Legal · Access to information
Manual of TheUmbrella (Pty) Ltd prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA), read with the Protection of Personal Information Act 4 of 2013 (POPIA).
At a glance
Private body
TheUmbrella (Pty) Ltd, Reg. No. 2026/771931/07, trading as theUmbrella and SBS.
Information Officer
Etienne Botha, Director · hello@theumbrella.co.za
To request a record
Complete the Regulator's Form 2, send it to the Information Officer and pay the R140 request fee. We respond within 30 days.
Wilderpass
The Wilderpass platform publishes its own PAIA manual. Requests about Wilderpass records are directed under that manual.
01 · Introduction
The Promotion of Access to Information Act 2 of 2000 (PAIA) gives effect to the constitutional right of access to any information held by the State, and to information held by another person that is required for the exercise or protection of any right. Section 51 of PAIA requires every private body to compile a manual explaining how a person may request access to the records it holds.
This manual is published by TheUmbrella (Pty) Ltd (registration number 2026/771931/07), a private company incorporated in the Republic of South Africa ("theUmbrella", "the company", "we"). It covers the company and the products it operates directly, including SBS, its security review service for software businesses.
Wilderpass, the online booking platform for outdoor experiences within the theUmbrella group, processes a distinct set of records (guests, operators, bookings and held funds) and publishes its own PAIA manual. Where a request concerns Wilderpass records, the Wilderpass manual applies and the request is handled under it. Where it is unclear which manual applies, send the request to the Information Officer named below, who will direct it.
This manual also contains the information that section 51 of PAIA, as amended by POPIA, requires about the processing of personal information by the company.
02 · Section 51(1)(a)
The head of a private body is its Information Officer under PAIA and POPIA. The company's Information Officer and the details for lodging a request are:
Private body
TheUmbrella (Pty) Ltd
Registration number 2026/771931/07
Street address: 128 Kommissaris Street, Welgemoed, Bellville, Western Cape, 7530
Postal address: 128 Kommissaris Street, Welgemoed, Bellville, Western Cape, 7530
Website: www.theumbrella.co.za
Information Officer
Etienne Botha, Director
Email: hello@theumbrella.co.za
Telephone: +27 71 485 4012
Registered with the Information Regulator as Information Officer of TheUmbrella (Pty) Ltd.
Deputy Information Officer
None designated at the date of this manual. The Information Officer handles all requests. If a deputy is designated, this section will be updated and the designation registered with the Information Regulator.
Requests under PAIA, and questions about personal information under POPIA, must be sent to the Information Officer at the email or postal address above. Please mark the subject line "PAIA request" or "POPIA request" so that it is routed to the Information Officer without delay.
03 · Section 51(1)(b)
The Information Regulator has compiled a Guide, in terms of section 10 of PAIA, in each official language, to help any person who wishes to exercise a right under PAIA or POPIA. The Guide explains the objects of both Acts, the contact details of information officers, how to lodge a request and the fees, the remedies available if a request is refused, and how to lodge a complaint with the Regulator.
The Guide is available free of charge from the Regulator:
Information Regulator (South Africa)
Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191
Telephone: 010 023 5200 · Toll-free: 0800 017 160
Website: inforegulator.org.za
General enquiries: enquiries@inforegulator.org.za
PAIA complaints: PAIAComplaints@inforegulator.org.za
POPIA complaints: POPIAComplaints@inforegulator.org.za
The Guide can also be inspected at the company's office during business hours on request to the Information Officer.
04 · Section 51(1)(c) and 52(2)
The following records are available without a person having to request access under PAIA. No fee is charged for records accessed on the website.
The company has not, at the date of this manual, published a notice under section 52(2) of PAIA. If it does, the notice will be referenced here.
05 · Section 51(1)(d)
Where a person is entitled to a record under another law, access is given under that law and this manual does not apply to it. Records held by the company under the following legislation (where applicable to the company) may be requested by persons entitled to them under that legislation:
The list is not exhaustive and is read as including the regulations under each Act.
06 · Section 51(1)(e)
The company holds records on the following subjects. Listing a category here does not mean that a record in it will be disclosed; every request is assessed against the grounds for refusal in Chapter 4 of Part 3 of PAIA (see section 10 of this manual).
Records of the Wilderpass platform (guest, operator and booking records, held-funds and payout records processed through Turnstay, and platform operational records) are described in the Wilderpass PAIA manual and are not listed here.
07 · Section 51(1)(c) read with POPIA
The company is a responsible party under POPIA. This section sets out the information that a PAIA manual must contain about the company's processing of personal information. The company's privacy policy, in the Terms & Policies, gives a fuller description.
| Data subjects | Personal information processed |
|---|---|
| Clients and prospective clients (and their staff) | Names, job titles, contact details, company details, correspondence, order and payment records, information contained in systems or documents submitted for review |
| Website visitors and enquirers | Name, company, email address and message submitted via the contact form; technical data such as IP address in server and security logs |
| Employees, contractors and job applicants | Identity and contact details, CVs and qualifications, employment and contract terms, remuneration and banking details, tax details, performance and disciplinary records |
| Suppliers and service providers (and their staff) | Names, contact details, contract and payment details, banking details |
| Directors and shareholders | Identity and contact details, shareholding, statutory and banking details |
Some of the company's service providers host data outside South Africa, including cloud hosting, content delivery, email and AI-assisted tooling used in service delivery. Personal information is transferred only to providers that are bound by contract to a level of protection substantially similar to POPIA, or where another ground in section 72 of POPIA applies. Card payment data is processed by the payment service provider and never held by the company.
