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Sorbet Holdings (Proprietary) Limited

Registration number:  2005/019913/07

(and all its subsidiaries and related entities)

Promotion of Access to Information Manual

 (Prepared in terms of Section 51 of the Promotion of Access to Information Act, 2 of 2000 (“the Act”)

1              Introduction


    • The 1996 South African Constitution provides a statutory right of access on request to any record held by the state as well as access to records held by any other person that is required for the exercise or protection of any right as promptly and as efficiently as reasonably possible to endorse, including but not limited to, mechanisms and procedures that empower and educate all persons.
    • The Promotion of Access to Information Act 2 of 2000 (“PAIA”), which came into effect on 9 March 2001, seeks to advance the values of transparency and accountability in South Africa and provides the mechanism for requesters to exercise their constitutional right to request access to a record.
    • PAIA establishes the following statutory rights of requesters to any record of a private body if –
      • that record is required for the exercise or protection of any of his or her legal rights;
      • that requester complies with all the procedural requirements; and
      • access is not refused in terms of any ground referred to in PAIA.
    • The information in this manual is published on the Sorbet Holdings Limited (“the Company” or “Sorbet Holdings ”) website, Sorbet Holdings, in accordance with the requirements of Section 51 of PAIA to facilitate access to records held by the Company.
    • PAIA requires organisations to compile a manual as a guide to requesters of information. The Manual also serves to indicate the types of records held by Sorbet Holdings and the availability of such records from Sorbet Holdings .
    • In addition, the manual explains how to access, or object to, or request correction or deletion of, personal information held by Sorbet Holdings, in terms of sections 23, 24 and 25 of the Protection of Personal Information Act 4 of 2013 (“POPIA”), and the Regulations Relating to the Protection of Personal Information, 2017 (“POPIA Regulations”).
    • This manual is not exhaustive of, nor does it comprehensively deal with, every procedure provided for in PAIA. Requesters are advised to familiarise themselves with the provisions of PAIA and POPIA before making any requests to Sorbet Holdings in terms of these Acts. However, in terms of section 19 of PAIA, and Regulations 2 and 3 of the POPIA, Sorbet Holdings will provide such assistance as is required in completing the necessary forms, by parties applying for access to information or personal information.
    • Sorbet Holdings makes no representation and gives no undertaking or warranty that the information in this manual or any information provided by it to a requester is complete or accurate, or that such information is fit for any purpose. All users of any such information use such information entirely at their own risk, and Sorbet Holdings will not be liable for any loss, expense, liability or claims, howsoever arising, resulting from the use of this manual or of any information provided by Sorbet Holdings or from any error therein.
  • OVERVIEW OF Sorbet Holdings


  • Sorbet Holdings is a public company trading on the Johannesburg Stock Exchange and an investment holding company. As a lifestyle-themed group, Sorbet Holdings is invested in a portfolio of assets which incorporates retail, wholesale, manufacturing, service, merchandising, distribution and e-commerce.
  • Sorbet Holdings aims to operate a decentralised management structure, providing financial, strategic and management support to its investee companies. Sorbet Holdings ’s intention is to take a long-term view on investments, while retaining the flexibility to dispose of investments which no longer meet the investment criteria and the agility to take advantage of opportunities as they arise.


  • Sorbet Holdings has several wholly owned subsidiaries – this structure is aimed at creating efficiencies in the administration of the listed Company.
    • The Information Officer of Sorbet Holdings is Kirsten whose contact details are as follows –


Contact details


Telephone no:  011 268 2034


  • The contact details for the Head Office of Sorbet Holdings are as follows –

Physical address

Head office

Sorbet Place, 6 Mellis Road, Rivonia, Sandton

    • On 1 July 2021, the Information Regulator assumed the functions of the South African Human Rights Commission (“SAHRC”) and will be responsible for PAIA and POPIA queries.
    • As part of its functions, the Information Regulator will publish a guide on how to use PAIA and POPIA in the new dispensation. The Information Regulator has not yet published a guide to this effect.
    • The SAHRC has previously developed a guide with information on how to use PAIA. This guide is available on the SAHRC website
    • Any information or queries related to the guide, or to PAIA or POPIA should be directed to –

Information Regulator

JD House

27 Stiemens Street




Telephone number:           (012) 406 4818

Fax number:                       (086) 500 3351



    • At this stage, no notices have been published by the Information Regulator on the categories of records automatically available without a person having to request access thereto in terms of PAIA.
    • PAIA requires institutions to list those records that are freely available. Such automatically available records usually do not have information that can reasonably be said to be of a sensitive nature. The records which fall into this category of information are available from the Company at its head office and do not require a formal process to access same. Some of the categories, encompassing these records and which are available on the Company’s website, Sorbet Holdings, include –
      • integrated reports;
      • SENS announcements;
      • circulars to shareholders; and
      • media releases.

