Prepared in terms of Section 51 of the Promotion of Access to Information Act 2 of 2000 (as amended)
PRIVATE BODY:
Harcourts Atlantic (Pty) Ltd
Effective Date: June 2026
Review Date: June 2027
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1. DEFINITIONS AND ABBREVIATIONS
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CEO – Chief Executive Officer
DIO – Deputy Information Officer
Information Officer – Information Officer appointed in terms of POPIA and PAIA
PAIA – Promotion of Access to Information Act 2 of 2000
POPIA – Protection of Personal Information Act 4 of 2013
Regulator – Information Regulator (South Africa)
Company – Harcourts Atlantic (Pty) Ltd
Data Subject – Any natural or juristic person whose personal information is processed
Personal Information – As defined in POPIA
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2. PURPOSE OF THIS MANUAL
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This Manual is published in accordance with Section 51 of PAIA and aims to:
• Explain how requests for access to records may be made.
• Describe records held by the Company.
• Identify records available without a formal PAIA request.
• Describe records available under other legislation.
• Explain how personal information is processed.
• Provide contact details for the Information Officer.
• Promote transparency and accountability.
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3. COMPANY DETAILS
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Company Name: Harcourts Atlantic (Pty) Ltd
Physical Address:
Central Parade
Cnr Camps Bay Drive & Victoria Drive
Camps Bay
Cape Town
Western Cape
7646
Postal Address:
PO Box 4019
Tyger Valley
7538
Telephone: 021 437 0013
Email: atlantic.po@harcourts.co.za
Website: https://Atlantic.harcourts.co.za
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4. INFORMATION OFFICER DETAILS
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Information Officer:
Bronwyn Scholtz
Telephone: 021 437 0013
Email: atlantic.po@harcourts.co.za
Deputy Information Officer:
Eberhard Kruger
Telephone: 021 882 8369
Email: eberhard.kruger@harcourts.co.za
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5. PAIA GUIDE
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The Information Regulator has published a PAIA Guide in terms of Section 10 of PAIA.
The Guide may be obtained from:
Information Regulator (South Africa)
Physical Address:
JD House
27 Stiemens Street
Braamfontein
Johannesburg
2001
Website: www.inforegulator.org.za
Email: PAIACompliance@inforegulator.org.za
The Guide explains:
• The purpose of PAIA.
• How to submit requests.
• Applicable fees.
• Available remedies.
• Complaint procedures.
• Access to records under PAIA and POPIA.
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6. RECORDS AVAILABLE WITHOUT FORMAL REQUEST
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The following records may be made available without a formal PAIA request, subject to operational requirements:
• Company brochures and marketing materials.
• Public property listings.
• Public website content.
• General service information.
• Employment opportunities advertised publicly.
• Published policies intended for public access.
• Consumer guides and educational materials.
• Publicly available media releases.
Access may be requested by contacting the Information Officer.
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7. RECORDS AVAILABLE IN TERMS OF OTHER LEGISLATION
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The Company maintains records in accordance with, among others:
• Companies Act 71 of 2008.
• Income Tax Act 58 of 1962.
• Tax Administration Act 28 of 2011.
• 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.
• Skills Development Act 97 of 1998.
• Unemployment Insurance Act 63 of 2001.
• Compensation for Occupational Injuries and Diseases Act 130 of 1993.
• Occupational Health and Safety Act 85 of 1993.
• Financial Intelligence Centre Act 38 of 2001.
• Property Practitioners Act 22 of 2019.
• Consumer Protection Act 68 of 2008.
• Electronic Communications and Transactions Act 25 of 2002.
• Protection of Personal Information Act 4 of 2013.
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8. RECORDS HELD BY THE COMPANY
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8.1 Corporate Records
• Memorandum of Incorporation.
• Company registrations.
• Shareholder records.
• Director records.
• Statutory registers.
• Board resolutions.
8.2 Financial Records
• Annual financial statements.
• Accounting records.
• Tax returns.
• VAT records.
• Banking records.
• Audit reports.
8.3 Human Resources Records
• Employment contracts.
• Payroll records.
• Leave records.
• Disciplinary records.
