Private-body PAIA Manual · Version 1.0. Prepared under section 51 of the Promotion of Access to Information Act 2 of 2000. Document date: 12 October 2026.
Acronyms used
- PAIA: Promotion of Access to Information Act 2 of 2000, as amended
- POPIA: Protection of Personal Information Act 4 of 2013
- IO: Information Officer / head of this private body
- DIO: Deputy Information Officer, if properly designated
- Regulator: Information Regulator (South Africa)
- HoldCo: Modu Mayo Group (Pty) Ltd
- TradeCo: Modu Mayo Distribution and Trade (Pty) Ltd
- FinCo: Modu Mayo Franchise Finance (Pty) Ltd
1. Particulars of the private body
- Legal name: Modu Mayo Group (Pty) Ltd.
- Registration number: 2025/370800/07, as shown in the CIPC amended registration certificate dated 15 December 2025.
- Legal form: South African private company.
- Registered and postal office: 6597 Kubone Drive, Mamelodi West, Mamelodi, Gauteng, 0122, as recorded in the CIPC certificate.
- Postal address: 6597 Kubone Drive, Mamelodi West, Mamelodi, Gauteng, 0122, as stated in the same official certificate.
- Principal place of business: 6597 Kubone Drive, Mamelodi West, Mamelodi, Gauteng, 0122. The PAIA Manual is presently maintained in digital format only. For an electronic copy or enquiries about access, contact info@modumayo.co.za or 066 413 3763. Visits to this address, including PAIA Manual inspections during normal business hours, are by prior appointment through info@modumayo.co.za.
- Main company, legal and PAIA telephone: 066 413 3763 (+27 66 413 3763). This number is also used for bulk-food enquiries.
- Website: www.modumayo.co.za.
- PAIA/legal/privacy correspondence: info@modumayo.co.za.
- Head of private body: Kamogelo S. Kekana, Managing Director. Rights requests may be sent to info@modumayo.co.za.
- PAIA correspondence and enquiries: 066 413 3763, info@modumayo.co.za, and the principal-place-of-business address above. Legal service of process follows applicable law and is not changed by this PAIA inspection designation.
This manual covers records held by or under the control of HoldCo, not automatically records that TradeCo or FinCo independently controls. Records independently controlled by TradeCo or FinCo are subject to the applicable responsibilities and access procedures of those separate legal entities.
2. Purpose of this manual
This manual explains how the public can identify and request access to the Company's records under the Promotion of Access to Information Act (PAIA). Availability of a record does not mean unrestricted public disclosure; statutory exemptions, third-party rights and access tests apply.
3. How to obtain the Information Regulator's PAIA Guide
The Information Regulator provides a guide explaining how to use PAIA, including request procedures, available remedies and prescribed forms. Official website: https://inforegulator.org.za/ and eServices https://eservices.inforegulator.org.za/.
4. Records available without a formal PAIA request
The following are examples of corporate information accessible through the Company website or the applicable official registry. This does not grant unrestricted access to confidential commercial information or third-party personal information.
| Record category | Access method | Qualification |
|---|---|---|
| Corporate business information | Company website | Information published for general access |
| Website Privacy Notice | Privacy Notice or request to info@modumayo.co.za | Explains website-related personal-information processing |
| PAIA Manual | Digital PAIA Manual; electronic-copy enquiries to info@modumayo.co.za | On-site inspection remains a separate requirement under PAIA section 51(3) |
| Public CIPC company particulars | CIPC's applicable records and access procedures | Public registry records do not give unrestricted access to other company records |
Other records may require a formal PAIA request. Publication of corporate information does not imply that internal financial, shareholder, customer, employee or commercial records are available without restriction.
5. Categories of records of the Company
The following categories describe records to the extent they are held by or under the control of Modu Mayo Group (Pty) Ltd. Subsidiary records are not automatically included.
| Subject | Record types (where held) | Scope and access |
|---|---|---|
| Corporate and Group governance | CIPC/MOI, meeting minutes, shareholding, registers, policies, signed Board decisions | Access subject to the records under HoldCo's custody and the applicable law |
| Group strategy and investment | Confidential plans, commercial due diligence, feasibility assessments, fundraising correspondence | Commercial and confidential records are assessed under PAIA |
| Website and intellectual property | Domains, content, master brand licences/artwork, vendor contracts | As applicable to website and brand records held by HoldCo |
| Finance, accounting and tax | HoldCo ledgers, tax filings, bank and audit records where held | Where HoldCo holds such records |
| Personnel and contractors | Employment or service-provider records where actually held | Where HoldCo is the actual employer or contracting party |
| Website enquiries and governance | Legal correspondence, enquiry communications, privacy/PAIA request logs when created | Where the relevant records exist |
Certain records may be exempt from disclosure in whole or in part under PAIA. Confidentiality labels do not themselves automatically create an exemption.