Records are kept in accordance with legislation as is applicable to Sorbet Holdings , which include (but may not be limited to) the following legislation –

  • Basic Conditions of Employment Act 75 of 1997;
  • The Constitution of the Republic of South Africa, 1996;
  • Companies Act 71 of 2008;
  • Compensation for Occupational Injuries and Diseases Act 130 of 1993;
  • Competition Act 89 of 1998;
  • Consumer Protection Act 68 of 2008;
  • Employment Equity Act 55 of 1998;
  • Financial Markets Act 19 of 2012
  • Electronic Communications and Transactions Act No 2 of 2000
  • Financial Intelligence Centre Act No 38 of 2001
  • Income Tax Act No 58 of 1962;
  • Labour Relations Act No 66 of 1995;
  • Promotion of Access to Information Act No 2 of 2000;
  • Protection of Personal Information Act 2013;
  • Unemployment Insurance Act No 63 of 2001; and
  • Value-added Tax Act No 89 of 1991.
    • The records below must be formally requested by lodging a request form as contained in Annexure A. The provision of these records are subject to the conditions as set out in paragraph 13 The following table contains a description of the types of records/subjects on which Sorbet Holdings holds and the categories of records held on each subject –


·         Policies and procedures

·         Contracts

·         Risk assessment

·         Compliance records

Statutory records/legal

·         Incorporation documents

·         Memorandum of Incorporation

·         Share register and statutory returns to relevant authorities

·         Minutes of meetings of the board of directors

·         Records relating to the appointment of directors, auditors, and other officers

Income tax

·              Pay-as-you-earn (PAYE) records

·              Documents issued to employees for income tax purposes

·              Records of payments made to South African Revenue Services on behalf of employees

·              All or any statutory compliance

·              Value Added Tax

·              Skills development levies

·              Unemployment Insurance Fund

Labour relations records

·              Personnel documents and records

·              Employment contracts

·              Medical aid records

·              Pension Fund records

·              Disciplinary records

·              Salary records

·              Disciplinary code and / or procedures

·              Leave records

·              Training records

·              Training manuals

·              Address lists

·              Internal telephone lists


·         General contract information

Information management and technology

·         Contract agreements with service providers

·         Policies, procedures and guidelines


·         Tax registration

·         Asset register

·         Receipts and payments

·         Bank statements

·         Budgets

·         Management accounts

·         Orders, quotes and invoices

·         Minutes of meetings

·         Correspondence

  • Whilst the records listed in the categories above may be formally requested, access to all or parts of these records may be refused or restricted to satisfy the objectives as set out in section 9 of PAIA, which include the observation of limitations aimed at the reasonable protection of privacy, commercial confidentiality (such as a confidence owed to a third party in terms of an agreement) and effective, efficient and good governance, and in a manner which balances the right to access of information with any other rights, including those set out in the Bill of Rights in Chapter 2 of the Constitution.
  • The Company further reserves the right to refuse access to records where the processing of the record will result in a substantial and unreasonable diversion of its resources or which are sensitive in nature. Access will also be refused where requests are clearly frivolous and/or vexatious.
    • POPIA
      • Chapter 3 of POPIA provides for the minimum conditions for lawful processing of Personal Information. These conditions may not be derogated from unless specific exclusions apply as outlined in POPIA.
      • Sorbet Holdings processes personal information in accordance with POPIA. As stated in our privacy policy, Sorbet Holdings will ensure that all processing conditions of POPIA are complied with at the time of processing of personal information. Sorbet Holdings processes personal information of both living and juristic persons.
    • Purpose for processing of personal information by Sorbet Holdings

As stated in our privacy policy, Sorbet Holdings processes personal information for a number of reasons including, but not limited to, –

