PAIA manual.

2. Purpose of this manual

This manual helps you to:

1. see which of our records you can get without making a formal PAIA request;
2. understand how to ask for a record, by describing the subjects on which we hold records and the kinds of records we hold on each;
3. know which of our records are available under other laws;
4. find the contact details of our Information Officer, who will help you with your request;
5. know about the Regulator’s Guide on how to use PAIA, and how to get a copy;
6. know whether we process personal information, why we do so, whose information it is and what kinds of information it is;
7. know who we may share personal information with;
8. know whether we plan to send or store personal information outside South Africa, and with whom;
9. know whether we have suitable measures to keep personal information confidential, accurate and available.

3. Key contact details

3.1 Head of the private body

Item	Details
Head	Frans van der Berg, director, acting as chief executive officer of VCR Properties (Pty) Ltd
Phone	082 774 6198 (through our Information Officer)
Email	celeste@kyalamicreek.co.za (through our Information Officer)
Postal address	Postnet Suite 155, Private Bag X1028, Lyttelton 0140
Street address	8 Lyndore Avenue, Willaway, Midrand 1684

3.2 Information Officer

Item	Details
Name	Celeste van der Berg, General Manager
Phone	082 774 6198 (also WhatsApp)
Email	celeste@kyalamicreek.co.za
Street address	8 Lyndore Avenue, Willaway, Midrand 1684
Postal address	Postnet Suite 155, Private Bag X1028, Lyttelton 0140

The head, Frans van der Berg, has authorised Celeste van der Berg, in writing, to act as Information Officer. Frans signed the written authorisation on 15 October 2026.

3.3 Deputy Information Officer

There is no Deputy Information Officer at present. Requests go to the Information Officer above.

3.4 General contact for access to information

Item	Details
Email	celeste@kyalamicreek.co.za

3.5 Head office

Item	Details
Company	VCR Properties (Pty) Ltd, trading as Kyalami Creek Luxury Apartments
Registration number	2006/020400/07
VAT number	4890190855
Postal address	Postnet Suite 155, Private Bag X1028, Lyttelton 0140
Physical address	8 Lyndore Avenue, Willaway, Midrand 1684
Phone and WhatsApp	082 774 6198
Email (short stays)	reservations@kyalamicreek.co.za
Email (monthly rentals)	rentals@vcrproperties.co.za
Website	www.kyalamicreek.co.za

4. The Regulator’s Guide to using PAIA

The Information Regulator has updated and published a Guide on how to use PAIA (section 10 of PAIA). It is written to help anyone who wants to use their rights under PAIA and POPIA. It is available in every official language and in braille.

The Guide explains:

• what PAIA and POPIA are for;
• the contact details of the Information Officer of every public body, and of every Deputy Information Officer of public and private bodies;
• how to ask for a record of a public body (section 11) or of a private body (section 50);
• the help available from Information Officers of public bodies, and from the Regulator;
• every legal remedy if a right or duty under PAIA or POPIA is not respected, including internal appeals, complaints to the Regulator and applications to court;
• the duty of public and private bodies to compile a manual (sections 14 and 51), and how to get one;
• records that bodies make available without a request (sections 15 and 52);
• the notices about fees for requests (sections 22 and 54), and the regulations made under section 92.

How to get the Guide:

• ask our Information Officer for a copy (Form 1, the Regulator’s request form can be used);
• download it from the Regulator’s website: the Guide in English (PDF), or other languages on the Regulator’s PAIA guidelines page;
• inspect or copy it at our office or the Regulator’s office during normal office hours.

A copy of the Guide is available at our office for inspection during office hours in English and Afrikaans.

5. Records available without a request

You can get these without filling in a PAIA request form: read them on our website, or ask us by WhatsApp, phone, email or letter.

Category	Types of record	On our website	On request
Company details	Company name, registration number, VAT number, address and contact details	Yes	Yes
Our stays	Apartment descriptions, what is included, “from” prices, check-in times, FAQ and policies	Yes	Yes
Privacy and PAIA	Our privacy notice and this PAIA manual	Yes	Yes
Rentals	Information about renting a home at Kyalami Creek and how to apply	Yes	Yes
Guest information	Guest information booklet and house rules, for booked guests	No	Yes, to guests
Tenant information	Tenant welcome guide and complex rules, for tenants	No	Yes, to tenants

6. Records available under other laws

We keep records that these laws require of a company that lets apartments and homes and employs staff. Where a law gives you a right to see a record, you may ask for it under that law.

