1. About this manual

1.1Blydex (Pty) Ltd ("Blydex") publishes this manual under section 51 of the Promotion of Access to Information Act 2 of 2000 ("PAIA"). It also records how Blydex processes personal information, as section 51(1)(c) of PAIA and section 17 of the Protection of Personal Information Act 4 of 2013 ("POPIA") require.

1.2The manual explains what records Blydex keeps, how to ask for them, what it costs, and what rights a person has over their personal information. The forms needed to exercise those rights are attached as Annexures A to F.

1.3Where this manual summarises the law it does so in plain terms. PAIA, POPIA and their regulations prevail over anything said here.

1.4This manual replaces the manual dated 23 October 2026.

2. Contact details

2.1Blydex is a private company. Its street and postal address is 38 Lebombo Road, Ashlea Gardens, Pretoria, 0081. Its telephone number is 083 424 2444, its email address is info@blydex.co.za and its website is www.blydex.co.za.

2.2Blydex provides services in accounting, labour, corporate services, compliance and risk, and immigration and visas.

3. Information Officer

3.1The head of Blydex is its sole director, Soren Burkal Nielsen, who is its Information Officer under PAIA and POPIA. Alan Buttle is its Deputy Information Officer under section 56 of PAIA and section 56 of POPIA. Both are registered with the Information Regulator under registration number 2026-005361.

3.2Every request for access to a record, and every request, objection or complaint about personal information, goes to the Information Officer at info@blydex.co.za or the Deputy Information Officer at alan@blydex.co.za, on 083 424 2444, or by hand or post at the address in clause 2.1.

4. The Information Regulator and its guide

4.1The Information Regulator has published a guide under section 10 of PAIA on how to use PAIA and POPIA. It is available free of charge in each official language from the Information Regulator, and may be inspected at Blydex's office during office hours.

4.2A copy of the guide may be asked for from the Information Officer on the form at Annexure C.

4.3The Information Regulator's contact details are: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191; telephone 010 023 5200 and toll free 0800 017 160; general enquiries enquiries@inforegulator.org.za; PAIA complaints PAIAComplaints@inforegulator.org.za; POPIA complaints POPIAComplaints@inforegulator.org.za; website www.inforegulator.org.za.

5. Records available without a request

5.1No notice has been published under section 52(2) of PAIA listing records of Blydex that are automatically available.

5.2The following may be obtained without a formal request: this manual, Blydex's privacy policy, its website terms of use, the information on its website, its marketing material, and its company records filed with the Companies and Intellectual Property Commission, which are obtainable from that Commission.

6. Records kept under other laws

6.1Blydex keeps records under the following laws, to the extent each applies to it:

6.1.1the Companies Act 71 of 2008;

6.1.2the Income Tax Act 58 of 1962, the Value-Added Tax Act 89 of 1991 and the Tax Administration Act 28 of 2011;

6.1.3the Basic Conditions of Employment Act 75 of 1997, the Labour Relations Act 66 of 1995 and the Employment Equity Act 55 of 1998;

6.1.4the Unemployment Insurance Act 63 of 2001 and the Unemployment Insurance Contributions Act 4 of 2002;

6.1.5the Compensation for Occupational Injuries and Diseases Act 130 of 1993;

6.1.6the Immigration Act 13 of 2002;

6.1.7the Electronic Communications and Transactions Act 25 of 2002;

6.1.8the Consumer Protection Act 68 of 2008; and

6.1.9PAIA and POPIA.

6.2A requester who relies on a right of access under another law should say so in the request.

7. Records Blydex holds

7.1Blydex holds the following categories of records. That a record falls within a category does not mean that access will be given. Each request is decided on its merits and against the grounds in clause 10.

7.1.1Company records: the memorandum of incorporation, registers of shareholders and directors, share certificates, resolutions and filings with the Companies and Intellectual Property Commission.

7.1.2Financial and tax records: financial statements, accounting records, bank records, invoices and tax returns.

7.1.3Personnel records: employment and contractor agreements, payroll, leave records and statutory returns.

7.1.4Client records: proposals, engagement letters, correspondence, documents supplied by clients and the work delivered to them.

7.1.5Visa matter records: applications, supporting documents and correspondence with the Department of Home Affairs, South African missions and their visa facilitation agents.

7.1.6Supplier and contract records: agreements with suppliers and service providers.

7.1.7Website and marketing records: enquiries received through the website, marketing material and records of consent to marketing.

8. How to request access

8.1A request is made on Form 2 of the PAIA Regulations, 2021, attached as Annexure A, and sent to the Information Officer by email, by post or by hand.