• Recruitment records.
• Training records.
• Performance management records.
8.4 Property and Real Estate Records
• Mandates.
• Listing agreements.
• Offer to Purchase documentation.
• Lease agreements.
• Property inspection reports.
• Property marketing records.
• Client correspondence.
• Transaction records.
8.5 Compliance Records
• FICA documentation.
• Risk management records.
• POPIA compliance records.
• PAIA records.
• Internal policies and procedures.
8.6 Information Technology Records
• User access logs.
• Security records.
• System audit trails.
• Backup records.
• Software licensing records.
8.7 Customer Records
• Client onboarding records.
• Identity verification documents.
• Contact information.
• Transaction histories.
• Service records.
• Complaints and dispute records.
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9. PROCESSING OF PERSONAL INFORMATION
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9.1 Purpose of Processing
The Company processes personal information for:
• Property sales and rentals.
• Client relationship management.
• Contract administration.
• Employee administration.
• Financial management.
• Regulatory compliance.
• FICA compliance.
• Marketing (where lawful).
• Risk management.
• Security and fraud prevention.
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9.2 CATEGORIES OF DATA SUBJECTS
Employees
Information Processed:
Identity information, contact details, banking details, employment records, qualifications, payroll information.
Property Sellers
Information Processed:
Identity information, contact details, property ownership information, banking details, transaction records.
Property Buyers
Information Processed:
Identity information, contact details, financial information, transaction records.
Landlords
Information Processed:
Identity information, contact details, banking information, property information.
Tenants
Information Processed:
Identity information, contact details, employment details, credit information, banking information.
Service Providers
Information Processed:
Business information, contact information, contractual information.
Website Users
Information Processed:
IP addresses, cookies, online usage information.
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9.3 RECIPIENTS OF PERSONAL INFORMATION
Personal information may be shared with:
• Property practitioners and brokers.
• Attorneys and conveyancers.
• Banks and financial institutions.
• Credit bureaus where lawful.
• Regulatory authorities.
• Government departments.
• Auditors and professional advisors.
• Information technology service providers.
• Harcourts franchise and support entities where required.
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9.4 CROSS-BORDER TRANSFERS
Personal information may be transferred outside South Africa where:
• Required for legitimate business purposes.
• Appropriate safeguards are in place.
• Binding corporate rules apply.
• Contractual protections exist.
• POPIA requirements are satisfied.
Certain Harcourts support services may involve secure cloud-based infrastructure located outside South Africa.
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9.5 INFORMATION SECURITY
The Company maintains reasonable technical and organisational measures including:
• Access control systems.
• Password management.
• Multi-factor authentication.
• Data encryption.
• Firewalls.
• Anti-malware protection.
• Physical access controls.
• Staff confidentiality obligations.
• Secure document storage.
• Data backup procedures.
• Incident response processes.
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10. REQUEST PROCEDURE
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Requests for access to records must:
• Be submitted on the prescribed PAIA request form.
• Provide sufficient detail to identify the requested record.
• Specify the right sought to be exercised or protected where applicable.
• Include proof of identity where necessary.
Requests should be directed to the Information Officer.
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11. FEES
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Fees prescribed under PAIA Regulations may apply.
Applicable fees will be communicated to requesters before processing where required by law.
The Company reserves the right to request payment of prescribed fees before providing access.
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12. GROUNDS FOR REFUSAL
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Access may be refused in accordance with PAIA, including where disclosure would involve:
• Personal privacy violations.
• Commercially confidential information.
• Confidential third-party information.
• Legally privileged information.
• Security risks.
• Information protected by law.
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13. AVAILABILITY OF THE MANUAL
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This Manual is available:
• On the Company's website.
• At the Company's offices during business hours.
• Upon written request to the Information Officer.
• From the Information Regulator where applicable.
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14. UPDATING OF THE MANUAL
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This Manual will be reviewed periodically and updated whenever:
• Legislative requirements change.
• Business operations materially change.
• Information Officer details change.
• New categories of records are introduced.
Approved by:
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Bronwyn Scholtz
Information Officer
Harcourts Atlantic (Pty) Ltd
Date: 09 JUNE 2026