PAIA MANUAL

No Sweat Work Media CC

Trading as NoSweat

Prepared in accordance with section 51 of the Promotion of Access to Information Act 2 of 2000 ("PAIA"), as amended, and incorporating relevant requirements of the Protection of Personal Information Act 4 of 2013 ("POPIA").

Registration Number: 2009/090625/23
Website:www.nosweat.co.za
Effective Date: 10 August 2026
Version: 2.0

1. Introduction

The Promotion of Access to Information Act 2 of 2000 ("PAIA") gives effect to the constitutional right of access to information.

PAIA provides for access to records held by public bodies and, in certain circumstances, records held by private bodies where the information is required for the exercise or protection of a right. (Justice)

No Sweat Work Media CC ("NoSweat", "we", "us" or "our") is a South African private body and talent platform connecting businesses with freelance, fractional and full-time professionals.

This Manual has been prepared to:

• describe the records held by NoSweat;

• explain which records may be available without a formal request;

• explain how a person may request access to records;

• provide the relevant contact information;

• describe how NoSweat processes personal information for purposes of POPIA; and

• assist persons wishing to exercise their rights under PAIA or POPIA.

2. Details of the Private Body

Registered Name:
No Sweat Work Media CC

Trading Name:
NoSweat / No Sweat

Registration Number:
2009/090625/23

Physical Address:
R512
Hartbeespoort
North West Province
0240
South Africa

Website:
www.nosweat.co.za

Telephone / WhatsApp:
+27 81 818 2053

Email:
sebastian@nosweat.co.za

These contact and entity details are consistent with the information currently published by NoSweat. (No Sweat)

3. Information Officer

Information Officer / Head of Private Body:
Sebastian van ’t Hoff

Email:
sebastian@nosweat.co.za

Telephone:
+27 81 818 2053

Physical Address:
R512, Hartbeespoort, North West Province, 0240, South Africa

All PAIA requests and privacy-related enquiries should be directed to the Information Officer.

Information Officers are required to be registered with the Information Regulator before performing their duties under POPIA. The Regulator provides registration through its eServices platform. (Empowered Compliance Monitoring)

4. Guide on How to Use PAIA

The Information Regulator has prepared a guide explaining PAIA and how members of the public can exercise their rights under the Act.

The Guide includes information about:

PAIA requests, the records that may be requested, assistance available to requesters, applicable fees, remedies where access is refused and the rights of data subjects under POPIA.

The Guide and the prescribed PAIA forms are available from the Information Regulator (South Africa). (Empowered Compliance Monitoring)

Information Regulator

Address:
Woodmead North Office Park
54 Maxwell Drive
Woodmead
Johannesburg
2191
South Africa

Telephone: 010 023 5200
Toll Free: 0800 017 160
General enquiries:enquiries@inforegulator.org.za
PAIA complaints:PAIAComplaints@inforegulator.org.za

Current contact details are published by the Information Regulator. (Empowered Compliance Monitoring)

5. Records Available Without a Formal PAIA Request

Certain information is publicly available through NoSweat's website without requiring a PAIA request.

This includes, where applicable:

NoSweat may make additional records available voluntarily without requiring a formal PAIA request.

The existence of a category in this Manual does not mean that every record within that category is automatically available.

6. Records Available in Terms of Other Legislation

NoSweat may hold records that are required to be maintained or made available under South African legislation.

Depending on its applicability to NoSweat at the relevant time, such legislation may include:

The inclusion of legislation above does not imply that every statute necessarily applies to every NoSweat activity or that every record is automatically accessible.

Access remains subject to the applicable legislation and any lawful restrictions.

7. Categories of Records Held by NoSweat

7.1 Corporate and Statutory Records

These may include incorporation and registration documents, membership records, statutory records, organisational information, policies, governance documents, insurance records and business licences where applicable.

7.2 Candidate and Talent Records

NoSweat operates a candidate platform through which professionals may create profiles, upload CVs, provide portfolios and apply for freelance, fractional and full-time opportunities. (No Sweat)

Records may include:

candidate profiles, names and contact details; CVs and résumés; portfolios and professional links; skills and disciplines; qualifications; employment history; experience levels; rates and salary expectations; availability; job applications; application history; candidate correspondence; interview information; matching and shortlist records; references; verification information; contracts; purchase orders; payment information; and tax-related records.

7.3 Verification and Background-Check Records

For appropriate placements, NoSweat may process or facilitate identity, experience, qualification and criminal-record verification. NoSweat's current website states that such checks may be conducted for full-time placements. (No Sweat)

Access to these records may be restricted because they can contain personal or special personal information.

