Manual prepared in accordance with section 51 of the Promotion of Access to Information Act no. 2 of 2000 private body manual

1. Contact details of the Private body

1.1 Name of Body: Synergy Evolution Private Limited (“Synergy Evolution”)

1.2 Physical Address: Clearwater Office Park, Corner Millenium Road & Christian de Wet Road Clearwater, Johannesburg 1735

1.3 Postal Address: 115 Wilde Amandel Avenue, Roodekrans, Roodepoort, 1724

1.4 Telephone: +27 (0) 64 524 8833, +27 (0) 10 007 5980, +27 (0) 76 350 5955,

1.5 Head of Body: Sihle John Nhlapo

1.6 Designated Accounts Advisory Services Manager: Mpho Nhlapo

1.7 Who we are: Synergy Evolution conducts business as an asset management specialist and complimentary business services, and solutions provider across various sectors.

2. Section 10 guide

2.1 In terms of section 10 of the Promotion of Access to Information Act No. 2 of 2000 (“Act”), the South African Human Rights Commission has published a guide containing information relating to:

2.1.1 obtaining access to a record of a Private Body and the assistance that is available from the South African Human Rights Commission in this regard;

2.1.2 lodging a court application against a decision by the head of a private body;

2.1.3 the fees that are payable for accessing a record; and

2.1.4 the voluntary disclosure of information by private bodies.

2.2 The contact details of the South African Human Rights Commission are as follows:

South African Human Rights Commission: PAIA Unit

Physical Address: Braampark Forum 3 33 Hoofd Street Braamfontein Johannesburg Gauteng 2017

Telephone: 011 877 3600

Facsimile: 011 404 0668



3. Section 52(2) Notice

No notice has been published.

4. Records available in terms of other legislation

No notice has been published.Insofar as may be applicable, the group keeps records of information to the extent required in terms of, inter alia, the following legislation:

4.1. Basic Conditions of Employment Act 75 of 1997;

4.2. Broad Based Black Economic Empowerment Act No.53 of 2003;

4.3. Companies Act 71 of 2008;

4.4. Compensation for Occupational Injuries and Diseases Act 130 of 1993;

4.5. Consumer Protection Act 68 of 2008;

4.6. Copyright Act 98 of 1978; and

4.7. Criminal Procedure Act 51 of 1977;

4.8. Electronic Communications and Transactions Act 25 of 2002;

4.9. Employment Equity Act 55 of 1998;

4.10. Financial Intelligence Center Act,38 of 2001;

4.11. Income Tax Act 58 of 1962;

4.12. Insolvency Act 24 of 1936;

4.13. Insurance Act 27 of 1943;

4.14. Labour Relations Act66 of 1995;

4.15. Medical Schemes Act 131 of 1998;

4.16. Occupational Health and Safety Act 85 of 1993;

4.17. Protection of Personal Information Act 4 of 2013;

4.18. Regulation of Interception of Communications and Provisions of Communications-related Information Act 70. of 2002;

4.19. Skills Development Act 97 of 1998;

4.20. Skills Development Levies Act 9 of 1999;

4.21. Unemployment Insurance Act 63 of 2001; and

4.22. Value-Added-Tax Act 89 of 1991.

5. Company records

5.1 No notice has been submitted to the Minister of Justice and Constitution Development regarding the categories of records which are available without a person having to request access in terms of s52(2) of PAIA. The information on the website of the business, however, it’s automatically available without having to request access in terms of PAIA.

5.2 General information about Synergy Evolution can be accessed via the internet on, which is available to all persons with access to the internet.

5.3 Company Records Classification Key:

Classification Number




May be disclosed

Public access document


May not be disclosed

Request for, or after commencement of, criminal or civil proceedings [s7]


May be disclosed

Subject to copyright


Limited disclosure

Personal information that belongs to the requester of that information [s61]


May not be disclosed

Unreasonable disclosure of personal information of natural person [s63(1)]


May not be disclosed

Likely to harm the commercial or financial interests of third party [s64(a)(b)]


May not be disclosed

Likely to harm a third party in contract or other negotiations [s64(c)]


May not be disclosed

Would breach a duty of confidence owed to a third party in terms of an agreement [s65]


May not be disclosed

Likely to compromise the safety of individuals or protection of property [s66]


May not be disclosed

Legally privileged document [s67]


May not be refused

Environmental testing / investigation which reveals public safety / environmental risks [s64(3)]


May not be disclosed

Commercial information of private body [s68]


May not be disclosed

Likely to prejudice research and development information of the Synergy Evolution or a third party [s69]


May not be refused

Disclosure in public interest [s70]


5.4 Summary Records Availability:

Departmental Records


Classification Number

Communications and Corporate Affairs Division

Current Product Information



Public Corporate Records



Media Releases





Environmental Division

Environmental Policy



Environmental Records

11, 14




Human Resources Division

Employee Records

4, 5, 8, 9


Employment Contracts

4, 5, 8


Personnel Guidelines, Policies and Procedures



Employee Medical Records

4, 5, 8, 9




Financial Division

Financial Statements



Financial and Tax Records (Company and Employees)

