PAIA Manual

Vicinity Agency Pty Ltd

Prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 (as amended)

Date of compilation: 16 July 2026 Date of last revision: 16 July 2026

1. Acronyms and abbreviations

DIO — Deputy Information Officer
IO — Information Officer
PAIA — Promotion of Access to Information Act 2 of 2000 (as amended)
POPIA — Protection of Personal Information Act 4 of 2013
Regulator — The Information Regulator (South Africa)
Republic — Republic of South Africa

2. Purpose of this manual

This manual is published so that members of the public can:

Check which categories of records held by Vicinity Agency are available without having to submit a formal PAIA request.
Understand how to make a request for access to a record, by describing the subjects on which Vicinity Agency holds records and the categories of records held on each subject.
Know which records are available under other legislation, without going through PAIA.
Find the contact details of the Information Officer and Deputy Information Officer who can assist with a request.
Know how to access the Regulator's official Guide on how to use PAIA.
Understand how Vicinity Agency processes personal information — the purpose of processing, the categories of data subjects and information involved, who it may be shared with, whether it moves outside South Africa, and what security measures protect it.

3. Key contact details for access to information

3.1 Information Officer

Name: Claudia Ann Freese Title: Founder & Director Tel: +27 78 946 1602 Email: claudia@vicinityagency.com

3.2 Deputy Information Officer

Name: Cameron Spangenberg Tel: +27 82 701 5157 Email: cameron@vicinityagency.com

3.3 General access-to-information contact

Email: hello@vicinityagency.com

3.4 Head office

Postal address: 219 Klip Street, Vryheid, KwaZulu-Natal, 3100, South Africa Physical address: 219 Klip Street, Vryheid, KwaZulu-Natal, 3100, South Africa Telephone: +27 78 946 1602 Email: hello@vicinityagency.com Website: vicinityagency.com

4. Guide on how to use PAIA

The Information Regulator has, in terms of section 10(1) of PAIA, published a Guide on how to use PAIA, explaining the objects of PAIA and POPIA, how to make a request, what assistance is available, and what remedies exist if a request is refused.

The Guide can be obtained:

By request to Vicinity Agency's Information Officer, at the contact details above.
From the Information Regulator's website: justice.gov.za/inforeg.

A copy of the Guide is available for public inspection during normal business hours at Vicinity Agency's head office in English and Afrikaans.

5. Categories of records available without a request

The following records are made available automatically, without a person needing to submit a formal PAIA request:

Category of record	Type of record	Available on website	Available on request
Company information	Company profile, services overview	X	X
Legal/website policies	Privacy Policy, Terms and Conditions, Cookie Policy, this PAIA Manual	X	X
Marketing material	Portfolio, case studies	X	X

6. Records available under other legislation

Category of record	Applicable legislation
Memorandum of Incorporation, company registration documents	Companies Act 71 of 2008
Annual financial statements	Companies Act 71 of 2008
Tax records	Tax Administration Act 28 of 2011
Employment records	Basic Conditions of Employment Act 75 of 1997; Labour Relations Act 66 of 1995
Personal information processing records	Protection of Personal Information Act 4 of 2013

7. Subjects and categories of records held

Subject	Categories of records
Corporate/governance	Memorandum of Incorporation, registration certificate, company resolutions
Finance	Invoices, financial statements, banking details, supplier and client contracts
Human resources	Employment contracts, ID documents, payroll records, leave records, qualifications
Client and project records	Client contracts, project briefs, creative deliverables, project correspondence
Marketing and website	Website analytics data (once active), social media content
IT and security	System access logs, data backups

8. Processing of personal information

8.1 Purpose of processing

Vicinity Agency processes personal information to deliver branding, marketing, and web design services to clients; to manage relationships with employees, contractors, and suppliers; and to operate and improve the Vicinity Agency website, including analytics and advertising once those tools are active. See the Privacy Policy for full detail.

8.2 Categories of data subjects and information processed

Category of data subject	Personal information that may be processed
Clients / prospective clients	Name, company, email, phone number, project details, billing information
Website visitors	IP address, browser/device data, cookies (once analytics/advertising tools are active — see Cookie Policy)
Employees / contractors	Name, ID number, contact details, banking details, tax number, qualifications
Suppliers	Company name, contact person, banking details, VAT number

8.3 Recipients or categories of recipients

Category of personal information	Recipients / categories of recipients
Website visitor data (once active)	Analytics and advertising platforms (e.g. Google, Meta)
Financial records	Accountant / auditors
Employee tax and payroll data	South African Revenue Service (SARS); payroll service provider

8.4 Planned transborder flows of personal information

Some personal information may be stored or processed outside South Africa where Vicinity Agency uses cloud-based service providers. Currently, this includes Vercel (website hosting, United States) and, once active and consented to, Google Analytics (United States). Vicinity Agency will only transfer personal information outside South Africa where the recipient is subject to a law, binding agreement, or other arrangement providing an adequate level of protection, consistent with POPIA.

8.5 Security measures

Vicinity Agency implements reasonable technical and organisational measures to protect the confidentiality, integrity, and availability of personal information under its control, including access controls and password protection, restricted access to personal information on a need-to-know basis, antivirus and anti-malware protection, and regular data backups.

9. Availability of this manual

A copy of this manual is available:

On Vicinity Agency's website: vicinityagency.com
At Vicinity Agency's head office, for public inspection during normal business hours
To any person on request, subject to payment of the prescribed fee for a physical copy
To the Information Regulator, on request

A fee for a printed copy of this manual, as prescribed under the PAIA Regulations, is payable per A4-size photocopy. Electronic copies (e.g. via the website) are provided free of charge.

10. Updating this manual

Vicinity Agency will review and update this manual on a regular basis, and whenever there is a material change to the categories of records held, how personal information is processed, or contact details.

Issued by:

Claudia Ann Freese Founder & Director, Vicinity Agency Pty Ltd

Note: this manual follows the Information Regulator's official private-body PAIA manual template. Before publishing, please fill in the bracketed placeholders (Cameron's email, second official language for the Guide, and specific cross-border service providers) and have it reviewed alongside the other three legal pages by a South African attorney — the categories of records and data flows above are drafted from typical agency operations and should be checked against how Vicinity Agency actually works.