7.4 Client Records

These may include:

client contact details; company information; client accounts; job briefs; vacancies; job specifications; budgets and salaries; hiring requirements; candidate submissions; interview information; selection information; agreements; placement records; invoices; payment records; correspondence; and support records.

7.5 Recruitment, Matching and Placement Records

These may include:

candidate searches; matching information; applications; candidate shortlists; suitability information; interview scheduling; selection outcomes; offers; placements; contractor engagements; replacement processes; and related communications.

7.6 Freelance and Contractor Records

NoSweat facilitates freelance engagements and currently states that it may issue purchase orders, process freelancer payments and deduct applicable PAYE for payment to SARS. (No Sweat)

Associated records may include:

purchase orders; freelancer agreements; timesheets where applicable; invoices; payment instructions; banking information; tax information; payment histories; project details; and client approvals.

7.7 Financial and Accounting Records

These may include:

financial statements; management accounts; invoices; quotations; receipts; payment records; bank records; accounting records; tax documentation; SARS correspondence; PAYE records; VAT records where applicable; expense records; and supplier records.

7.8 Supplier and Service-Provider Records

These may include:

supplier information; service agreements; invoices; quotations; correspondence; contact information; software-provider records and payment records.

7.9 Personnel Records

Where applicable, records may include:

employee or contractor information; employment agreements; remuneration information; leave records; performance records; tax information; disciplinary information; training information and related correspondence.

7.10 Website, Platform and Technology Records

These may include:

user-account information; authentication information; website logs; IP addresses; analytics; cookie information; account activity; security logs; application records; platform activity; technical logs; backups and support information.

7.11 Communications

These may include:

email correspondence; WhatsApp communications; telephone records where maintained; website enquiries; client and candidate correspondence; support enquiries and other business communications.

7.12 Legal and Compliance Records

These may include:

contracts; legal correspondence; legal advice; privacy records; POPIA requests; PAIA requests; complaints; data-subject requests; regulatory correspondence; security-incident records; consent records and compliance documentation.

7.13 Marketing and Public Communications

These may include:

marketing materials; newsletters; social-media content; public announcements; testimonials where authorised; website content and campaign records.

7.14 Intellectual Property

These may include:

website content; branding; designs; software-related records; domain information; databases; copyright works; trademarks where applicable and other intellectual property.

8. Requesting Access to a Record

A person wishing to request access to a record held by NoSweat must use the prescribed Form 2 – Request for Access to Record under the current PAIA Regulations. (Empowered Compliance Monitoring)

The completed request should be sent to:

Information Officer
Sebastian van ’t Hoff
Email: sebastian@nosweat.co.za
Tel: +27 81 818 2053

The request should contain sufficient information to allow NoSweat to identify:

the requester; the record requested; the preferred form of access; and appropriate contact details.

Because NoSweat is a private body, the requester must also identify the right that they seek to exercise or protect and explain why access to the requested record is necessary for the exercise or protection of that right. The Information Regulator specifically identifies this as a requirement when requesting records from private bodies. (Empowered Compliance Monitoring)

Where a request is submitted on behalf of another person, appropriate proof of authority may be required.

9. Fees

Fees are prescribed under PAIA and its Regulations and may change from time to time.

As at the effective date of this Manual, the Information Regulator's 2026 fee schedule states that the request fee for a private body is R140.00.

Current prescribed private-body fees include:

If the search for a record is expected to exceed six hours, a deposit may be required in accordance with the Regulations.

NoSweat will advise a requester of applicable fees before providing access where required.

10. Decision on a Request

NoSweat will consider a properly submitted request in accordance with PAIA.

Access may be:

granted in full; granted in part; or refused.

Where access is granted, NoSweat will advise the requester of any applicable access fee and the manner in which access will be provided.

Where access is refused, the requester will be given the reason for refusal as required by PAIA.

11. Grounds on Which Access May Be Refused

PAIA does not provide an unrestricted right of access to every record.

Access may be refused where permitted or required by PAIA, including where disclosure would improperly affect:

the privacy of another person; confidential commercial information; trade secrets; confidential information supplied by a third party; legally privileged communications; the safety or security of a person; NoSweat's own commercial information; or other information protected by PAIA.

A record containing information that may not be disclosed may, where reasonably possible and legally required, be severed so that the remainder can be disclosed.

The applicable grounds of refusal are contained in PAIA rather than being determined solely at NoSweat's discretion. (Justice)

12. Complaints and Remedies

There is no compulsory internal PAIA appeal procedure for a private body such as NoSweat.

If a requester is dissatisfied because a request has been refused, inadequately answered or not responded to, the requester may lodge a complaint with the Information Regulator.

