Last updated: 12 October 2026

Lema International Trading (Pty) Ltd (“Lema”, “we”, “our”) publishes this manual under section 51 of the Promotion of Access to Information Act 2 of 2000. It describes the records we hold, how to request them, and how we process personal information.

1. Acronyms and terms

  • B-BBEE: Broad-Based Black Economic Empowerment
  • Guide: the Regulator’s Guide on how to use PAIA, issued under section 10 of PAIA
  • Information officer: the person who deals with PAIA and POPIA requests made to Lema
  • PAIA: Promotion of Access to Information Act 2 of 2000, as amended
  • POPIA: Protection of Personal Information Act 4 of 2013
  • Regulations: Regulations relating to the Promotion of Access to Information, 2021 (Government Notice R757, Government Gazette 45057 of 27 August 2021)
  • Regulator: the Information Regulator of South Africa
  • SARS: South African Revenue Service

2. Purpose of this manual

This manual helps you to:

  • see which of our records are available without a formal request;
  • understand the subjects on which we hold records, and the categories of records on each subject, so that you can make a request;
  • know which records we keep under other laws;
  • contact our information officer;
  • find the Regulator’s Guide on how to use PAIA;
  • understand why we process personal information, whose information we process, who receives it, whether it leaves South Africa, and how we protect it.

3. Contact details

Information officer

Warren Ehlers, Managing Director, is the head of Lema under section 1 of PAIA and its information officer under POPIA.

Send requests for records, and questions about this manual, to the information officer.

Head office

4. The Regulator’s Guide on how to use PAIA

Section 10 of PAIA requires the Regulator to publish a Guide on how to use PAIA. The Regulator has updated the Guide for anyone who wants to use a right under PAIA or POPIA, and publishes it in the official languages and in braille.

The Guide explains:

  • the objects of PAIA and POPIA;
  • the contact details of the information officer of every public body, and of every deputy information officer of a public or private body;
  • how to request a record from a public body (section 11 of PAIA) or a private body (section 50 of PAIA);
  • the help available from information officers and from the Regulator;
  • every legal remedy, including how to lodge an internal appeal, a complaint to the Regulator or a court application;
  • the duty of public and private bodies to publish a manual (sections 14 and 51 of PAIA) and how to get a copy;
  • voluntary disclosure of records (sections 15 and 52 of PAIA);
  • the fees for requests (sections 22 and 54 of PAIA) and the regulations made under section 92 of PAIA.

You can get the Guide:

  • on the Regulator’s website;
  • free of charge from our information officer, by asking on Form 1 of the Regulations;
  • at our head office, where copies in at least two official languages are available for inspection during normal business hours.

Contacting the Regulator

5. Records available without a request

You do not need a PAIA request for these records.

On our website

From the information officer

  • Our B-BBEE verification certificate.

6. Records kept under other legislation

We keep records under the laws below. Where one of these laws gives a person a right to see a record, that person may use that right directly. Anyone else may request the record under PAIA.

  • Basic Conditions of Employment Act 75 of 1997: employment contracts, records of time worked and remuneration, and leave records.
  • Broad-Based Black Economic Empowerment Act 53 of 2003: our B-BBEE verification certificate and supporting records.
  • Companies Act 71 of 2008: memorandum of incorporation, registers of directors and securities, minutes and resolutions, and annual financial statements.
  • Compensation for Occupational Injuries and Diseases Act 130 of 1993: registration, assessment and injury records.
  • Consumer Protection Act 68 of 2008: records of goods sold, returns and warranty claims.
  • Electronic Communications and Transactions Act 25 of 2002: records of transactions concluded on our website.
  • Employment Equity Act 55 of 1998: workforce and employment equity records.
  • Income Tax Act 58 of 1962: income tax and employees’ tax records.
  • Labour Relations Act 66 of 1995: disciplinary records.
  • Occupational Health and Safety Act 85 of 1993: health and safety records and incident records.
  • Promotion of Access to Information Act 2 of 2000: this manual and records of requests received.
  • Protection of Personal Information Act 4 of 2013: records of the personal information we process.
  • Skills Development Levies Act 9 of 1999: skills development levy records.
  • Tax Administration Act 28 of 2011: tax records and returns.
  • Unemployment Insurance Act 63 of 2001 and Unemployment Insurance Contributions Act 4 of 2002: unemployment insurance records and contributions.

