top of page

Section 51 PAIA & POPIA Manual

Financial Mind (PTY) LTD

Effective Date: October 2026

Contact Email: admin@financialmind.college

​

1. Introduction and Purpose of the Manual

This Manual is prepared in terms of Section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA) and incorporates provisions from the Protection of Personal Information Act 4 of 2013 (POPIA).

 

It applies to Financial Mind (PTY) LTD (“Financial Mind”), a private body providing accredited financial education, Continuous Professional Development (CPD) programmes, and corporate learning solutions in South Africa. The objective is to assist requesters in accessing records held by Financial Mind and exercising their data privacy rights.

 

2. Legal and Regulatory Disclaimer

IMPORTANT NOTICE: All educational services, training records, and compliance manuals maintained by Financial Mind (PTY) LTD strictly serve educational, training, and regulatory development functions.

  1. No Financial Advice: Information provided within this manual or related organizational documentation does not constitute legal, tax, investment, or financial advice under the Financial Advisory and Intermediary Services (FAIS) Act 37 of 2002, or as regulated by the Financial Sector Conduct Authority (FSCA).

     

  2. Professional Discretion: Requesters, clients, and financial service providers (FSPs) remain responsible for their own regulatory compliance and professional judgments.

     

3. Contact Details & Information Officer

The responsibility for ensuring compliance with PAIA and POPIA has been delegated to the Information Officer of Financial Mind (PTY) LTD:

 

  • Entity Name: Financial Mind (PTY) LTD

    ​

  • Designated Information Officer: Managing Director / Designated Compliance Lead

    ​

  • General & Privacy Email: admin@financialmind.college

     

  • Website: financialmind.college

     

4. Guide on How to Use PAIA (Section 10 Guide)

The Information Regulator (South Africa) has compiled a guide in each official language containing information to assist any person wishing to exercise any right contemplated in PAIA and POPIA.

 

5. Records Automatically Available Without Formal Request

The following categories of records are automatically available for inspection, download, or purchase on our website without submitting a formal PAIA request:

 

  • Public course catalogs, CPD learning programme overviews, and fee structures.

     

  • Company marketing materials and public accreditation notices.

     

  • Published Privacy Policy, Terms & Conditions, and Cookie Policy.

    ​

6. Subjects and Categories of Records Held

Financial Mind holds records in the following areas (access to which is subject to formal PAIA request procedures, statutory limitations, and POPIA privacy constraints):

 

  • Company and Secretarial Records: Statutory registration documents, Memorandum of Incorporation (MOI), director registers, share registers, board resolutions, and statutory compliance filings.

     

  • Financial and Commercial Records: Annual financial statements, tax returns, VAT records, auditor reports, accounting journals, invoice ledgers, and third-party payment gateway transaction metadata (processed via Yoco and Peach Payments).

     

  • Learner and Educational Records (LMS): Student enrollment registers, course progress logs, assessment scores, attendance records, FPI member validation numbers, and issued CPD certificates generated within our MoodleCloud Learning Management System.

     

  • Human Resources and Subject Matter Expert (SME) Records: Independent contractor agreements with Subject Matter Experts (SMEs), employment contracts, performance management records, and internal administrative contact details.

     

  • Regulatory and Accreditation Records: Formal correspondence with the Financial Planning Institute of Southern Africa (FPI), FSCA Financial Education Commitment Charter alignment documentation, and CPD activity accreditation approvals.


​

7. Processing of Personal Information (POPIA Section 51(1)(c))

A. Purpose of Processing

Financial Mind processes personal information to deliver accredited learning solutions, verify FPI membership details for CPD credit allocation, process payments via Peach Payments and Yoco, administer our MoodleCloud LMS, and fulfill tax and company law mandates.

 

B. Categories of Data Subjects

  • Learners & Clients: Full names, ID/passport numbers, email addresses, employer details, payment references, and FPI membership numbers.

     

  • SMEs & Suppliers: Name, banking details, registration numbers, tax details, and professional contracts.

     

C. Transborder Data Flows

Where learning data is hosted on cloud infrastructure (e.g., MoodleCloud servers), Financial Mind ensures compliance with Section 72 of POPIA by confirming that data operators operate under substantially similar data protection laws or binding contracts.

 

8. Procedure for Requesting Access to Records

  1. Form Requirement: Requesters must complete Form 2 (Prescribed PAIA Request Form available on the Information Regulator’s website).

     

  2. Submission: Send the completed form alongside proof of identity to admin@financialmind.college.

     

  3. Sufficient Detail: The request must provide sufficient detail to enable the Information Officer to identify the record, the requester, and the specific right being exercised.

     

  4. Prescribed Fees: A request fee and access fee may apply in accordance with PAIA regulations prior to the release of non-personal records.

     

9. Grounds for Refusal of Access

Financial Mind may refuse access to requested records on statutory grounds specified in PAIA, including:

 

  • Mandatory protection of the privacy of a third party who is a natural person.

     

  • Protection of commercial or confidential information of a third party or Financial Mind.

     

  • Mandatory protection of safety of individuals and protection of property.

     

  • Records privileged from production in legal proceedings.

bottom of page