what grounds access may be refused, and what you can do about it if we get it wrong. Published because section 51 requires it — the exemption for private bodies lapsed on 31 December 2021.
This page is the manual. The PDF is the same document on the company letterhead, for a file or an agenda pack. Where this page and the Promotion of Access to Information Act 2 of 2000 differ, the Act prevails.
| Private body | MBM Valkyrie Advisory (Pty) Ltd, registration number 2026/493372/07 |
|---|---|
| Head of the body and Information Officer | Mthokozisi Brian Mhlongo (Director) — registered with the Information Regulator under number 2026-064683 |
| Deputy Information Officer | None appointed. The Company has one director and no employees; a deputy will be designated and registered if that changes. |
| Address for requests | 31 Ouklipmuur Avenue, Equestria, Pretoria, Gauteng, 0184 |
| Dedicated mailbox | paia@mbmvalkyrie.co.za — every PAIA request and every POPIA request, objection or complaint |
| Telephone | +27 61 586 9435 |
| Hours | Monday to Friday, 09:00 to 16:00, excluding public holidays |
| Version | 2.0 · compiled 18 August 2026 · revised 13 September 2026 · next review 31 August 2027 |
How to request a record
Four things, and the third is the one that fails.
Section 50 of PAIA entitles you to a record of a private body only where the record is required for the exercise or protection of a right. That is a real threshold, and it is where most requests fall over.
- 01 · FormUse Form 2 of the PAIA Regulations, 2021Obtainable from the Information Regulator at www.inforegulator.org.za, or ask us and we will send it. Email it to paia@mbmvalkyrie.co.za or deliver it to the address above.
- 02 · IdentifyDescribe the record well enough for us to find itThe list of subjects and categories below is published for exactly this purpose. Give the form of access you want — inspection, a copy, a transcription, or a particular electronic form.
- 03 · The rightSay which right, and why this recordIdentify the right you are exercising or protecting, and explain in two or three sentences why this record bears on it. “For my records” is not a right. This is the item that most often causes a request to be refused — and the one we will help you get right if you telephone first.
- 04 · FeePay the R140 request feeUnless you are a personal requester — someone asking for a record about themselves — in which case no request fee is payable. Access fees, if any, are quoted with the decision and paid before access is given.
What it costs
The prescribed fees, in full.
These are the fees prescribed for private bodies in Annexure B to the PAIA Regulations, 2021. They are reproduced here for convenience; where they differ from the Regulations as amended, the Regulations apply. No VAT — the company is not a registered VAT vendor.
| Request fee — every requester except a personal requester, before the request is processed | R140.00 |
|---|---|
| Photocopy or printed copy of an A4 page, or part of a page | R2.00 |
| Printed copy of an A4 page held in electronic form, or part of a page | R2.00 |
| Copy in computer-readable form — flash drive or compact disc provided by the requester | R40.00 |
| Copy in computer-readable form — compact disc provided by the Company | R60.00 |
| Transcription of an audio record, per A4 page | R24.00 |
| Copy of an audio record — on media provided by the requester | R40.00 |
| Copy of an audio record — on media provided by the Company | R60.00 |
| Search and preparation, per hour or part of an hour, excluding the first hour | R145.00 to a maximum of R435.00 |
| Postage, where a copy is posted | The actual cost |
| Deposit, where search and preparation is likely to exceed six hours | One third of the access fee |
What we hold
Subjects, and the categories of records on each.
Published under section 51(1)(e) to help you identify the record you want. Listing a record here is not an undertaking that access will be granted — every request is decided against the grounds below.
| Company records and governance | Memorandum of Incorporation; CIPC filings; registers of directors, securities and beneficial ownership; declarations of interest; resolutions and minutes; the internal governance framework and its policy register. |
|---|---|
| Client engagements | Engagement letters and scoping notes; conflict and independence checks; instructions and correspondence; advice, opinions and drafted instruments; working papers; file-closure records. |
| Financial and tax | Accounting records; invoices and statements; bank records; supplier and procurement records; annual financial statements; SARS returns, assessments and correspondence. |
| Marketing and business development | Website enquiries and scoping-call requests; proposals and quotations; tender and bid submissions; supplier-database registrations. |
| Information and technology | Systems and access records; backups; the operator register and operator agreements; security-compromise records; the personal-information inventory and data-flow map. |
| Insurance and compliance | Professional indemnity policy and certificates; B-BBEE affidavit; tax compliance status; the compliance universe, calendar and breach register. |
| People | Records of any employee, contractor or intern engaged from time to time. The Company presently has no employees. |
| Access to information and privacy | Requests received under PAIA and POPIA, the decisions taken and the reasons for them; the register of requests; this Manual and its earlier versions. |
When access can be refused — and what you do then
The grounds, and your two remedies.
