Effective Date: 2026-07-06

Uniquely Recycled & Asset Disposal (Pty) Ltd (“URAD-SA”) is committed to conducting business in a transparent, ethical and lawful manner.

This PAIA Manual has been developed in accordance with the Promotion of Access to Information Act (PAIA) and supports our obligations under the Protection of Personal Information Act (POPIA).

The purpose of this manual is to:

• promote access to information held by URAD-SA;
• explain how information may be requested;
• demonstrate our commitment to protecting personal information; and
• outline the measures implemented to ensure compliance with South African legislation.

URAD-SA is a South African Information Technology Asset Disposition (ITAD) and e-Waste Management company providing:

• Secure IT Asset Disposal
• Secure Data Destruction
• Electronic Waste Recycling
• Asset Auditing
• Chain of Custody Management
• Sustainable Resource Recovery

As part of these services, URAD-SA processes limited personal information relating to clients, suppliers, employees, contractors and service providers.

URAD-SA has implemented an Information Governance Framework based on recognised governance principles and South African legislation.

Our compliance programme follows seven key steps.

We identify what personal information is processed throughout our business and assess how it is collected, stored, used, shared and destroyed.

This includes information relating to:

• Clients
• Employees
• Contractors
• Suppliers
• Service providers
• Visitors
• Operational records

URAD-SA has appointed an Information Officer responsible for ensuring compliance with PAIA and POPIA.

The Information Officer is responsible for:

• administering access to information requests;
• promoting lawful processing of personal information;
• maintaining compliance programmes;
• responding to privacy enquiries;
• liaising with the Information Regulator where required.

Name: Paula Gaviana Peffer
Position: Managing Director / Information Officer
Email: paula@urad-sa.co.za
Telephone: 010 495 4925

URAD-SA regularly evaluates privacy and information security risks associated with our operations.

This includes risks relating to:

• Personal information
• Client information
• Asset registers
• Data-bearing devices
• Secure transportation
• Data destruction
• Third-party contractors
• Electronic waste processing
• Information security

Risk assessments are reviewed periodically to ensure appropriate controls remain effective.

URAD-SA has implemented documented policies and procedures that support legal compliance and good governance.

These include:

• PAIA Manual
• POPIA Compliance Framework
• Information Security Policy
• Chain of Custody Procedures
• Data Destruction Procedures
• Records Management Procedures
• Data Breach Response Procedure
• Records Retention and Disposal Schedule

To protect confidential and personal information, URAD-SA has implemented internal controls including:

• Controlled access to company records
• Secure storage of documentation
• Chain of Custody procedures
• Asset verification processes
• Secure transport procedures
• Certified destruction of data-bearing devices
• Access controls
• Regular compliance reviews

URAD-SA recognises that compliance is an ongoing process.

Employees receive awareness training covering:

• PAIA
• POPIA
• Information Security
• Confidentiality
• Secure handling of information
• Data breach reporting
• Records management

Training is supported through regular communication and operational reviews.

Our governance framework is reviewed periodically to ensure continued compliance with:

• Promotion of Access to Information Act (PAIA)
• Protection of Personal Information Act (POPIA)
• National Environmental Management legislation
• Occupational Health and Safety legislation
• Other applicable South African laws

Where necessary, policies and procedures are updated to reflect legislative or operational changes.

URAD-SA processes personal information only where necessary for legitimate business purposes.

This may include:

• Client information
• Employee records
• Supplier information
• Contractor information
• Financial records
• Asset management records
• CCTV footage where applicable
• Contact information

Personal information is processed lawfully, securely and only for authorised business purposes.

Any person may request access to records held by URAD-SA in accordance with PAIA.

Requests must be submitted in writing to the Information Officer.

Where applicable:

• prescribed request forms must be completed;
• proof of identity may be required;
• applicable request fees may apply;
• requests will be processed within the timeframes prescribed by PAIA.

This manual is available:

• on the URAD-SA website;
• from the Information Officer upon request; and
• at the registered office of URAD-SA during normal business hours.

Registered Office

Uniquely Recycled & Asset Disposal (Pty) Ltd

Unit 3, 29 7th Street, Delarey, Johannesburg, 1709, South Africa
Telephone: 010 495 4925
Email: info@urad-sa.co.za
Website: www.urad-sa.co.za

Paula Gaviana Peffer
Managing Director / Information Officer

Email: paula@urad-sa.co.za
Telephone: 078 178 1153

This PAIA Manual will be reviewed periodically to ensure that it remains accurate, relevant and compliant with applicable legislation.