Law	Records
Companies Act 71 of 2008	Memorandum of incorporation, registers of directors and shareholders, minutes, annual financial statements
Tax Administration Act 28 of 2011	Tax records and supporting documents
Income Tax Act 58 of 1962	Income tax returns and records, employees’ tax (PAYE) records
Value-Added Tax Act 89 of 1991	VAT invoices, VAT returns and supporting records
Basic Conditions of Employment Act 75 of 1997	Employment contracts, time worked, pay and leave records
Labour Relations Act 66 of 1995	Disciplinary records, and records of strikes, lock-outs and protest action if any
Unemployment Insurance Act 63 of 2001 and Unemployment Insurance Contributions Act 4 of 2002	Records of employees and UIF contributions
Skills Development Levies Act 9 of 1999	Skills development levy records
Occupational Health and Safety Act 85 of 1993	Health and safety records, incident reports, risk assessments and appointments
Compensation for Occupational Injuries and Diseases Act 130 of 1993	Records of employees’ earnings and of injuries on duty
Consumer Protection Act 68 of 2008	Booking terms, quotes and records of our dealings with guests
Rental Housing Act 50 of 1999	Leases, deposit records and inspection reports
Protection of Personal Information Act 4 of 2013	Privacy notice and records of how we process personal information
Promotion of Access to Information Act 2 of 2000	This PAIA manual

7. Subjects and categories of records we hold

We hold records on the following subjects. Holding a record does not mean it will be released: some records are confidential or protect someone else’s privacy, and PAIA sets out when we may or must refuse access.

Subject	Categories of records
Company	Memorandum of incorporation, company registration documents, registers of directors and shareholders, minutes and resolutions, directors’ reports
Finance and tax	Annual financial statements, management accounts, bank statements and reconciliations, invoices, payment records, tax and VAT returns, auditor’s records
Staff	Employment contracts, personal details, payroll and payslips, leave records, tax and UIF records, training, disciplinary records, health and safety records
Guests (short stays)	Enquiries and quotes, bookings, guest details and ID copies, invoices and payments, corporate client details, guest messages, reviews
Tenants (monthly rentals)	Enquiries and applications, vetting results, leases, deposits, rent and arrears records, inspection reports and photos, maintenance requests, access records
Suppliers and contractors	Contracts and quotes, invoices, payment records, bank details, company and VAT details
Security, access and CCTV	Gate visitor records (kept by TRSS, our security company), access codes, tenants’ fingerprints and RFID tag records in the gate access system, CCTV footage of the parking areas, the gym and the gate, incident reports
Buildings	Unit records, maintenance and repair records, insurance, utility accounts, plans and compliance certificates
Website and marketing	Website content, website visit statistics (Google Analytics, with consent), marketing contacts and opt-outs, social media posts, photos

8. How we process personal information

8.1 Why we process personal information

• to take and manage bookings, prepare for each stay and look after our guests;
• to let homes on monthly leases: viewings, applications, vetting, leases, rent and maintenance;
• to invoice, take payments and keep proper accounts and tax records;
• to keep guests, residents, visitors and staff safe, control access to the complex and protect the buildings;
• to employ and pay our staff and meet our duties as an employer;
• to deal with suppliers and contractors;
• to send news and offers to past guests and others who have agreed to receive them;
• to meet our other legal duties.

Our privacy notice explains this for guests and tenants in more detail.

8.2 Whose information, and what kinds

People	Personal information we may process
Guests	Name, ID or passport number and copy, contact details, booking dates, arrival time, parking bay, special requests, messages, payment records, reviews
Corporate clients and bookers	Company name, registration and VAT details, billing details, name and contact details of the person booking
Rental applicants and tenants	Name, ID number and copy, contact details, employment and income information, vetting results, lease details, payment and arrears history, inspection photos, fingerprints (with consent) or RFID tag number
Visitors	Name, vehicle details and contact details recorded at the gate, CCTV images
Staff and job applicants	Name, ID number, contact details, address, qualifications, bank details, tax and UIF numbers, pay, leave and health and safety records
Suppliers and contractors	Business and contact names, registration and VAT numbers, address, bank details
Website visitors	IP address and website use (Google Analytics, only with consent), cookie choice

8.3 Who we may share it with

Information	Recipients
Booking details	Booking channels (NightsBridge, Booking.com, LekkeSlaap, Expedia, TravelIT) and our booking system, Semper
Payment details	Payfast, PayGate, NightsBridge and our bank (FNB)
Corporate booking and invoice details	Our BEE partner company, for corporate bookings made through it
Rental applications and tenant details	Pretor, our current managing agent, and TPN, for vetting
Staff payroll and leave details	Pretor, which runs our payroll and leave for now
Visitor and access details	TRSS, our security company
Financial records	Our accountant and auditor; SARS
Staff tax and UIF details	SARS and the Department of Employment and Labour
Any details, when the law requires it or to protect someone’s safety	The South African Police Service, courts and other authorities

We never sell personal information.

8.4 Information sent or stored outside South Africa

We don’t plan to send personal information abroad except through services we use that store information outside South Africa:

• WhatsApp (Meta), when people message us;
• Google, for email, file storage and, with consent, website statistics (Google Analytics);
• international booking sites, such as Booking.com and Expedia, for bookings made through them;
• NightsBridge, our online booking system, whose privacy policy says it may send or store personal information outside South Africa.