A refusal is given in writing, with adequate reasons, the provisions relied on, and a statement of your remedies. Where only part of a record may be withheld, you get the rest.
- Section 63Unreasonable disclosure of personal information about a third party
- Section 64Commercial information of a third party — trade secrets, and information supplied in confidence in contract negotiations
- Section 65Information supplied in confidence, where disclosure could found an action for breach of a duty of confidence
- Section 66Information whose disclosure could endanger life or physical safety, or prejudice the security of property
- Section 67Records privileged from production in legal proceedings
- Section 68Commercial information of the Company itself
- Section 69Research information of the Company or of a third party
- Section 70The public-interest override — access must be granted despite the above where disclosure would reveal a substantial contravention of the law or an imminent and serious public safety or environmental risk, and the public interest clearly outweighs the harm
Your remedies
There is no internal appeal against a decision of a private body. If you are dissatisfied — including where we have failed to decide in time — you have two routes, and you may take either.
- Complain to the Information Regulator in the prescribed manner under section 77A of PAIA, within 180 days. PAIAComplaints@inforegulator.org.za · 33 Hoofd Street, Forum III, 3rd Floor Braampark, Braamfontein, Johannesburg · P.O. Box 31533, Braamfontein, 2017 · +27 10 023 5200 · www.inforegulator.org.za
- Apply to a court with jurisdiction for appropriate relief under section 78 of PAIA, within 180 days of the decision or of the outcome of a complaint.
A third party unhappy that we have decided to grant access to a record containing information about them has the same two remedies.
Personal information
What we process, why, who receives it, and your rights.
POPIA amended section 51 so that a private body’s manual must also record the particulars of its processing. Part 8 of the PDF sets these out in full; the substance is here.
To answer an enquiry and run a conflict check; to perform an engagement under a signed engagement letter; to invoice and keep accounting records; to comply with company, tax, labour and — where applicable — financial-intelligence legislation; to run our own governance framework and evidence it; to answer a PAIA or POPIA request; and to send information about our services to someone who has asked for it, and to nobody else.
The client on whose instruction it is processed. Operators bound by written agreements meeting section 21 of POPIA — our email and cloud storage provider, our website host, our accounting provider and our document-destruction provider. Professional advisers under confidentiality. A practising attorney to whom a matter is referred, with the client’s knowledge. A regulator, court or organ of state where the law requires it. Our bank and insurers where necessary. It is never sold, rented or traded.
We do not plan to transfer personal information outside South Africa for our own purposes. It may be stored or processed abroad by a cloud email, storage or hosting provider — where that happens we rely on section 72 and satisfy ourselves that the recipient is bound by terms no less protective than POPIA’s conditions.
Access limited to the director and to operators bound by written agreement, on a need-to-know basis; unique credentials and multi-factor authentication; encryption at rest and in transit; tested backups; paper records locked and destroyed against a certificate; a retention schedule with a litigation hold; and a security-compromise procedure that governs notification to the Regulator and to affected data subjects under section 22.
You may ask us to confirm what we hold about you, and ask for it. You may ask us to correct or delete personal information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or unlawfully obtained — on Form 2 of the POPIA Regulations, 2018, and there is no fee. You may object to processing on reasonable grounds, on Form 1, and there is no fee. You may tell us to stop using your information for direct marketing at any time, without giving reasons. You may complain to the Information Regulator and you may sue under section 99. We answer within 30 days.
This manual, and the work behind it
Start here
Does your organisation have one of these?
It is compulsory, it is public, and its absence is the first thing a complainant points at. A section 51 manual is included in our POPIA readiness programme, or quoted on its own.