  • providing requested services;
  • managing the commercial relationship with customers;
  • manage dispute resolution;
  • create and manage supplier relationships;
  • manage contracts, orders, deliveries, invoices and accounting;
  • sending quotation estimates;
  • processing and managing customer subscriptions;
  • collect statistical information and run analytics in order to improve services understand customers better;
  • general human resource and finance functions including those obligations imposed by legislation;
  • sending marketing communications and managing a list of customers who wish to not receive marketing material; and
  • to allow proper functioning of the website which includes, amongst others, proper display of content, interface personalisation and ensuring that the website is safe and secure to protect against misuse.
  • Categories of data subjects

Sorbet Holdings processes personal information relating to the following categories of data subjects –

  • customers;
  • shareholders;
  • beneficiaries;
  • directors;
  • employees and job applicants;
  • juristic entities (i.e. service providers, contractors, consultants);
  • complainants and enquirers;
  • visitors to premises;
  • individuals captured by CCTV images; and
  • individuals who have an interest in the products and services of Sorbet Holdings.
  • Types of personal information processed
    • As stated in our privacy policy, Sorbet Holdings processes the following types of personal information, amongst others,
      • name and surname;
      • email address and postal address (invoicing);
      • phone number;
      • transaction information (details regarding the service subscribed, transaction number);
      • services history;
      • payment information;
      • data relating to the commercial relationship and details regarding the service subscribed (including duration and any correspondence);
      • billing data; and
      • information collected by cookies or similar technologies.
    • Please refer to our privacy policy for further information.
  • Disclosure of your personal information
    • We may disclose your personal information to third parties who are involved in the delivery of products and services to you such as trusted service providers (sub-contractors).
    • Where Sorbet Holdings discloses your personal information to any third party, the latter will be obliged to use that personal information for the reasons and purposes it was disclosed for. To this end, we have agreements in place with these third parties to ensure this and to ensure an adequate level of security and confidentiality for your personal information.
    • Sorbet Holdings may be obliged to disclose your personal information where we have a duty to disclose in terms of law or where we believe it is necessary to protect our rights.
  • Trans-border/Cross border flows of personal information

Section 72 of POPIA provides that personal information may only be transferred out of the Republic of South Africa if certain conditions are satisfied. Sorbet Holdings  complies with the requirements set out in section 72 of POPIA in respect of cross border transfer of personal information.

  • General description of information security measures
    • Sorbet Holdings takes reasonable and appropriate technical and organisational measures to ensure that personal information is kept secure and is protected against unauthorised or unlawful processing, accidental loss, destruction or damage, alteration disclosure or access. We contractually require that service providers who handle your personal information for us do the same.
    • Sorbet Holdings , on a regular basis, reviews the security controls and related to processes to ensure that personal information is secure.
    • Telephonic requests

Requests made to the Company telephonically are not valid and will not be entertained.

  • Voluntary access

Information that is automatically available can be obtained from the Company’s website, or in writing via the email address provided under paragraph 3.1 above. Where applicable, a reproduction fee will be charged. Transcription and copying of records in or onto other media attract reproduction fees.

