This Compliance Update serves to remind ICS clients, who have not done so already, to compile and submit their section 51 manuals in terms of the Promotion of Access to Information Act (PAIA).

PAIA places specific compliance requirements on both state institutions and the private sector. In terms of section 51 of PAIA, the head of a private body must compile a section 51 manual and submit it to the South African Human Rights Commission. The manual must also be made available at the company offices and on their website.

In December 2011 an exemption was granted to certain private bodies from compiling section 51 manuals until the 31st of December 2015. Please ensure that your manual is compiled and submitted timeously. Should you wish for ICS to do this on your behalf against payment of a fee of R350 (excl. VAT), please contact for further details.

Please note that the head of a private body who wilfully or in a grossly negligent manner fails to comply with the provisions of section 51 commits an offence and is liable on conviction to a fine, or to imprisonment for a period not exceeding two years.

Please also note that the following private bodies were not granted the exemption until the abovementioned date:
– companies which are not private companies; and
– private companies which operate in specific sectors, with 50 or more employees OR operate in specific sectors and have an annual turnover equal to or exceeding specific amounts (in the case of Finance and Business Services, the amount is R10 million).



If you would like to find out more about the services that ICS offers please contact us.