6. Records available under other legislation
The following legislation may apply to records held by HoldCo. Inclusion does not mean that every listed record exists or is automatically accessible:
| Legislation | Potentially applicable HoldCo records |
|---|---|
| Companies Act 71 of 2008 | Incorporation/MOI, directors, securities and corporate records as required by law |
| PAIA 2 of 2000 | This manual, applicable access requests and decision records |
| POPIA 4 of 2013 | Processing records, data-subject requests and security records as applicable |
| Tax Administration Act 28 of 2011 | Tax returns, supporting documents and retention records as applicable |
| Employment-related law, if HoldCo employs staff | Statutory employment and remuneration records, subject to exact employer identity |
Availability under legislation does not mean every requester receives every record. The relevant statute, company-record access provisions, confidentiality, personal information and PAIA tests remain applicable.
7. How to request access
The prescribed Form 2 may be obtained from the Information Regulator's PAIA forms page. Under PAIA section 50, access to private-body records ordinarily requires identifying the right being exercised or protected and why the record is required for that right, meeting procedure and applicable exemptions. A request for one's own personal information may also engage POPIA sections 23–25, for which distinct access procedures may apply.
A requester seeking records of this private body generally makes a request through the prescribed PAIA request form (Form 2), identifying the record, preferred access method and the right to be exercised or protected, with enough details to locate the record. Send to info@modumayo.co.za, preferably with “PAIA Request — Modu Mayo Group” as the subject line, or use the lawful delivery method/verified physical address. Enquiries may be sent to info@modumayo.co.za; this does not exclude another delivery method recognised by law.
An authorised official will acknowledge and evaluate the application under PAIA, considering statutory grounds for refusal, third-party notification where relevant and applicable request/access fees. The usual PAIA decision period is 30 calendar days, with a possible statutory extension in qualifying circumstances. The Company will communicate its decision and, where required, the reasons, applicable fees and available remedies. Requests concerning a separate Group company are considered in accordance with the correct legal entity's responsibilities and applicable law.
Official forms and fees: Current prescribed forms and fee information are available from the Information Regulator's PAIA resources. Any applicable charges are governed by law.
8. PAIA safeguards for confidential and commercially sensitive records
This manual is a route to records, not an unconditional publication licence for internal information. Requests must be decided record by record, within statutory periods and with any prescribed third-party notice, fees, reasons and remedies.
The following statutory provisions may apply, depending on the circumstances of the particular request:
- Section 63: protection of qualifying third-party personal information.
- Section 64: third-party trade secrets, commercially harmful information and qualified confidence.
- Section 65: duties of confidence owed by agreement.
- Section 66: risk to personal safety, systems or specified security/property interests.
- Section 67: legally privileged records (unless privilege is waived).
- Section 68: qualifying HoldCo trade secrets, financial/commercial/technical information, negotiating prejudice and proprietary software.
- Section 69: protected third-party research records.
- Section 70: mandatory public-interest disclosure if statutory conditions are met.
- Section 71: severance and partial access where reasonably practicable.
Potentially protected information may include commercially sensitive feasibility studies, business plans, non-public supplier contracts, proprietary methods, financing analyses and pricing models, where the specific PAIA statutory test is met. A 'confidential' label alone is not a lawful reason for refusal. The relevant statutory test, disclosure overrides, severance and available remedies apply.
Common ownership does not combine all TradeCo/FinCo records with HoldCo's records or justify denying otherwise valid access. The lawful custodian and correct legal person must be identified. This manual does not exempt the business from POPIA, food-safety or consumer-protection requirements.
9. Remedy if a request is declined or delayed
A requester may use the applicable Form 5 complaint mechanism at the Information Regulator, and court remedies where applicable. A private body has no mandatory internal appeal procedure equivalent to the public-body internal appeal process. The Regulator identifies a generally applicable 180-day complaint period, with condonation processes where relevant. A decision notice will provide the applicable remedies and time limits where required.
10. Processing personal information under POPIA (section 51)
10.1 Purposes
Group strategy/governance, corporate administration, website and partnership communications, lawful employment/vendor administration, security and regulatory compliance where applicable to the Company's activities and records.
10.2 Categories of data subjects and data
Potential categories include website enquirers (names/contact/proposal details), business representatives, employees/contractors where applicable, suppliers, advisers, shareholders and corporate stakeholders. Sensitive or children's data are not solicited through the website.
10.3 Recipients
Authorised HoldCo team members, relevant operating subsidiaries where appropriate, professional advisers, regulators (where lawfully required) and contracted technology/mail/security providers.
10.4 Cross-border processing
Website infrastructure and security providers and communications services may process data across borders.
10.5 General security measures
Access controls and authentication, encrypted transport, need-to-know access, appropriate contractual provider measures, technical security review, incident handling and secure destruction.
11. Availability, languages and review
This is a private-body manual. The Regulator's PAIA Guide explains that section 51 does not mandate the private-body manual itself be published in several official languages; English is permissible. The Guide must be available as required by applicable Regulations, and additional languages may be appropriate for accessibility. Requests for accessible copies or language assistance may be directed to the contact details in section 1.
This Manual is maintained in digital format. Electronic copies are available on request through info@modumayo.co.za or 066 413 3763. To arrange an in-person inspection at 6597 Kubone Drive, Mamelodi West, Mamelodi, Gauteng, 0122 during normal business hours, please request an appointment in advance through the same contacts. PAIA section 51(3) governs public availability and inspection of the Manual. Any charges for copies must comply with applicable law. This Manual is reviewed as the Company's activities and legal obligations change.