Manual in terms of section 51 of PAIA.
The records we hold and how to ask for them.
Version 1.0, October 2026. Reviewed by our compliance officer, National Compliance.
1. Introduction
Brawne Protect (Pty) Ltd (“Brawne Protect”) is a private company and an authorised financial services provider (FSP 51198). It gives advice and arranges long-term insurance, investment and retirement benefit products and short-term insurance as an intermediary. It does not decide or pay claims. The insurer does.
This manual is compiled under section 51 of the Promotion of Access to Information Act, 2000 (PAIA), read with the Protection of Personal Information Act, 2013 (POPIA). It tells you which records we hold, how to ask for them and what to expect.
2. Contact details
| Private body | Brawne Protect (Pty) Ltd |
|---|---|
| Registration number | 2019/433770/07 |
| Head of the private body | Naresh Ashok, Chief Executive Officer |
| Information Officer | Marc Potgieter |
| info@brawne.co.za | |
| Phone | +27 72 338 2640 |
| Place of business | 47 Norman Avenue, Bryanston Ext 70, Johannesburg, 2191 |
| Website | https://brawne.co.za |
3. The Information Regulator’s guide
Section 10 of PAIA requires the Information Regulator to publish a guide on how to use the Act. It is available in all official languages from the Regulator.
| Information Regulator | Phone 010 023 5200 or 0800 017 160. Email enquiries@inforegulator.org.za. Website www.inforegulator.org.za |
|---|
4. Records available without a request (section 52)
These are available on our website or on request, without a formal PAIA request:
- Information about our products and services.
- Our privacy notice, complaints policy, terms of use and FSP disclosures.
- Our contact details and licence details.
- This manual.
The Minister has not published a notice under section 52(2) that applies to us at the time of writing.
5. Records kept under other laws
We keep records as required by the laws below, to the extent they apply to us. This is not a list of records you may access. Access is subject to PAIA.
- Companies Act 71 of 2008
- Financial Advisory and Intermediary Services Act 37 of 2002 (FAIS), including the General Code of Conduct
- Insurance Act 18 of 2017 and the Policyholder Protection Rules
- Financial Intelligence Centre Act 38 of 2001 (FICA)
- Protection of Personal Information Act 4 of 2013 (POPIA)
- Promotion of Access to Information Act 2 of 2000 (PAIA)
- Electronic Communications and Transactions Act 25 of 2002
- Consumer Protection Act 68 of 2008
- Income Tax Act 58 of 1962, Value-Added Tax Act 89 of 1991 and Tax Administration Act 28 of 2011
- Basic Conditions of Employment Act 75 of 1997, Labour Relations Act 66 of 1995, Employment Equity Act 55 of 1998, Skills Development Act 97 of 1998, Unemployment Insurance Act 63 of 2001 and Compensation for Occupational Injuries and Diseases Act 130 of 1993, where we employ people
6. Categories of records we hold
Listing a category does not mean the records in it will be disclosed. Every request is assessed against PAIA.
| Category | Examples |
|---|---|
| Company and governance | Incorporation documents, share register, directors’ and shareholders’ resolutions, minutes |
| Licensing and compliance | FSP licence, key individual and representative records, fit-and-proper and examination records, compliance monitoring reports, regulatory returns and correspondence |
| Customer records | Needs analyses, records of advice, quotations, applications, policy information, correspondence, call-back requests, FICA identification and verification records |
| Complaints | Complaints register, complaint files and outcomes |
| Insurer and supplier agreements | Intermediary agreements, service-provider agreements, commission and fee statements |
| Finance and tax | Annual financial statements, accounting records, invoices, bank records, tax returns |
| Human resources | Employment and contractor agreements, payroll, leave and training records, policies. Applies where we employ staff |
| Information technology | System and access records, backups, security and incident logs, data-processing agreements |
| Marketing and website | Website content, enquiry-form submissions, marketing material |
| Insurance | Our professional indemnity and fidelity cover documents |
7. How we process personal information (section 51(1)(c) and POPIA)
Purposes
- Giving advice, arranging cover and servicing policies.
- Identifying and verifying customers and meeting anti-money-laundering duties under FICA.
- Keeping the records FAIS and the Insurance Act require.
- Handling complaints and enquiries.
- Running the business: finance, tax, employment and information security.
Data subjects and the information we hold
| Data subjects | Information |
|---|---|
| Customers and prospective customers | Name, identity or registration number, contact details, financial and needs information, health information where a product needs it, banking details for premiums, beneficiary details |
| Beneficiaries and policy lives | Name, identity number, relationship, contact details |
| Employees, representatives and job applicants | Identity, contact, qualification, fit-and-proper, payroll and performance information |
| Suppliers and service providers | Business and contact details, banking details, agreements |
| Website visitors | Details you type into our contact form |
Recipients
We share information only as needed, with: insurers and product providers; our compliance officer; regulators and ombud schemes when the law or a complaint requires; auditors, accountants and legal advisers; and service providers who process information for us, such as our email, web-hosting and form providers, under written confidentiality duties.
Cross-border transfers
Our website form provider is based in the United States and our email provider may store data outside South Africa. We transfer information only where POPIA section 72 allows it, for example where the recipient is bound by rules or an agreement that give similar protection. We do not plan other transfers outside South Africa.
Information security
- Access to records is limited to people who need it, with individual sign-ins and multi-factor authentication where available.
- Electronic records are held in reputable cloud services with encryption in transit and at rest.
- Paper records, if any, are kept locked.
- Devices are password-protected and kept updated.
- Service providers sign confidentiality and data-protection terms.
- We report security breaches to the Information Regulator and affected people as POPIA requires.
- We keep records for the periods the law sets, then destroy or de-identify them.
8. How to request a record
- Complete Form 2 (request for access to a record), prescribed under the PAIA regulations. It is available from the Information Regulator’s website.
- Send it to the Information Officer at info@brawne.co.za.
- Describe the record, say which right you want to exercise or protect and why you need the record, and give proof of your identity. If you act for someone else, include their written authority.
- We will confirm receipt and decide within 30 days. We may extend this once by up to 30 days, for the reasons PAIA allows, and we will tell you if we do.
- We will tell you if we grant or refuse access, the fee payable and, if we refuse, the reasons and your remedies.
If you cannot read or write, or have a disability, you may make the request orally. We will help you complete the form.
To see or correct your own personal information under POPIA, see our privacy notice.
9. Fees
PAIA allows a request fee (not payable by a person asking for their own personal records), a deposit where the search and preparation will take long, and fees for copies and for search and preparation time. The Minister sets the amounts. The current amounts are on the Information Regulator’s website. We will tell you the amount before we process the request.
10. Grounds for refusal
PAIA allows us to refuse access where, for example, disclosure would:
- unreasonably disclose personal information about another person;
- reveal confidential commercial information of ours or a third party;
- breach a duty of confidence owed to a third party;
- endanger someone’s safety or property;
- reveal privileged information; or
- be restricted by another law.
We will release any part of a record that can be separated from the part we must withhold.
11. Remedies
PAIA does not require an internal appeal for private bodies. If we refuse, or you disagree with the fee or the outcome, you may complain to the Information Regulator (details in section 3) or apply to a court with jurisdiction. Time limits apply, so act promptly.
12. Availability and updates
This manual is on our website at https://brawne.co.za/paia-manual.html and available at our place of business and from the Information Officer on request. We will update it when our records, processes or the law change, and at least once a year.
Version 1.0, October 2026.