7. Subjects and categories of records we hold

Records by subject

  • Company and governance: memorandum of incorporation, registration documents, registers of directors and shareholders, minutes, resolutions and annual returns.
  • Finance: annual financial statements, accounting records, management accounts, invoices and credit notes, bank statements, debtor and creditor records, and the asset register.
  • Tax: income tax, employees’ tax, skills development levy and unemployment insurance records, returns and correspondence with SARS.
  • Customers and sales: customer and trade account records, trade account applications, quotations, orders (including orders placed through customers’ procurement systems), invoices, delivery records, customer price lists and product ranges, artwork, logos and proofs for branding, and correspondence and website enquiries.
  • Suppliers and purchasing: supplier agreements, price lists and product data, purchase orders, supplier invoices, delivery records, supplier B-BBEE certificates and correspondence.
  • Products and production: product catalogue data and images, stock records, branding and production job records, and quality records.
  • Employees: employment contracts, personnel files, job applications, remuneration and payroll records, leave records, training records, disciplinary and grievance records, employment equity records, and health and safety records.
  • Website and information technology: website content, customer user accounts, orders and form entries made on the website, system and security logs, software licences and backups.
  • Legal and compliance: contracts and leases, insurance policies, B-BBEE verification records, PAIA and POPIA records, and records of legal matters and disputes.
  • Marketing: catalogues, brochures, photographs, and website and social media content.

A category listed here does not mean a record will be released. Each request is decided under PAIA, including its grounds for refusal.

How to request a record

Under section 50 of PAIA, you have a right of access to a record we hold if you need it to exercise or protect a right, you follow the procedure below, and no ground for refusal applies.

  • Complete the request for access form (Form 2 of the Regulations).
  • Send it to the information officer by e-mail, or deliver it to our head office (section 53(1) of PAIA).
  • Give enough detail for us to identify the record and you, say in which form you want access, give an address or fax number in South Africa for our reply, and explain which right you want to exercise or protect and why you need the record for it (section 53(2) of PAIA).
  • If you are asking on behalf of someone else, include proof of the capacity in which you make the request.

The information officer will help you with your request. If you cannot complete the form because you cannot read or write, or because of a disability, you may make the request orally. The information officer will then complete Form 2 for you and give you a copy (regulation 7 of the Regulations).

Fees

  • The request fee must be paid before we process a request (section 54(1) of PAIA).
  • If we grant access, an access fee applies for copies and for the time needed to search for and prepare the record after the first hour.
  • If the search and preparation will take more than six hours, we will ask for a deposit of up to one third of the access fee (section 54(2) of PAIA). We refund the deposit if we refuse the request (section 54(4) of PAIA).
  • We may withhold a record until the fees are paid (section 54(5) of PAIA).

The amounts set by the Regulations are on the outcome of request and fees page. If you only want to know whether we hold personal information about you, we will confirm this free of charge (section 23 of POPIA).

Our decision

  • We decide within 30 days after receiving the request and the details section 53(2) of PAIA requires (section 56 of PAIA).
  • We may extend this once, by up to 30 days, if the request covers a large number of records, needs a search at another office or needs consultation, or if you agree in writing. We will tell you within the first 30 days, with reasons (section 57 of PAIA).
  • If the record contains a third party’s information, we must notify that party and consider their response before deciding, which can take longer (sections 71 to 73 of PAIA).
  • We give our decision on Form 3 of the Regulations. If we grant access, it states the access fee and the form of access. If we refuse, it gives our reasons.
  • If we do not decide in time, the request is regarded as refused (section 58 of PAIA).

Grounds for refusal

Chapter 4 of Part 3 of PAIA sets out when we must or may refuse access. The main grounds protect:

  • the privacy of a third party who is a natural person (section 63);
  • the commercial information of a third party (section 64) and of Lema (section 68);
  • confidential information of a third party (section 65);
  • the safety of individuals and the protection of property (section 66);
  • records privileged from production in legal proceedings (section 67);
  • research information of a third party or of Lema (section 69).

We must still grant access if the record would reveal a substantial breach of the law or an imminent and serious risk to public safety or the environment, and the public interest clearly outweighs the harm (section 70). If only part of a record is protected, we release the rest (section 59). PAIA does not apply to a record requested for criminal or civil proceedings that have already started, if another law provides for access to it (section 7).

If you disagree with our decision

  • There is no internal appeal against a decision of a private body.
  • You may complain to the Regulator within 180 days of our decision, on Form 5 of the Regulations. This covers a refusal, the fees, an extension of time and the form of access (section 77A of PAIA). A third party may also complain about our decision on a request.
  • Once the complaint procedure is exhausted, you may apply to court within 180 days (section 78 of PAIA).

