PAIA Manual

NUTEC DIGITAL INK (PTY) LTD
Registration number 2009/017637/07

PROMOTION OF ACCESS TO INFORMATION MANUAL
Prepared in terms of Section 51 of the Promotion of Access to Information Act, 2000 (Act No. 2 of 2000)
Last updated: May 2026

1. Introduction
NUtec Digital Ink (Pty) Ltd (“NUtec” or “the Company”) is a private company incorporated in South Africa. This manual is prepared in accordance with Section 51 of the Promotion of Access to Information Act (“PAIA”) to facilitate access to records held by the Company. This manual also incorporates relevant provisions of the Protection of Personal Information Act, 2013 (“POPIA”).
The purpose of this Manual is to:
• provide a description of the categories of records held by the Company;
• explain how requests for access to records may be made;
• describe the manner in which personal information is processed; and
• provide transparency regarding the governance and information practices of the Company.

2. Company details
NUtec was founded in November 2009 and develops and produces premium quality Water-based, UV Curable, Eco and Mild Solvent ink for the high-resolution, wide and super-wide format inkjet digital printing industry, packaged in cartridges, bottles and pouches and in bulk for the commercial as well as industrial markets.

Full name: NUtec Digital Ink (Pty) Ltd
Registration number: 2009/017637/07
Physical address: 1 Clifford Street, Ottery, 7808, South Africa
Postal address: Same as above
Telephone: +27 21 763 6990
Website: www.nutecdigital.com

3. Information officer
Information Officer: Darren Crosse
Email: data.privacy@nutecdigital.com
The Information Officer is duly appointed and responsible for compliance with PAIA and POPIA. The Information Officer is registered with the Information Regulator. There is no Deputy Information Officer.

4. PAIA Guide
The Information Regulator has compiled a guide in terms of section 10 of PAIA containing information required by persons wishing to exercise rights under PAIA and POPIA.
The Guide is available:
• from the Information Regulator website: https://inforegulator.org.za/;
• at the offices of the Information Regulator; and
• for inspection at the principal place of business of the Company during ordinary business hours.
The Guide is available in at least two official languages.

5. Categories of records automatically available
The following categories of records may be made available without a formal PAIA request, subject to availability and applicable confidentiality considerations:
• Company profile
• Published policies
• Publicly available marketing material
• Product brochures
• Safety data sheets
• Standard terms and conditions
• Website content
• Public corporate information

These records may be accessed:
• on the Company website where applicable;
• by request to the Information Officer; or
• at the Company’s registered office during ordinary business hours.

6. Records available in terms of other legislation
Records are maintained in accordance with applicable legislation, including but not limited to:
• Companies Act 71 of 2008
• Income Tax Act 58 of 1962
• Value Added Tax Act 89 of 1991
• Labour Relations Act 66 of 1995
• Basic Conditions of Employment Act 75 of 1997
• Employment Equity Act 55 of 1998
• Occupational Health and Safety Act 85 of 1993
• Protection of Personal Information Act 4 of 2013
• Unemployment Insurance Act, 2001
• Compensation for Occupational Injuries and Diseases Act, 1993
• Electronic Communications and Transactions Act, 2002
• Protection of Personal Information Act, 2013

7. Subjects and categories of records held
7.1 Corporate and Governance Records
• Certificates of incorporation
• Memoranda of Incorporation
• Shareholder records
• Director records
• Board resolutions and minutes
• Statutory registers
7.2 Financial Records
• Annual financial statements
• Accounting records
• Management accounts
• Banking records
• Asset registers
• Tax records
• Audit records
7.3 Human Resources Records
• Employment agreements
• Payroll records
• Leave records
• Performance records
• Disciplinary records
• Training records
• Employee benefit records
7.4 Investment and Transaction Records
• Shareholding records
• Investment agreements
• Funding arrangements
• Transaction records
• Due diligence records
7.5 Operational Records
• Supplier agreements
• Customer contracts
• Operational procedures
• SHEQ records
• Insurance records
• Compliance records
7.6 Information Technology Records
• IT policies
• Access control records
• System usage records
• Cybersecurity records
• Data backup records
7.7 Legal and Compliance Records
• Litigation records
• Legal opinions
• Compliance reports
• Regulatory correspondence
• Licences and permits
7.8 Intellectual Property
• Trademarks
• Proprietary information

8. Processing of personal information
8.1 Purpose of Processing
Personal information is processed for purposes including:
• employment administration;
• business operations;
• client and supplier relationship management;
• legal and regulatory compliance;
• financial administration; and
• risk management and security.
8.2 Categories of Data Subjects
The Company may process personal information relating to:
• employees;
• directors;
• shareholders;
• customers;
• suppliers;
• contractors;
• service providers;
• visitors; and
• business partners.
8.3 Categories of Personal Information
The Company may process:
• identification information;
• contact details;
• financial information;
• employment information;
• transactional information;
• correspondence;
• CCTV and access records; and
• compliance and due diligence information.
8.4 Recipients or Categories of Recipients
Personal information may be shared with:
• regulatory authorities;
• banks and financial institutions;
• auditors and professional advisers;
• IT service providers;
• payroll and benefit administrators;
• insurers; and
• law enforcement authorities where legally required.
8.5 Cross-Border Transfers
The Company may transfer personal information outside South Africa where required for:
• cloud storage;
• IT systems;
• international service providers; and
• business operations.
Where personal information is transferred internationally, appropriate contractual and security safeguards are implemented in accordance with POPIA.
8.6 Information Security Measures
The Company implements reasonable technical and organisational measures to protect personal information, including:
• access controls;
• password protection;
• cybersecurity safeguards;
• secure storage;
• confidentiality undertakings;
• restricted access to sensitive records;
• document retention and destruction procedures; and
• system monitoring and backup procedures.

9. Request procedure
Requests for access to records must:
• be made using the prescribed Information Regulator request form ( https://inforegulator.org.za/paia-forms/ );
• contain sufficient detail to identify the requested record;
• include proof of identity; and
• specify the form of access required.
Requests must be submitted to the Information Officer.
The requester may be required to pay prescribed fees before access is granted.

10. Fees
Fees payable in terms of PAIA are prescribed by regulation as set out on the Information Regulator web site ( https://inforegulator.org.za/paia-forms/ ) and may include:
• request fees;
• search and preparation fees;
• reproduction fees; and
• postage or courier costs.
The requester will be informed of applicable fees before processing proceeds.

11. Grounds for refusal of access
Access to records may be refused on grounds including:
• protection of personal information of third parties;
• protection of confidential commercial information;
• protection of legally privileged information;
• protection of safety and security;
• records prohibited from disclosure by law; and
• manifestly frivolous or vexatious requests.

12. Availability of this manual
This Manual is available:
• on the Company website;
• at the principal place of business during ordinary business hours;
• from the Information Officer upon request; and
• on the Information Regulator eServices portal where required.

13. Annual reporting
Where applicable, the Information Officer shall submit annual reports to the Information Regulator in accordance with section 32 of PAIA.