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PAIA Manual

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

Version 1, 5 October 2026. This manual is published for a private body. It is not legal advice. It aligns with the Information Regulator’s PAIA Manual Template for a Private Body and current guidance on inforegulator.org.za.

1. Introduction

The Promotion of Access to Information Act 2 of 2000 (“PAIA”) gives effect to the constitutional right of access to information. This Manual helps members of the public understand what records Emthunzini Financial Services holds and how to request access. It also includes information required under the Protection of Personal Information Act 4 of 2013 (“POPIA”).

Our Privacy Notice is available at privacy-notice.html.

2. Company details (private body)

EFS distributes funeral cover (including Legacy Shield) underwritten via Anayasure Underwriting Managers (FSP 52695).

3. Information Officer and Deputy Information Officer

PAIA requests (Form 2) and POPIA data-subject requests should be sent to the Information Officer at the email addresses above.

4. Guide on how to use PAIA (section 10 Guide)

The Information Regulator has compiled a Guide on how to use PAIA, in terms of section 10 of PAIA. The Guide is available from the Information Regulator in the official languages and explains how to request access to records, the forms to use, and remedies available.

You may also request a copy of the Guide from our Information Officer using the Regulator’s prescribed form (Form 1 under the PAIA Regulations).

5. Categories of records held by EFS

The following categories describe records that EFS may hold. Listing a category does not mean that access will be granted; each request is assessed under PAIA (including grounds for refusal) and POPIA where personal information is involved.

5.1 Company / statutory records

5.2 Financial and accounting records

5.3 Client and policyholder records

5.4 Marketing, website and lead records

5.5 Legacy Connect Community Member / Partner records

5.6 Human resources and internal records

5.7 Information technology and security records

6. Records available without a formal PAIA request

The following information is generally available without submitting Form 2 (subject to any stated conditions):

No further categories have been published under section 52 at the date of this manual. The Information Officer will update this section if additional categories are made automatically available.

7. Records available in accordance with other legislation

EFS may hold records required under legislation including (without limitation):

In addition to PAIA and POPIA, records may be held under (among others): the Financial Advisory and Intermediary Services Act 37 of 2002 and subordinate notices; the Long-term Insurance Act 52 of 1998 and Policyholder Protection Rules; the Insurance Act 18 of 2017; the Financial Sector Regulation Act 9 of 2017; the Medical Schemes Act 131 of 1998 (where we act as a broker); the Consumer Protection Act 68 of 2008; the Electronic Communications and Transactions Act 25 of 2002; the Companies Act 71 of 2008; the Financial Intelligence Centre Act 38 of 2001 (to the extent applicable); the Promotion of Access to Information Act 2 of 2000; tax legislation; and employment laws where we have staff. This list is not exhaustive.

8. How to request access (Form 2)

To request a record of this private body:

  1. Complete the prescribed Form 2 – Request for Access to Record (Regulation 7), available from the Information Regulator: https://inforegulator.org.za/paia-forms/ (or the PAIA Forms section at inforegulator.org.za/paia).
  2. Submit Form 2 to the Information Officer by email to thulasizwen@emthunzinifs.co.za (copy compliance@emthunzinifs.co.za), or by hand / post to 35 Newquay, New Redruth, Alberton, 1449, or by another method the Information Officer accepts in writing.
  3. Attach proof of identity. If you request on behalf of another person, attach proof of authorisation.
  4. Describe the record sufficiently for us to identify it, state the form of access required, and (for a private body) identify the right you wish to exercise or protect and why the record is required for that purpose.
  5. Pay any prescribed request fee and, if applicable, deposit / access fees (see section 9).

We will acknowledge receipt and decide the request within the time periods in PAIA (generally 30 days, which may be extended once by a further 30 days on the grounds in the Act). You will be notified of the outcome using the prescribed Form 3 where applicable.

9. Fees

Fees payable for PAIA requests to a private body are the prescribed fees set out in the PAIA Regulations (including Annexure B), as updated from time to time by the Minister / published by the Information Regulator. They typically include:

We do not invent or vary the prescribed tariffs. The current schedule is available from the Information Regulator. Before processing a non-personal request, we may require payment of the request fee. Where search and preparation will take longer than the prescribed hours, a deposit of up to one-third of the estimated access fee may be required.

Payment details for fees: To be confirmed by the Director (Finance). Until published, ask the Information Officer for the current bank account details and the reference format (for example “PAIA-[your surname]-[date]”). Do not pay a fee until you have those details in writing from EFS.

10. Grounds for refusal

Access to a record may be refused on the grounds in Chapter 4 of Part 3 of PAIA, including (where applicable) where disclosure would involve:

Mandatory disclosure provisions in PAIA may still require disclosure in the public interest in defined cases. Where only part of a record is refused, the remainder may be severed and disclosed where reasonably possible.

11. Remedies

EFS is a private body. There is no internal appeal process under PAIA equivalent to that for certain public bodies. If a request is refused, partially refused, or not responded to within the statutory period, you may:

Information Regulator contacts (verified on inforegulator.org.za at drafting): Tel 010 023 5200 / Toll free 0800 017 160; enquiries@inforegulator.org.za; Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191.

12. POPIA processing information (section 51 read with POPIA)

In line with the Information Regulator’s private-body template, the following summarises POPIA-related information. Full detail is in our Privacy Notice.

12.1 Purpose of processing

We process personal information to provide financial services and funeral-cover distribution, administer policies and claims, operate our website / Smart Compare / Legacy Connect, manage Community Members, handle leads and marketing (where lawful), meet FAIS and other legal duties, and secure our systems.

12.2 Categories of data subjects

Clients and policyholders (and nominated family members / beneficiaries / claimants); website and Smart Compare users; WhatsApp and other leads; Legacy Connect Community Members / Partners; employees and FAIS representatives (where appointed); and service-provider contacts.

12.3 Categories of personal information

Identity and contact details; financial and banking details for premiums or rewards; policy and claims information; communication and consent records; technical / cookie data; and, where necessary, special personal information such as health information for medical-aid matching or claims.

12.4 Recipients / categories of recipients

Anayasure Underwriting Managers (FSP 52695) and insurers; the Legacy Connect platform provider / developer (Eddie Digital Solutions / developer legal entity name to be confirmed by the Director); IT, hosting, communications and professional service providers acting as operators; regulators and ombuds; and other parties where required or permitted by law or with your instruction.

12.5 Planned transborder flows

Personal information may be transferred outside South Africa where our operators host or process data in other countries, subject to POPIA section 72 safeguards. Specific countries and cloud regions are to be confirmed by the Director / IT and listed once verified.

12.6 Information security measures

Reasonable technical and organisational measures are applied as required by POPIA section 19, including access controls, operator agreements, and incident-response processes. Detail appropriate for public disclosure is kept at a high level to avoid undermining security.

13. Availability of this Manual

In terms of section 51(3) of PAIA, this Manual is available:

14. Updates

The head of the private body / Information Officer will update this Manual on a regular basis. The version date appears at the top of this page.

15. Contact

Information Officer: Mr Thulasizwe Nyandeni — thulasizwen@emthunzinifs.co.za / compliance@emthunzinifs.co.za / 087 183 1300.

Emthunzini Consortium (Pty) Ltd t/a Emthunzini Financial Services is an authorised Financial Services Provider (FSP 54028). Underwritten via Anayasure Underwriting Managers (FSP 52695). Illustrative benefits subject to plan terms and conditions. Waiting periods, exclusions and sub-limits apply.

Version 1, 5 October 2026.