The Regulator’s contact details are in section 4.

8. Processing of personal information

Why we process personal information

We supply promotional products, corporate gifts, clothing, headwear and workwear, and brand them in-house. We process personal information to:

  • give quotations, take and fulfil orders, brand and deliver goods, and handle returns;
  • open and manage customer accounts, including trade accounts with their own product ranges and prices;
  • receive orders placed through customers’ procurement systems;
  • invoice customers and collect amounts owed to us;
  • answer enquiries made on the website, by e-mail or by phone;
  • buy goods and services from suppliers and manage those relationships;
  • recruit and employ staff, and administer their remuneration and benefits;
  • meet our legal duties, including tax, employment, company law and B-BBEE requirements;
  • keep our website and systems secure, and prevent fraud and misuse;
  • protect our legal rights.

Whose information we process, and what

  • Customers and their staff: names, company names, e-mail addresses, phone numbers, billing and delivery addresses, account log-in details, orders, quotations and saved lists, and artwork and logos supplied for branding. For buyers who order through their organisation’s procurement system: the name, e-mail address and order details that system sends us.
  • People who contact us: name, company, e-mail address, phone number and message.
  • Website visitors: IP address, browser and device information, pages visited, how they arrived at the website, and the cookies needed for the cart and for signing in.
  • Organisations we deal with, such as customer companies, suppliers and service providers: registered names and numbers, tax numbers, addresses, contact people, bank details, B-BBEE status, contracts and transaction records. POPIA protects this information too.
  • Staff of suppliers and service providers: names and contact details.
  • Employees, job applicants and contractors: names, identity numbers, contact details, CVs and qualifications, employment contracts, remuneration, bank details, tax numbers, next of kin, and leave, performance and disciplinary records. Where the law requires it, we also process race, gender, disability and health information, which POPIA treats as special personal information, for employment equity, B-BBEE reporting and sick leave.
  • Directors and shareholders: names, identity numbers, addresses and shareholdings.

Who receives it

We share personal information only as far as a purpose above needs it, with:

  • couriers and transport companies, to deliver orders;
  • suppliers and subcontractors that help us fulfil an order;
  • the organisation a buyer orders for, including through its procurement system;
  • banks, and the online transaction service that processes purchases and refunds on our website;
  • providers that host, maintain, secure and back up our website and IT systems, and that provide our e-mail and business software;
  • our auditors, accountants, legal advisers and insurers;
  • payroll and employee benefit providers, for staff information;
  • SARS, the Department of Employment and Labour, the Companies and Intellectual Property Commission, B-BBEE verification agencies, the Regulator, courts and law enforcement agencies, where the law requires it.

Information sent outside South Africa

Our website and its database are hosted in South Africa. Cloudflare, Inc., a United States company that protects the website and delivers its pages, processes website traffic data, such as IP addresses, browser information and the pages requested, and may do so in data centres outside South Africa, including in the United States. Some of our other service providers, such as e-mail providers, may also process personal information outside South Africa.

We transfer personal information outside South Africa only as section 72 of POPIA allows: for example, where the recipient is bound by a law, binding corporate rules or an agreement that gives protection substantially similar to POPIA, or where the transfer is needed to perform a contract with you.

How we protect it

  • Connections to our website are encrypted (HTTPS).
  • A firewall and malware scanning protect the website, and a content delivery network filters harmful traffic.
  • Customers and staff sign in with their own accounts. Passwords are stored in hashed form, and each user’s role limits what they can see.
  • We keep our software up to date.
  • We back up website data regularly and keep the backups apart from the web server.
  • Only staff and service providers who need personal information for their work can access it, and service providers must keep it confidential and secure (sections 20 and 21 of POPIA).
  • If an unauthorised person gains access to personal information, we notify the Regulator and the people affected, as section 22 of POPIA requires.

Our privacy policy explains how we use personal information and how to exercise your rights under POPIA.

9. Availability of this manual

As section 51(3) of PAIA requires, this manual is available:

  • on our website at www.lema.co.za/paia-manual/;
  • at our head office, for inspection during normal business hours;
  • as a printed copy to anyone who asks, at the copying fee set in the Regulations (see the fees page);
  • to the Regulator on request.

10. Updating this manual

We review this manual regularly and update it when our records, contact details or processing of personal information change (section 51(2) of PAIA). The date at the top of this page shows when it was last updated.