The company applies its own Secure Build Standard to its systems and takes appropriate, reasonable technical and organisational measures to protect personal information, including: encryption in transit and at rest; multi-factor authentication and least-privilege access control; centralised logging and alerting; separation of production and non-production environments; secure development and review practices; contractual security obligations on operators; staff confidentiality undertakings; and an incident-response procedure that includes notification to the Regulator and affected data subjects where section 22 of POPIA requires it.
A data subject may request access to, or correction or deletion of, their personal information, or object to its processing, by writing to the Information Officer using the Regulator's prescribed forms (Form 1 for an objection and Form 2 for a correction or deletion request under the POPIA Regulations). A request for access to personal information is handled as a PAIA request under section 8 of this manual, except that no request fee is payable for a data subject's own personal information.
08 · Section 51(1)(f) and 53
Any person may request access to a record of the company if the record is required for the exercise or protection of a right. A requester must identify the right and explain why the record is required to exercise or protect it. A request may also be made on behalf of another person, in which case proof of the capacity in which the request is made must be provided.
A request must be made on the Regulator's prescribed Form 2 (Request for access to record of private body), available from inforegulator.org.za under PAIA forms, or from the Information Officer on request. The form must:
Send the completed form to the Information Officer by email to hello@theumbrella.co.za or by post to the address in section 2. The Information Officer will assist a requester who cannot complete the form because of illiteracy or disability.
A request fee of R140 is payable before the request is processed, unless the requester is asking for their own personal information. Where the request requires more than six hours to search for and prepare the record, the Information Officer may require a deposit of one third of the estimated access fee. See section 9.
The Information Officer will decide on a request as soon as reasonably possible and in any event within 30 days of receiving it, and will notify the requester of the decision in writing. The period may be extended once by up to a further 30 days where the request is for a large number of records, requires a search through many records, or requires consultation with a third party, in which case the requester is notified of the extension and the reasons for it. If no decision is communicated within the period, the request is deemed refused.
Where a request concerns a record containing information about a third party (including a client's confidential information or another person's personal information), the company must notify that third party and allow them to make representations before deciding on the request, as required by Chapter 5 of Part 3 of PAIA.
If access is granted, the record is made available in the form requested where reasonably possible, on payment of the applicable access fee and, where relevant, postage. Access is given electronically wherever practicable.
09 · Section 54 and the PAIA Regulations
Fees are prescribed in the Regulations published under PAIA (Annexure B, as amended from time to time) and published by the Information Regulator in its PAIA fee structure. The amounts below reflect the fee structure in force at the date of this manual; where the regulations change, the regulated amounts apply. All amounts are inclusive of VAT.
| Item | Fee |
|---|---|
| Request fee (private body) | R140.00 |
| Photocopy or printed black-and-white copy of an A4 page or part thereof | R2.00 per page |
| Copy in computer-readable form on a flash drive or compact disc provided by the requester | R40.00 |
| Copy in computer-readable form on a compact disc provided by the company | R60.00 |
| Transcription or copy of visual images | Outsourced; service provider's quotation |
| Transcription of an audio record, per A4 page or part thereof | R24.00 |
| Copy of an audio record on a flash drive or compact disc provided by the requester | R40.00 |
| Copy of an audio record on a compact disc provided by the company | R60.00 |
| Search and preparation of a record for disclosure, for each hour or part of an hour after the first hour, to a maximum of R435.00 | R145.00 per hour |
| Deposit, where search and preparation will exceed six hours | One third of the estimated access fee |
| Postage, courier, email or other electronic transfer | Actual cost, if any |
No request fee is payable for a data subject's own personal information. A record provided by email carries no reproduction fee. The company may waive a fee where the cost of collecting it would exceed the amount.
10 · Section 51(1)(f) and Chapter 4 of Part 3
The company must refuse access to a record, or may refuse it, on the grounds set out in sections 62 to 70 of PAIA, including where disclosure would:
Access must nevertheless be granted where disclosure would reveal evidence of a substantial contravention of the law or an imminent and serious public-safety or environmental risk, and the public interest in disclosure clearly outweighs the harm (section 70). Where a record contains some information that may be refused, the remainder is severed and disclosed where reasonably possible (section 59).
PAIA does not provide for an internal appeal against a decision of a private body. A requester, or a third party, who is dissatisfied with a decision of the Information Officer (including a refusal, a fee, an extension or the form of access) may:
11 · Section 51(3) and Regulation 7
This manual is available:
Copies may be requested from the Information Officer, who may charge the prescribed reproduction fee for printed copies. This manual is available in English; a translation into another official language will be considered on request.
The manual is reviewed at least once a year and whenever the company's contact details, products, categories of records or processing of personal information change materially. The effective date and version appear at the top of the manual.
Approved by
Etienne Botha, Director and Information Officer
TheUmbrella (Pty) Ltd · 27 October 2026 · Version 1.0