8.2The requester must attach proof of identity, identify the record, say in what form and manner access is wanted, give an address or email address in South Africa, and state which right the requester seeks to exercise or protect and why the record is needed for it, as section 53(2) of PAIA requires. A private body may only be required to release a record that is needed to exercise or protect a right.

8.3A person who asks on behalf of another must state the capacity in which the request is made and attach proof of it.

8.4A requester who cannot complete the form because of illiteracy or disability may make the request orally. The Information Officer will write it down and give the requester a copy.

8.5Blydex decides a request within 30 days of receiving it, under section 56 of PAIA, and tells the requester in writing on Form 3, attached as Annexure B. It may extend that period once, by up to 30 days, under section 57 of PAIA, and tells the requester in writing of the extension and the reasons for it. A request not decided in time is treated as refused under section 58 of PAIA.

8.6Where only part of a record may be released, Blydex removes the part that may not be released and gives access to the rest, under section 59 of PAIA.

8.7Where a record cannot be found or does not exist, Blydex tells the requester by affidavit or affirmation setting out the steps taken to find it, under section 55 of PAIA. That notice is treated as a refusal. If the record is later found, the requester is given access unless a ground in clause 10 applies.

8.8Where a record concerns a third party, Blydex notifies the third party within 21 days under section 71 of PAIA. The third party may make representations within 21 days of the notice, and Blydex then decides the request within 30 days and informs both the third party and the requester.

9. Fees

9.1Two fees arise. A request fee of R140,00 is payable before a request is processed. A requester asking for a record of their own personal information pays no request fee. An access fee is payable once access is granted, and covers reproduction, search and preparation.

9.2The access fee is made up of the following items:

9.2.1a photocopy or printed copy of an A4 page, or part of a page, R2,00;

9.2.2a copy on a flash drive supplied by the requester, R40,00, on a compact disc supplied by the requester, R40,00, and on a compact disc supplied by Blydex, R60,00, the same amounts applying to a copy of an audio record;

9.2.3a transcription of an audio record, R24,00 for each A4 page;

9.2.4a transcription or copy of visual images, at the amount quoted by the service provider to whom the work is outsourced;

9.2.5search and preparation, R145,00 for each hour or part of an hour after the first hour, up to R435,00; and

9.2.6postage, email or other electronic transfer, at actual cost.

9.3Where the search and preparation will take more than six hours, Blydex may ask for a deposit of one third of the access fee before it starts. The deposit is refunded if access is refused.

9.4Personal inspection of a record at Blydex's office is free. Blydex may withhold a record until the fees payable have been paid.

9.5These are the fees prescribed for private bodies at the date of this manual. If the prescribed fees change, the prescribed fees apply, and the amount payable is stated on Form 3.

10. Grounds for refusing access

10.1Blydex may or must refuse access on the grounds in Chapter 4 of Part 3 of PAIA, which are:

10.1.1unreasonable disclosure of personal information about a third party, including a deceased person, under section 63;

10.1.2the trade secrets, or the financial, commercial, scientific or technical information, of a third party, where disclosure would likely cause it harm, under section 64;

10.1.3information supplied in confidence, where disclosure would breach a duty of confidence owed to a third party, under section 65;

10.1.4information whose disclosure could endanger the life or physical safety of a person, or the security of property, under section 66;

10.1.5records privileged from production in legal proceedings, under section 67;

10.1.6Blydex's own trade secrets, commercially sensitive information and computer programs, under section 68; and

10.1.7research information of Blydex or a third party, where disclosure would seriously disadvantage the research, under section 69.

10.2Access must still be given where section 70 of PAIA applies, being where disclosure would reveal a substantial contravention of the law or an imminent and serious risk to public safety or the environment, and the public interest clearly outweighs the harm.

11. Remedies if a request is refused

11.1Blydex has no internal appeal. The internal appeal on Form 4 of the PAIA Regulations applies only to public bodies.

11.2A requester, or a third party, who is unhappy with a decision may complain to the Information Regulator within 180 days of the decision under sections 77A and 77B of PAIA, on the Information Regulator's complaint form (Form 5 of the PAIA Regulations), which is available on its website.

11.3An application to court under section 78 of PAIA may be brought only after the complaint procedure in section 77A has been exhausted.

12. How Blydex processes personal information

12.1Blydex processes personal information to provide its services; to enter into and manage engagements; to verify the identity of clients and their representatives; to prepare and submit visa applications; to invoice and collect fees; to recruit, employ and pay its people; to comply with the law; to run its website; and to market its services where the law allows.

