1. Introduction and purpose
The Promotion of Access to Information Act 2 of 2000 (PAIA) gives everyone the right to access records held by public and private bodies, subject to limited grounds for refusal. Section 51 of PAIA requires every private body to compile a manual that explains how to make a request.
This manual is published by Load Factor Group (Pty) Ltd ("LFG"), a hub-to-hub airfreight consolidator in South Africa. It also covers Lode, the logistics management platform LFG builds and operates.
This manual is useful to you if you want to:
- find out which categories of records LFG holds, and which are available without a formal request
- understand how to request access to a record, and what it costs
- understand how we process personal information under the Protection of Personal Information Act 4 of 2013 (POPIA)
- know how to challenge a refusal or lodge a complaint
Nothing in this manual creates a right to receive information beyond what PAIA provides.
2. Contact details
| Detail | Information |
|---|---|
| Private body | Load Factor Group (Pty) Ltd |
| Registration number | 2021/429913/07 |
| Head of the private body | Bruce Van Wyk |
| Information Officer | Brandon Van Wyk |
| Deputy Information Officer(s) | None appointed |
| Physical address | 154 Forest Road, Benoni, 1509, South Africa |
| Postal address | 154 Forest Road, Benoni, 1509, South Africa |
| Phone | +27 72 942 7588 |
| Email for PAIA requests | privacy@loadfactor.co.za |
| Website | lode.mobi |
Requests should go to the Information Officer by email or post. We'll acknowledge receipt and tell you the outcome within the timelines in section 7.
3. The Information Regulator's PAIA Guide
The Information Regulator publishes a guide on how to use PAIA and POPIA, in all official languages, on its website at inforegulator.org.za. You can also ask the Regulator for a printed copy.
The Regulator's contact details are:
- Address: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191
- Phone: 010 023 5200 (toll-free 0800 017 160)
- General enquiries: enquiries@inforegulator.org.za
- PAIA complaints: PAIAComplaints@inforegulator.org.za
4. Records available without a formal request
These records are available to anyone without filing a PAIA request. Some may be free, and others may carry a copying or postage cost:
| Record | Where to get it |
|---|---|
| This PAIA manual and our POPIA Privacy Policy | lode.mobi/privacy |
| Terms of service and service descriptions | lode.mobi/terms |
| Published rates and service information | On request by email |
| Shipment tracking status for your own shipment | Through the tracking link or by contacting your account manager |
| Company registration and VAT details | On request by email |
For any record not listed here, make a formal request under section 7.
5. Records held by LFG and Lode
The table below lists the categories of records LFG holds. Access to any record is subject to PAIA's grounds for refusal, including protection of third-party personal information, privileged information and commercial confidentiality.
| Category | Examples | Held for |
|---|---|---|
| Company records | Founding documents, share register, board and shareholder resolutions, minutes | Companies Act 71 of 2008 |
| Financial records | Ledgers, bank statements, invoices, supplier and customer accounts, annual financial statements | Companies Act, Tax Administration Act 28 of 2011 |
| Tax and VAT records | VAT returns (filed monthly), PAYE and income tax records, customs declarations | Value-Added Tax Act 89 of 1991, Income Tax Act 58 of 1962, Customs and Excise Act 91 of 1964 |
| Employment records | Employee contracts, payroll, leave, disciplinary records, UIF and SDL records | Basic Conditions of Employment Act 75 of 1997, Labour Relations Act 66 of 1995, Unemployment Insurance Act 63 of 2001 |
| Operational records | Shipment waybills, AWB and manifests, uplift confirmations, delivery records, tracking logs | Business records; customs and aviation requirements |
| Customer and supplier records | Contracts, rate sheets, correspondence, account files | Contract and business records |
| Lode system records | User accounts, activity logs, system configuration | Business records; POPIA security obligations |
| Insurance records | Policies, claims, cargo liability records | Business records |
| Legal and compliance records | Privacy and PAIA documentation, breach records, complaints | POPIA, PAIA |
We haven't listed records in categories that don't exist at LFG.
