Legal
PAIA manual
This manual is published in terms of section 51 of the Promotion of Access to Information Act 2 of 2000. It tells you what records this company holds, how to request access to them, and what to do if we turn you down. It also sets out the information required under section 17 of the Protection of Personal Information Act 4 of 2013.
1. The company
Registered name
LMNR Group (Pty) Ltd, trading as Averin
Registration number
2026/828138/07
Registered office, principal place of business and location of records
11 Olievenhoutbosch Road, Highveld, Centurion, Gauteng, 0144
Postal address
11 Olievenhoutbosch Road, Highveld, Centurion, Gauteng, 0144
Website
averin.co.za
2. Head of the private body and Information Officer
The head of the private body, as defined in section 1 of the Act, is the sole director of the company.
Name
L Matshiyane
Capacity
Director, and Information Officer registered with the Information Regulator
Email
lu@averin.co.za
Postal address
As above
No Deputy Information Officers have been designated. The company has no employees at the date of this manual. This section will be updated when that changes.
3. The Information Regulator's guide
The Information Regulator has compiled a guide in terms of section 10 of the Act, in an easily comprehensible form, containing the information a person needs in order to exercise their rights under the Act. The guide is available from the Regulator:
Information Regulator (South Africa)
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
PO Box 31533, Braamfontein, Johannesburg, 2017
PAIAComplaints.IR@justice.gov.za
inforegulator.org.za
4. Records available without a request
The following are already published and may be obtained without following the request procedure below:
- This manual.
- Our privacy notice, at averin.co.za/privacy.
- Marketing and product information published on our website.
- Company registration particulars, which are public at the Companies and Intellectual Property Commission.
5. Records held under other legislation
We hold records in terms of, among others, the Companies Act 71 of 2008, the Income Tax Act 58 of 1962, the Tax Administration Act 28 of 2011, the Value-Added Tax Act 89 of 1991, the Protection of Personal Information Act 4 of 2013 and the Electronic Communications and Transactions Act 25 of 2002. Access to a record held under other legislation does not follow automatically from this manual.
6. Categories of records held
Records in the categories below are held by the company. Listing a category here does not mean access will be granted; each request is assessed against the grounds for refusal in Chapter 4 of the Act.
- Company and statutory records — memorandum of incorporation, registration certificate, share register, director records, resolutions, Beneficial Ownership filings and annual returns.
- Financial records — annual financial statements, accounting records, tax returns and assessments, invoices, bank records and supplier records.
- Customer records — service agreements, operator agreements, correspondence, support records and billing records.
- Records processed on behalf of customers — debtors books and related communication records loaded into the Averin service. The company holds these as an operator in terms of section 20 of the Protection of Personal Information Act. The customer remains the responsible party and controls access to them.
- Operational and systems records — application and infrastructure configuration, access logs, audit logs, security records and agreements with our service providers.
- Marketing records — website content, enquiries received and campaign material.
- Employment records — none at the date of this manual. Should the company employ staff, records will include contracts, payroll, leave and statutory returns.
7. How to request a record
A request must be made on the prescribed form, Form 2 of the Regulations, and sent to the Information Officer at the address in section 2. The form is available from the Information Regulator's website.
Your request must give enough particularity to identify the record and to identify you, state the form of access you want, give an address or email address in the Republic for our reply, and, if you are requesting the record in order to exercise or protect a right, identify that right and explain why the record is required to exercise or protect it.
If you are making the request on behalf of someone else, you must attach proof of your authority in a form acceptable to the Information Officer.
8. Fees
Fees are those prescribed in the Regulations made under the Act, as amended from time to time. Two kinds may apply. A request fee is payable when a requester other than a personal requester submits a request. An access fee covers the cost of searching for, reproducing and preparing the record, and we may require a deposit where preparation is expected to exceed the prescribed time.
We will notify you of any fee before processing the request, and you may lodge a complaint with the Information Regulator about a fee you consider unreasonable. The current prescribed schedule is published by the Information Regulator.
9. Decision and timeframes
We will decide on your request as soon as reasonably possible, and within thirty days of receipt. That period may be extended once, by not more than thirty days, where the request is for a large number of records or requires a search through records held elsewhere. We will tell you in writing if we extend, and why.
If we grant access, we will tell you the fee payable, the form in which access will be given and your right to complain about the fee. If we refuse, we will give reasons and tell you how to challenge the decision.
10. Grounds for refusal
Access may be refused on the grounds set out in Chapter 4 of Part 3 of the Act. These include the mandatory protection of the privacy of a third party who is a natural person, the commercial information of the company or a third party, information supplied in confidence, records privileged from production in legal proceedings, research information, and requests that are manifestly frivolous or vexatious or that would involve a substantial and unreasonable diversion of resources.
Access must be granted despite those grounds where disclosure would reveal 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, as section 70 provides.
11. If we refuse
There is no internal appeal against a decision of a private body. If we refuse your request, or you are unhappy with how it was handled, you may lodge a complaint with the Information Regulator, or apply to a court with jurisdiction, within one hundred and eighty days of the decision.
12. Information required under section 17 of POPIA
Purpose of processing. We process personal information to provide and bill for the Averin service, to support and correspond with customers, to meet statutory record-keeping obligations, and, as an operator on our customers' instruction, to contact their debtors about accounts owed to them.
Categories of data subjects and their information. Customers and their representatives, being name, work email, company, telephone number, correspondence and billing details. Debtors of our customers, being account name, contact person, email, telephone number, amount outstanding, days overdue, invoice reference, preferred language, and the records of messages, calls, recordings, replies and outcomes generated while working the account. Suppliers and service providers, being contact and contracting details.
Recipients. Our operators, being our application host, email delivery provider, messaging provider and voice calling provider, each bound by written agreement. Our professional advisers. Regulators and authorities where the law requires disclosure.
Cross-border transfers. Personal information is transferred to operators located outside the Republic. We rely on section 72(1)(a) of the Protection of Personal Information Act, each recipient being bound by a written agreement that upholds principles for lawful processing substantially similar to those in the Act.
Security measures. Access to the application requires authentication, information in transit is encrypted, and access to production data is restricted to those who need it to run the service. A fuller description is in our privacy notice.
13. Availability of this manual
This manual is available on this website, at our principal place of business during normal office hours, and on request to the Information Officer. It is also available to the Information Regulator on request. We will update it whenever the particulars in it change.
Requests and questions about this manual go to lu@averin.co.za.