12.2Blydex processes personal information about the following people:

12.2.1clients and their directors, shareholders, employees and representatives: names, identity and registration numbers, contact details, financial, tax and company records, and correspondence;

12.2.2visa applicants and their family members: identity and passport details, nationality, marital status, birth and marriage records, employment, qualification and financial records, police clearance certificates and medical and radiological reports;

12.2.3employees, applicants for employment and contractors: identity, contact, banking, tax, payroll and qualification details, and next of kin;

12.2.4suppliers and service providers: names, contact, tax and banking details of the business and its representatives; and

12.2.5website users and subscribers: the details they submit, their marketing preferences, and technical information such as browser type and IP address.

12.3Police clearance certificates, which concern criminal behaviour, and medical reports, which concern health, are special personal information under section 26 of POPIA. Blydex processes them only with the data subject's consent under section 27(1)(a) of POPIA, only for the visa application concerned, and only by those who need them for that application.

12.4A visa application may include the personal information of a child. Blydex processes it only with the prior consent of a parent or guardian under section 35(1)(a) of POPIA, and only for the application concerned.

12.5Blydex shares personal information only where the purpose requires it, with the Department of Home Affairs, South African missions abroad and their visa facilitation agents, the Companies and Intellectual Property Commission, the South African Revenue Service, the Department of Employment and Labour, banks, auditors and professional advisers, and with its operators for accounting software, email, cloud storage and website hosting. Operators act under a written agreement as sections 20 and 21 of POPIA require.

12.6Some of Blydex's operators store information on servers outside South Africa, and a visa matter may require information to be sent to a South African mission or foreign authority abroad. Blydex sends personal information outside South Africa only where section 72 of POPIA allows it: where the recipient is bound by law, binding corporate rules or a binding agreement giving adequate protection, where the data subject consents, or where the transfer is necessary to perform a contract with or in the interest of the data subject.

12.7Blydex protects personal information as section 19 of POPIA requires, by taking reasonable technical and organisational measures to prevent its loss, damage, unauthorised destruction and unlawful access. These include individual user accounts with access limited by role, secured and backed up systems, encryption of information in transit, locked storage for paper records, confidentiality undertakings from its people, and written agreements with its operators.

12.8Where there are reasonable grounds to believe that personal information has been accessed or acquired by an unauthorised person, Blydex notifies the Information Regulator and the data subject as soon as reasonably possible, as section 22 of POPIA requires.

12.9Blydex keeps records for as long as the purpose or the law requires, which for company and tax records is generally five to seven years, and then destroys or de-identifies them as section 14 of POPIA requires.

13. Rights of data subjects

13.1A data subject has the right:

13.1.1to be told that personal information is being collected, and that it has been accessed by an unauthorised person;

13.1.2to ask whether Blydex holds personal information about them, and for a record of it, under section 23 of POPIA, which is done by a request under clause 8;

13.1.3to ask for personal information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully to be corrected or deleted, and for a record Blydex may no longer keep to be destroyed, under section 24 of POPIA;

13.1.4to object to processing on reasonable grounds, and to object at any time to processing for direct marketing, under section 11(3) of POPIA;

13.1.5not to receive direct marketing by electronic communication without consent, unless they are an existing client, under section 69 of POPIA;

13.1.6not to be subject to a decision with legal consequences based solely on automated processing, under section 71 of POPIA;

13.1.7to withdraw consent at any time; and

13.1.8to complain to the Information Regulator under section 74 of POPIA, and to bring civil proceedings under section 99 of POPIA.

13.2An objection is made on Form 1 of the POPIA Regulations, attached as Annexure D. A request for correction, deletion or destruction is made on Form 2 of the POPIA Regulations, attached as Annexure E. Both are free of charge and may be sent to the Information Officer by hand, post, email, SMS or WhatsApp. An objection or request made by telephone is recorded, and a transcript is given on request.

13.3Blydex tells the data subject in writing of the action taken on a request for correction, deletion or destruction within 30 days. Where a correction is made and the information has been supplied to a third party, Blydex informs that third party where reasonably practicable. Where a request is refused, Blydex attaches to the record a note that a correction was asked for and not made.

13.4Blydex asks for consent to direct marketing on Form 4 of the POPIA Regulations, attached as Annexure F, or in another written form substantially similar to it. It asks a person who has not consented only once, and a failure to opt out is not consent.

13.5A complaint to the Information Regulator about personal information is made on Form 5 of the POPIA Regulations, which is available on its website, to the contact details in clause 4.3.

14. Availability, review and reporting

14.1This manual is available free of charge on www.blydex.co.za and at Blydex's office during office hours, and by email from the Information Officer. A printed copy is given on request at the copy fee in clause 9.2.1. Blydex gives a copy to the Information Regulator on request.

14.2Blydex reviews this manual at least once a year and whenever its particulars change.

14.3The Information Officer submits Blydex's annual report on requests for access to the Information Regulator in the form and by the date the Information Regulator prescribes.

15. Approval

15.1This manual was approved by the head of Blydex and takes effect on 29 October 2026.