6. Personal information we process (POPIA section 51)
This section gives the detail that POPIA requires a private body to include in its PAIA manual. Our full POPIA Privacy Policy is available at lode.mobi.
| Item | Detail |
|---|---|
| Categories of data subjects | Customers and their staff, consignors and consignees, suppliers and airline partners, website visitors, Lode users, and job applicants and employees |
| Categories of personal information | Contact details, company and VAT details, shipment and delivery details, billing and payment records, user account data, technical data, and employment records |
| Purpose | Delivering freight, tracking shipments, billing, meeting legal obligations, keeping systems secure, and employment administration |
| Recipients | Airlines and ground handlers, transport partners, Google Cloud and Firebase, Meta (WhatsApp), accountants, banks, and authorities where the law requires it |
| Transfers outside South Africa | Google Cloud hosting in Belgium (europe-west1), and Firebase and WhatsApp processing abroad. Transfers are made under POPIA section 72 safeguards |
| Security measures | Encryption in transit and at rest, role-based access controls, Firebase Authentication, a private code repository, activity logging, backups, and staff confidentiality obligations |
We'll review this section whenever our processing changes.
7. How to request a record
Step 1: Use the right form. Complete Form 2 (Request for Access to Record) from the PAIA Regulations 2021, available at inforegulator.org.za. Any other form will be treated as incomplete.
Step 2: Give us enough detail. Include:
- your full name, identity number or passport number, and contact details
- if you're acting for someone else, proof of their authority
- enough detail to identify the record and the right you want to exercise or protect
- the form of access you want (copy, inspection, electronic copy)
- your preferred language, if any, and how you want to be contacted
Step 3: Send it. Email the completed form to the Information Officer at privacy@loadfactor.co.za, or post it or hand-deliver it to our physical address in section 2.
Step 4: Pay the request fee. A request fee is payable before we process your request (see section 8).
Timelines. We'll decide within 30 days of receiving a complete request. We may extend this by up to 30 more days if we need to search a large number of records or consult third parties, and we'll tell you why. We'll notify you of our decision on Form 3, along with any fees payable.
Verifying identity. We may ask you to prove who you are before we release personal information about you.
8. Fees
Fees are set by the PAIA Regulations 2021 (Annexure B). We can't charge more than the prescribed amounts.
| Fee | When payable | Amount |
|---|---|---|
| Request fee | Before we process any request | R100 |
| Deposit | If we estimate an access fee, we may require a deposit of up to one-third of it before we give access (PAIA s54(2)) | Up to one-third of the access fee |
| Access fee | Once we grant access: the cost of searching for, preparing and copying the record, subject to the capped fees in Annexure B | Per Annexure B, plus actual postage or electronic transfer costs |
We'll give you a fee estimate on Form 3 before we process your request. Records may be withheld until fees are paid. If you think a fee is wrong, you can apply to a court.
You're exempt from paying the access fee if the law exempts you, and in some other circumstances set out in PAIA section 54. Fees don't include VAT, but a VAT-registered private body may add VAT to prescribed fees.
9. Grounds for refusal and your remedies
Grounds for refusal. PAIA allows us to refuse access in limited cases, including where disclosure would unreasonably reveal personal information about a third party (ss 63-64), reveal commercial or privileged information (ss 64-67), endanger safety, or breach a duty of confidence. If we refuse, we'll explain why in writing, with the section relied on (PAIA ss 62-70).
Partial access. Where only part of a record is protected, we'll give you the rest with the protected parts removed.
Remedies. A private body has no internal appeal. If your request is refused, or we don't respond in time, you can:
- Complain to the Information Regulator using the complaint form (PAIA s77A). Send PAIA complaints to PAIAComplaints@inforegulator.org.za.
- Apply to a court with jurisdiction for a review of the decision (PAIA s78). You may do this without complaining to the Regulator first, and the court can order access.
We'll treat any complaint or refusal as an opportunity to fix the problem, and we'll cooperate with the Regulator fully.
10. Updating this manual
We'll review this manual at least every two years, and whenever our records, processing or contact details change (PAIA s51(2)). The date at the top shows the last update. We'll also keep our Information Officer's registration with the Information Regulator current.
This manual is published on lode.mobi and available at 154 Forest Road, Benoni, 1509, South Africa for inspection during business hours.