Statutory PAIA Manual
Promotion of Access to Information Act (Act 2 of 2000)
Entity: Hlomo Safety (Pty) Ltd t/a Hlomo Advisory
Date of Revision: 2026-07-21
Registration Status: CIPC Compliant // Republic of South Africa
1. Ancillary & Contact Details
- Registered Entity Name: Hlomo Safety (Pty) Ltd
- Trading Identity: Hlomo Advisory
- Head of Entity / Designated Information Officer: The Director (
desk@hlomo.com) - Physical & Correspondence Address: WomHub, Century City, Cape Town, 7441, South Africa
- Primary Purpose: Executive Advisory, Organizational Design, and Fiduciary Intelligence Infrastructure.
2. The PAIA Guide & Section 51 Mandate
The Promotion of Access to Information Act (PAIA) grants private individuals and entities the right to access records held by a private body, provided that the record is required for the exercise or protection of any rights.
Requests under PAIA must be submitted formally to the Designated Information Officer using Form 2 (PAIA Request) via desk@hlomo.com.
3. Records Automatically Available
The following records are available without a formal PAIA request:
- Public Web Content & Media Releases (
hlomo.com) - Executive Guidance & Compliance Briefs (
/compliance) - Publicly Disclosed Governance Frameworks
4. Records Held in Accordance with Other Legislation
Hlomo Safety (Pty) Ltd maintains statutory records under the following South African statutes where required by law:
- Companies Act (Act 71 of 2008)
- Income Tax Act (Act 58 of 1962) & Value Added Tax Act (Act 89 of 1991)
- Protection of Personal Information Act (POPIA, Act 4 of 2013)
- Basic Conditions of Employment Act (Act 75 of 1997)
5. Technical Architecture & Data Limits (POPIA / Zero-Knowledge)
Statutory Notice on "Thought Capital":
Pursuant to Section 51(1)(f) of PAIA and Section 14 of POPIA, notice is hereby given regarding the technical boundaries of the Steward Operating System:
- Cryptographic Isolation: All unstructured strategic inputs, audio transcripts, and executive notes ("Thought Capital") submitted to the platform are mathematically isolated in temporary vector space.
- Irrecoverability & Vaporization: The Provider operates on a strict zero-training, read-only ingestion architecture. Upon execution of user deletion commands or system termination, vector indices are cryptographically shredded.
- Non-Extractability: The Provider does not hold, archive, or possess unencrypted shadow copies, model weights, or raw training pools of user Thought Capital. Consequently, the Provider cannot produce raw user Thought Capital in response to a third-party PAIA request, as such data is mathematically non-existent within the Provider's static infrastructure.
6. Grounds for Refusal of Access
Access to requested internal records will be evaluated and refused if the request falls under the statutory grounds outlined in Chapter 4 of PAIA, including:
- Protection of personal privacy of a third party (POPIA alignment)
- Protection of commercial or proprietary trade secrets of Hlomo Safety (Pty) Ltd
- Protection of confidential information bound by fiduciary client agreements
Prepared by the hlomo Operations Desk (W). Legacy HTML privacy/terms surfaces are not authoritative.