  • Formal requests
    • To request a record in terms of PAIA, the requester must complete the prescribed form attached to this manual as Annexure A. This request must be sent to the Information Officer at the addresses provided at paragraph 1.
    • The requester must indicate the form or manner of access required. The Company will endeavour to provide information in the form requested where possible.
    • For POPIA-related requests to object to the processing of personal information, correct or delete personal information, the request must be made in writing on the applicable prescribed Form 1 (objection) or Form 2 (correction or deletion), which are attached to this Manual as Annexure B.
    • The requester must provide sufficient detail to enable the Information Officer to identify the record(s) requested and the requester. The requester must indicate which form of access is required, identify the right that he/she is seeking to exercise or protect and provide an explanation of why the requested record is required for the exercise or protection of that right.
    • If a person is making a request on behalf of another, then written evidence that they have been requested to do so must be submitted to the Company.
    • PAIA makes provision for certain grounds upon which a request for access to information must be refused. On this basis, the Information Officer will make a decision whether or not to grant a request for access to information.
    • Fee impositions are prescribed in terms of the PAIA. A fee schedule is attached hereto as Annexure C. Fees are payable at the inception of a request and thereafter, fees are incurred for search processes and reproduction costs. Certain categories of persons are exempt from paying fees. These categories include those persons who are requesting their own personal information, or that relating to their minor children.
    • PAIA provides for two types of fees, namely –
      • a request fee, which will be a standard non-refundable administration fee, payable prior to the request being considered; and
      • an access fee, payable when access is granted which must be calculated by taking into account reproduction costs, search and preparation time and cost, as well as postal costs.
    • Subsequent to a request being made, the Information Officer, shall by notice require the requester, excluding personal requester, to pay the prescribed request fee (if any), before further processing of the request.
    • All payments are to be made directly into the bank account of the Company.
    • Requests for voluminous non-personal records will not be accepted without prior payment.
    • If a request is granted, then a further access or search fee is required. This fee is calculated in terms of the rates set out in the attached regulation. Fees are charged for time spent searching for the record and preparing and/or reproducing the record/s.
    • If the search for and preparation for disclosure of the record has been made, including an arrangement to make it available in the requested form, requires more than the hours prescribed in the regulations for this purpose, Sorbet Holdings will request the requester to pay as a deposit the prescribed portion of the access fee which would be payable if the request is granted.
    • Sorbet Holdings may withhold a record until the requester has paid the fees as indicated in Annexure C.
    • A requester whose request has been granted must pay the applicable access fee for reproduction, search, preparation and for any time reasonably required in excess of the prescribed hours to search for and prepare the record for disclosure including making arrangements to make it available in the request form.
    • In terms of POPIA, a data subject has the right to request Sorbet Holdings to confirm, free of charge, whether or it holds personal information about the data subject and request from Sorbet Holdings  the record or a description of the personal information held, including information about the identity of all third parties, or categories of third parties, who have, or have had, access to the information.
    • POPIA further provides that where the data subject is required to pay a fee for services provided to them, Sorbet Holdings must provide the data subject with a written estimate of the payable amount before providing the service and may require that the requester pay a deposit for all or part of the fee.
    • Sorbet Holdings will inform the requester within 30 days after receipt of the request of its decision whether or not to grant the request.
    • The 30-day period may be extended by a further period of not more than 30 days if the request is for a large number of records or requires a search through a large number of records and compliance with the original period would unreasonably interfere with the activities of Sorbet Holdings or the records are not located at Sorbet Holdings .

Should the request be refused, the notice will state adequate reasons for the refusal, including the provisions of the PAIA relied upon and that the requester may lodge an application with a Court against the refusal of the request.

    • In terms of Section 62 to 69 of PAIA access granted to a record may be refused on one or more of the following grounds –
      • protection of privacy to a third party who is a natural person;
      • protection of the commercial information of a third party;
      • protection of certain confidential information of a third person;
      • protection of the safety of individuals and the protection of property;
      • protection of records privileged from production and legal proceedings;
      • the commercial information of Sorbet Holdings ; and/or
      • the protection of research information of a third party.
    • Despite any provisions of PAIA, a request must be granted if the disclosure of the record would reveal evidence of substantial contravention of, or failure to comply with, the law or imminent and serious public safety or environment risk, and the public interest in the disclosure of the record clearly outweighs the harm contemplated (section 70 of PAIA).

Should the requester be dissatisfied with the Information Officer’s decision to refuse access, that person may within 30 days after notification of the refusal apply to a Court for the appropriate relief.

  • missing records

Requesters have the right to receive a response in regard to records that cannot reasonably be located, but to which a requester would have had access had the record been available.


Requesters will be advised whether a particular record has been disposed of where this is relevant to the records requested.


The Company reserves the right to transfer requests for records to relevant bodies where these bodies were the primary holders or generators of the information requested, or where the Company no longer has possession of such record, and to create new categories of records where this is necessary. This manual will be updated to reflect changes in categories of records accordingly.


   Schedule of fees



The fee for a copy of the manual as contemplated in regulation 5(c) is R0,60 for every photocopy of an A4-size page or part thereof.


Reproduction fees: Regulation 11(1):

For every photocopy of an A4-size page or part thereof


For every printed copy of an A4-size page or part thereof held on a computer or in electronic or machine-readable form


For a copy in a computer-readable form on:

(i)        Compact disc



For a transcription of visual images:

(i)        for A4-size page or part thereof

(ii)      copy of visual images

(iii)     transcription of an audio record, A4 size page or part thereof

(iv)     copy of an audio record







Request fee payable by a requester, other than a personal requester


Search fees – to search and prepare a record for disclosure. The fee is charged per hour (or part of the hour).



For purposes of Section 22(2) of the Act, the following applies:

a)        in the event that the preparation of the record requested exceeds preparation time of six hours, a deposit will be payable by the requester; and

b)        one third of the access fee is payable as a deposit by the requester.


The actual postage is payable when a copy of a record must be posted to a requester.


Formal Request Form for Documents not automatically available

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