Manual published in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 ("PAIA"), as amended by the Protection of Personal Information Act 4 of 2013 ("POPIA").

The exemption that relieved most small private bodies of this obligation expired on 31 December 2021. Since 1 January 2022 every private body must have this manual available at its principal place of business, on its website, and to anyone who asks.

1. Particulars of the private body

  • Registered name: VDM DIGITAL (PTY) LTD
  • Trading as: VDM Digital
  • Company registration number: 2026/179981/07
  • Type of entity: Private company incorporated in the Republic of South Africa
  • Physical and postal address: 13 Jigger Avenue, Somerset West, Western Cape, 7130, South Africa
  • Telephone: Our telephone number is published in the current version of this document on our website, and is available on request by email.
  • Email: erik@vdmdigital.io
  • Website: https://vdmdigital.io

Head of the private body

The head of the body for PAIA purposes is Erik van der Merwe, Co-founder and Information Officer.

Information Officer

  • Name: Erik van der Merwe
  • Capacity: Co-founder and Information Officer
  • Email: erik@vdmdigital.io
  • Postal address: as above

Deputy Information Officer

  • Name: Nico van der Merwe
  • Capacity: Co-founder and Deputy Information Officer
  • Email: nico@vdmdigital.io

All requests under PAIA must be addressed to the Information Officer at the address above.

2. The PAIA Guide

The Information Regulator has compiled a guide, in terms of section 10 of PAIA, on how to use the Act. It is available in all official languages, free of charge, from:

Information Regulator (South Africa)

3. Records available without a formal request

The following are already published and may be obtained from our website or by asking us, with no PAIA request and no fee:

4. Records held, by category

We hold the following categories of record. Listing a category here does not mean it will be released — a request for it is still decided under Chapter 4 of PAIA, and most of what follows is protected from disclosure.

4.1 Company and statutory records

Memorandum of incorporation, CIPC filings, share register, director records, minutes and resolutions.

4.2 Financial records

Invoices, quotes, receipts, bank statements, ledgers, tax returns and supporting schedules, and payment-processor settlement records. Retained for five years under the Companies Act 71 of 2008 and the Tax Administration Act 28 of 2011.

4.3 Client records

Client details, contracts, statements of work, proposals, project correspondence, deliverables, credentials for systems we manage, and support history.

4.4 Employee, contractor and recruiter records

Employment and contractor agreements, remuneration records, statutory deductions, recruiter agreements and referral records.

4.5 Website and systems records

Source code and configuration for this website and the systems we build, first-party website analytics events, sign-in and access logs, and video testimonial submissions with their consent records.

4.6 Third-party records

Agreements with our hosting, database, email and payment providers, and the records those providers generate on our behalf.

5. Records held under other legislation

Records are also kept in terms of, among others: the Companies Act 71 of 2008; the Income Tax Act 58 of 1962; the Tax Administration Act 28 of 2011; the Value-Added Tax Act 89 of 1991 (should we become a registered vendor); the Basic Conditions of Employment Act 75 of 1997; the Labour Relations Act 66 of 1995; the Unemployment Insurance Act 63 of 2001; the Compensation for Occupational Injuries and Diseases Act 130 of 1993; the Electronic Communications and Transactions Act 25 of 2002; the Consumer Protection Act 68 of 2008; and POPIA.

6. How to request a record

  1. Use Form 2 of the PAIA Regulations (the Request for Access to Record form). It is available from https://inforegulator.org.za and we will email it to you on request.
  2. Complete it in full. State the record you want with enough particularity for us to find it, the form of access you want, your contact details, and — if you are requesting the record in order to exercise or protect a right — which right, and how the record will help you exercise or protect it. Section 50 of PAIA makes that the test for a private body, and a request that does not address it will be refused.
  3. Send it to the Information Officer at erik@vdmdigital.io, or deliver it to our address above.
  4. If you are requesting on someone else's behalf, attach proof of your authority.

Your own personal information: a request for access to your own personal information, or to correct it, is made under POPIA on Form 2 (access) or Form 3 (correction or deletion) of the POPIA Regulations, sent to the same address. There is no fee for a request for your own personal information.

7. Timelines

  • We must decide within 30 days of receiving a compliant request.
  • We may extend by a further 30 days where the request is for a large number of records or requires a search of records held elsewhere. We will tell you in writing, with reasons, before the first 30 days expire.
  • Our decision will be in writing. If we refuse, we will give the reasons and the provisions of PAIA we rely on, and tell you about your right to apply to court.

8. Fees

The fees prescribed in the PAIA Regulations apply:

  • A request fee is payable before we process a request for a record that is not your own personal information.
  • An access fee covers reproduction, search and preparation time, and postage. We will give you a written estimate before doing the work, and may require a deposit where preparation is expected to exceed the prescribed threshold.
  • No fee is charged for a request for your own personal information.
  • The current prescribed amounts are set by regulation and change from time to time. We will quote you the amounts in force when you make your request rather than publish figures here that go stale.

9. Grounds on which we must or may refuse

Chapter 4 of PAIA requires or permits refusal where disclosure would involve:

  • Section 63 — unreasonable disclosure of the personal information of a third party. This is a mandatory refusal.
  • Section 64 — commercial information of a third party: trade secrets, financial or commercial information likely to cause harm, or information supplied in confidence in a contractual negotiation. Mandatory.
  • Section 65 — a breach of a duty of confidence owed to a third party.
  • Section 66 — endangering the life or physical safety of a person, or prejudicing the security of property or a system.
  • Section 67 — records privileged in legal proceedings.
  • Section 68 — our own commercial activities: our trade secrets, our confidential financial or commercial information, and information that could put us at a disadvantage in negotiations or commercial competition. This is the ground most likely to apply to a request about our client work, our pricing or our source code.
  • Section 69 — records of research where disclosure would expose the researcher or the subject.
  • Section 70 — the public interest override: even where a ground above applies, we must grant access if disclosure would reveal a substantial contravention of the law or an imminent and serious public safety or environmental risk, and the public interest in disclosure clearly outweighs the harm.

Where part of a record is protected and part is not, we will release the part that is not, with the protected part severed.

10. If you are unhappy with our decision

You may:

  1. Lodge a complaint with the Information Regulator (South Africa) — complaints.IR@justice.gov.za; or
  2. Apply to a court with jurisdiction, within 180 days of being notified of our decision.

You do not have to complain to the Regulator before going to court, and doing so does not stop the 180-day clock. There is no internal appeal within VDM Digital — we are a private body, and PAIA provides none.

11. Availability of this manual

This manual is available:

We will provide it in a language you can read, and in an alternative format on reasonable request if you have a disability.

12. Updates

This manual is reviewed at least annually and whenever our records, our structure or the law changes materially. The current version, its publication date and its version number are shown on this page, and every previous published version is retained.

Last updated: 10 September 2026.