This may include contact details, booking details and the content of messages. POPIA (section 72) allows it where the recipient is bound by similar protection, where it is needed for the booking, or with consent.

8.5 How we keep personal information secure

• Only the people who need information for their work can see it.
• Our systems and email accounts are protected with passwords, and our website runs on secure (HTTPS) connections.
• Our office computers have anti-virus software, and sensitive files on them are kept in an encrypted, password-protected folder. Our Google accounts need two-step sign-in with an authenticator app.
• We don’t take card numbers or ID copies by phone, WhatsApp, email or website forms; card payments are made on the payment providers’ own secure pages or on our card machine.
• Paper records, such as copies of ID documents and card machine slips, are kept in the office where only our team can reach them, and shredded when we no longer need to keep them.
• If we believe personal information has been accessed by someone who shouldn’t have it, we tell the people affected and the Regulator as soon as reasonably possible.

8.6 How long we keep records

Record	How long we keep it
Bookings, invoices, payments and other financial and tax records	7 years (the Companies Act requires 7 years for accounting records; tax law, at least 5 years)
Guest ID copies	12 months after check-out, unless needed for an incident or a claim
Guest registration cards	3 years after check-out, unless needed for an incident or a claim
Enquiries that don’t become bookings	12 months
Gate visitor records	12 months
CCTV footage	30 days, unless needed for an incident
Tenants’ fingerprints	Removed within 30 days after the tenant moves out
Rental applications that don’t go ahead	3 months
Leases, inspections and tenant files	3 years after the lease ends (the financial parts, 7 years)
Marketing contacts	Until they opt out

When we no longer need a record, we delete or destroy it securely, or remove anything that identifies a person.

9. Where to find this manual

This manual is available:

• on our website, at www.kyalamicreek.co.za/paia-manual/;
• at our office, 8 Lyndore Avenue, Willaway, Midrand, for anyone to read during office hours (usually Monday to Friday, 07:30 to 16:30);
• to anyone who asks for a copy, for the fee set by the regulations for each A4 page copied (R2 a page when this manual was compiled; see the Regulator’s PAIA fee schedule);
• to the Information Regulator, on request.

10. Updating this manual

The directors of VCR Properties (Pty) Ltd will update this manual regularly, and whenever the records we keep or the way we handle personal information changes. The date of the latest version is shown at the top.

11. How to ask for a record

1. Fill in Form 2, the Regulator’s “Request for access to record” (download Form 2 (PDF), or see all PAIA forms).
2. Send it to our Information Officer by email to celeste@kyalamicreek.co.za, by post to Postnet Suite 155, Private Bag X1028, Lyttelton 0140, or by hand to our office at 8 Lyndore Avenue, Willaway, Midrand 1684.
3. Give enough detail for us to find the record, say how you want access (for example a copy by email), and say which right you want to use or protect and why you need the record for it. PAIA (section 50) gives access to a private body’s records when you need them to use or protect a right.
4. Prove who you are, and if you ask on someone else’s behalf, show that you may act for them.
5. Pay the request fee before we process the request (you don’t pay it if you are asking for your own personal information). Fees are set by the regulations, not by us: see the Regulator’s PAIA fee schedule (the request fee for a private body was R140 when this manual was compiled; check the current amount). If we give access, there may also be access fees for copying, searching and preparing the record, and a deposit if the search will take long. We tell you in writing what is payable (Form 3).

Our answer. We decide within 30 days of receiving a complete request, and tell you in writing. We may extend this once, by up to 30 days, if the request is large or needs others to be consulted; we will tell you why.

When we may refuse. PAIA lets or requires us to refuse access in some cases, for example to protect another person’s privacy, confidential business information of ours or a third party, someone’s safety, or legally privileged records. If we refuse, we give our reasons.

If you are not happy with our decision. PAIA has no internal appeal against a private body’s decision. You can complain to the Information Regulator (Form 5, PAIA complaint form) within 180 days of our decision, or of the date by which we should have answered, or apply to court.

Your own personal information. To ask what personal information we hold about you, or to correct or delete it, email our Information Officer. See the rights section of our privacy notice.

Information Regulator contact details

Item	Details
Website	inforegulator.org.za
Address	Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg 2191
Phone	010 023 5200; toll-free 0800 017 160
General enquiries	enquiries@inforegulator.org.za
PAIA complaints	PAIAComplaints@inforegulator.org.za
POPIA complaints	POPIAComplaints@inforegulator.org.za

12. Issued by

Issued by: Frans van der Berg, director, for VCR Properties (Pty) Ltd, as head of the private body.

Signed by Frans van der Berg on 15 October 2026. The signed copy is kept at our office.