The Regulator's current guidance states that complaints relating to private bodies should generally be submitted using Form 5, and ordinarily within 180 days of the relevant refusal, non-response or other decision. (Empowered Compliance Monitoring)

Complaints may be sent to:

Information Regulator (South Africa)
Email: PAIAComplaints@inforegulator.org.za
Telephone: 010 023 5200
Toll Free: 0800 017 160
Address: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191. (Empowered Compliance Monitoring)

A requester may also seek relief from a competent court where permitted by PAIA.

13. Processing of Personal Information Under POPIA

NoSweat processes personal information as part of operating its talent platform and providing its services.

13.1 Categories of Data Subjects

Data subjects may include:

14. Categories of Personal Information

Depending on the relationship with NoSweat, personal information may include:

identification and contact information; CV and professional information; employment history; qualifications; skills; portfolio information; rate and salary expectations; availability; application records; correspondence; identity information; verification results; financial and banking information; tax information; account and login information; website usage information; IP addresses; and information required to comply with law.

Certain verification processes may involve special personal information, including information relating to criminal behaviour. Such information is subject to additional requirements under POPIA. The Information Regulator currently identifies processing of criminal-behaviour information on behalf of third parties as one of the circumstances that may require prior authorisation under section 57 of POPIA. (eservices.inforegulator.org.za)

15. Purposes for Processing Personal Information

NoSweat may process personal information for purposes including:

operating the NoSweat platform; maintaining candidate and client accounts; matching candidates with opportunities; processing applications; presenting candidates to clients; facilitating interviews and placements; performing appropriate verification; preparing contracts and purchase orders; administering freelance engagements; processing payments and tax obligations; client administration; invoicing; customer support; fraud and security prevention; website administration; analytics; legal and regulatory compliance; responding to data-subject requests; resolving disputes; and protecting NoSweat's lawful interests.

16. Recipients of Personal Information

Where necessary and lawful, personal information may be disclosed to:

prospective or existing clients; candidates where necessary for an engagement; service providers; cloud and software providers; background-check and verification providers; banks and payment providers; SARS and other governmental authorities; accountants and professional advisers; legal advisers; regulators; courts; law-enforcement bodies; and other persons where required or permitted by law.

Personal information is not made publicly available merely because it is held by NoSweat.

17. Cross-Border Transfers

NoSweat may use technology, cloud, software or other service providers whose systems or personnel are located outside South Africa.

Where personal information is transferred outside South Africa, NoSweat will take reasonable steps to ensure that the transfer complies with POPIA and applicable requirements governing international transfers.

18. Security of Personal Information

NoSweat takes reasonable technical and organisational measures intended to safeguard personal information against loss, damage, unauthorised destruction, unlawful access or unlawful processing.

Security measures are applied according to the nature of the information and the systems in which it is stored and may include appropriate access restrictions, authentication controls, secure technology providers, system security measures, backups, confidentiality requirements and incident-response procedures.

Specific security controls are not disclosed publicly where doing so could compromise the security of NoSweat's systems.

19. Requests Relating to Personal Information

A data subject may have rights under POPIA to request access to personal information held about them and, where applicable, to request correction or deletion of inaccurate, outdated, incomplete, excessive or unlawfully obtained information.

The Information Regulator provides prescribed PAIA and POPIA forms for such requests. (Empowered Compliance Monitoring)

Requests may be directed to:

Sebastian van ’t Hoff
Information Officer
sebastian@nosweat.co.za
+27 81 818 2053

Reasonable proof of identity may be required before personal information is released, amended or deleted.

20. Availability of This Manual

This Manual is available:

Online:www.nosweat.co.za
By email:sebastian@nosweat.co.za
At NoSweat's physical address: R512, Hartbeespoort, North West Province, 0240, South Africa.

The Information Regulator currently requires organisations to make PAIA manuals publicly available through their websites and at their offices and indicates that manuals must also be available in multiple languages. (eservices.inforegulator.org.za)

NoSweat may make additional language versions available in accordance with applicable PAIA requirements.

21. Updating This Manual

NoSweat will review this Manual periodically and update it where necessary, including when:

the organisation's contact information changes; the Information Officer changes; material categories of records change; NoSweat's processing of personal information changes; relevant legislation or PAIA Regulations change; or the Information Regulator issues materially relevant new requirements.

The most recent version published on www.nosweat.co.za will replace earlier versions.

22. Approval

Approved for No Sweat Work Media CC

Information Officer / Head of Private Body:
Sebastian van ’t Hoff

Date: 10 August 2026

Version: 2.0