PAIA manual – HEGEMONIKON (PTY) LTD
Date of this manual: 10 November 2026
1. Introduction
This manual is published by HEGEMONIKON (PTY) LTD (registration number 2026/590078/07) (‘hegemonikon’, ‘we’ or ‘our’) in terms of section 51 of the Promotion of Access to Information Act, No. 2 of 2000 (‘PAIA’). It explains how to request access to our records and contains the information about our processing of personal information which PAIA requires, read with the Protection of Personal Information Act, No. 4 of 2013 (‘POPIA’).
2. Contact details of the head of hegemonikon
Requests in terms of PAIA and POPIA should be directed to the head of hegemonikon, who is its Information Officer, using the following details.
| Detail | Particulars |
|---|---|
| Postal and street address | 50 Harrington Street, Cape Town |
| Telephone | None |
| Fax | None |
| hello@hegemonikon.co.za (for the attention of the Information Officer) |
3. Guide on how to use PAIA
The Information Regulator has updated and made available the guide on how to use PAIA contemplated in section 10 of PAIA. The guide is available on the Regulator’s website, inforegulator.org.za, and a copy may be obtained from the Regulator or from our Information Officer.
4. Records available without a request
We have not published a notice in terms of section 52(2) of PAIA. Information published on our website, hegemonikon.co.za, may be accessed there without a request.
5. Records available in terms of other legislation
Section 26 of the Companies Act, No. 71 of 2008, entitles any person to inspect and copy our securities register and register of directors, on payment of a fee not exceeding the prescribed maximum.
Holders of our securities, and persons who hold a beneficial interest in them, also have the rights of access set out in section 26(1) of that Act, which include access to our memorandum of incorporation, the records relating to our directors and our annual financial statements.
Section 23 of POPIA entitles a data subject to ask whether we hold personal information about him, her or it, and to request a record or description of that information. These requests are dealt with in terms of PAIA, as described in paragraph 7 below.
6. Subjects and categories of records
| Subject | Categories of records |
|---|---|
| Company administration | Memorandum of incorporation, statutory registers, resolutions and minutes, and records filed with the Companies and Intellectual Property Commission |
| Finance and tax | Accounting records, financial statements, tax returns and assessments, and banking records |
| Clients and prospective clients | Proposals, engagement terms, correspondence, deliverables and invoices, and records and data received from clients in the course of engagements |
| Suppliers and service providers | Agreements, correspondence and invoices |
| Directors, shareholders and personnel | Appointment records, agreements, and remuneration and tax records |
| Information technology | Systems, security and website records |
| Intellectual property | Software code, prompts, agent configurations, methodologies and other work product developed or used by us |
7. How to request access to a record
To request access to a record, a requester must –
- complete Form 2 (Request for Access to Record) of the Regulations relating to the Promotion of Access to Information, 2021, which is available on the Information Regulator’s website;
- submit it to our Information Officer using the details in paragraph 2 above;
- provide sufficient detail to enable the record and the requester to be identified, and state the form of access required;
- identify the right which the requester seeks to exercise or protect, and explain why the record is required for that purpose; and
- where the request is made on behalf of another person, provide proof of the capacity in which it is made.
A request fee is payable, except by a person requesting access to his, her or its own personal information. An access fee may also be payable for the search, preparation and reproduction of a record. All fees are prescribed by those Regulations and published on the Information Regulator’s website. We will notify the requester of any fee payable before processing the request, and may require a deposit.
We will decide on a request within 30 days of receiving it, and may extend that period once, by up to 30 days, in the circumstances set out in section 57 of PAIA. We may refuse access only on the grounds set out in Chapter 4 of Part 3 of PAIA, for example to protect the privacy of a third party or confidential commercial information. A requester who is dissatisfied with our decision may lodge a complaint with the Information Regulator, or apply to court for appropriate relief, within 180 days of the decision.
8. Processing of personal information
Purposes of processing
We process personal information to –
- provide services to our clients, and respond to and correspond with prospective clients;
- design, build, test and operate systems for our clients, including systems which use artificial intelligence, which requires us to process personal information held by our clients on their behalf;
- obtain goods and services from our suppliers;
- administer the company, including its relationships with its directors, shareholders and personnel;
- operate our website and information technology systems and keep them secure; and
- comply with our legal obligations.
Categories of data subjects and personal information
| Data subjects | Personal information |
|---|---|
| Clients and prospective clients, and their representatives | Names, contact details, organisation and role, correspondence, and engagement and billing information |
| Persons whose personal information is held in our clients' records and systems, such as their customers, employees and other contacts | Any personal information in the records and systems to which we are given access in the course of an engagement, which may include special personal information and the personal information of children. We process this information as an operator on behalf of the client concerned, which remains the responsible party. |
| Website visitors | IP addresses, and device and request information |
| Suppliers and service providers, and their representatives | Names, contact details, correspondence, and contractual and banking information |
| Directors, shareholders and personnel | Identity, contact, tax, banking, shareholding and remuneration information |
Recipients of personal information
We may supply personal information, to the extent necessary, to –
- our information technology, cloud computing, artificial intelligence and other service providers, which process it on our behalf in terms of written agreements;
- our professional advisers, such as our accountants, auditors and attorneys;
- our bank, for the purpose of making and receiving payments; and
- the South African Revenue Service, the Companies and Intellectual Property Commission and other public authorities, where the law requires us to do so.
Planned transborder flows
Some of our service providers, including our website hosting provider, our email and customer relationship management service provider and the providers of the artificial intelligence services which we use, store or process personal information outside South Africa. We transfer personal information outside South Africa only where section 72 of POPIA permits it.
Security measures
We protect personal information by restricting access to those who need it, using multi-factor authentication on our systems, encrypting data in transit, and using service providers which are bound by written agreements to maintain appropriate security safeguards.
9. Availability of this manual
This manual is available on our website and for inspection at our address during normal business hours. A copy may also be obtained from our Information Officer, and will be provided to the Information Regulator on request.