1, 8


Asset Register





Legal / Company Secretarial Division

General Contract Documentation

6, 10, 13


Company Guidelines, Policies and Procedures

10, 13


Trade Marks



Statutory Records


Marketing and Sales Division

Market Information



Product Brochures



Marketing and Product Strategies



Product Sales Records



Customer Information and Customer Database

5, 6, 9


Quality Records



6. Purpose of processing of personal information

We process personal information to:

6.1. provide our goods or supply our services;

6.2. better understand our data subjects’ needs when doing so;

6.3. keep our data subject records up-to-date;

6.4. manage employees in general;

6.5. manage supplier contracts in general;

6.6. manage dealer relationships in general;

6.7. manage customers in general;

6.8. manage customer credit in general;

6.9. market to customers in various countries;

6.10. enforce debts;

6.11. market goods and services to prospects;

6.12. to engage with investors and the media;

6.13. process customer requests or complaints; and

6.14. process personal information of employees for forensic purposes.

7. Data subjects categories and their personal information

We process many different categories of personal information, including:

7.1. contact details, such as phone numbers, physical and postal addresses, and email addresses;

7.2. personal details, such as names and ages;

7.3. demographic details, such as races and age groups;

7.4. health information;

7.5. biometric information;

7.6. account numbers;

7.7. background information;

7.8. contract information;

7.9. credit information;

7.10. market intelligence information; and

7.11. debt and debtor information.

8. Planned recipients of personal information 

We give the following people personal information that we process in the ordinary course of business to fulfill our obligations to our customers or clients:

8.1 Statutory authorities;

8.2 Law enforcement;

8.3 Tax authorities;

8.4 Financial institutions;

8.5 Medical schemes;

8.6 Employee pension and provident funds;

8.7 Industry bodies;

8.8 contractors, vendors, or suppliers;

8.9 agents, distributors, or other resellers;

8.10 operators, other responsible parties, or co-responsible parties; and

8.11 third party vendors (such as software developers) to help us maintain our services.

9. Planned trans-border flow of personal information 

9.1 We may send personal information outside of South Africa to various countries. We will only transfer data to other countries who have similar privacy laws to South Africa’s or recipients who can guarantee the protection of personal information to the same standard we must protect it.

9.2 For more information on this, please see our privacy policy.

10. Security

10.1 We secure our data by maintaining reasonable measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction. We also take reasonable steps to keep personal information accurate, current, complete and reliable for its intended use.

11. The request procedure

11.1 Forms and fees

11.1.1 A request for information must be made in the prescribed form, must be addressed to the Information Officer and must be submitted with the prescribed fee.

11.1.2 The prescribed request form and details regarding the prescribed fees are available from the South African Human Rights Commission, whose contact details are set out in this document. The prescribed request form and prescribed fee details are available on the website of the Department of Justice and Constitutional Development (

11.2 Form of request

11.2.1. The requester must use the prescribed form to make the request for access to a record. This request must be made to the address, facsimile number or electronic mail address of the information Officer and must contain the requester’s postal address and facsimile number within the Republic.

11.2.2. The requester must provide sufficient detail on the request form to enable the Information Officer to identify the record requested and the requester. The requester should also indicate which form of access is required. The requester should indicate if notice of the decision of the Information Officer is required in any manner, other than in writing, and if so, the necessary particulars to be so informed.

11.2.3. In the request form, the requester must identify the right that is sought to be exercised or to be protected and provide an explanation of why the requested record is required for the exercise or protection of that right.

11.2.4. If a request is made on behalf of another person, the requester must submit proof of the capacity in which the requester is making the request to the satisfaction of the Information Officer.

11.3 Fees

11.3.1 A requester who seeks access to a record containing personal information about that requester, is not required to pay the request fee. Every other requester, who is not a personal requester, must pay the required request fee.

11.3.2 The Information Officer must by notice, require the requester to pay the prescribed fee, if any, set out in the notice, before further processing the request.

11.3.3 The requester may lodge an application with a court against the payment of the prescribed request fee.

11.3.4 After the Information Officer has made a decision on the request, the requester must be notified in the required form.

11.3.5 If the request is granted then a further access fee must be paid for the search, reproduction, preparation and for any time, in excess of the prescribed hours, required to search and prepare for the record disclosure.

12. Remedies

If request for access is denied, the requester may:

  • apply to a court with appropriate jurisdiction, or
  • lodge a complaint with the Information Regulator, for the necessary relief.

13. Availability of the manual

13.1 This manual is available for inspection by the general public upon request during office hours and free of charge at Synergy Evolution’s physical address as well as on Synergy Evolution’s website,

14. Updates to this manual

14.1 This manual will be updated whenever we make material changes to the current information.

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⚠️ Scammer Alert ⚠️

We’ve been alerted to fraudulent job offers being circulated via WhatsApp, Telegram, and email by individuals falsely claiming to represent  Synergy Evolution.

These offers typically involve part-time online jobs, including watching YouTube videos for payment, and may ask for personal information.

Please be aware:

  • Synergy does not offer such jobs.
  • We never request personal information or payment for job applications in this manner.
  • All legitimate job openings are posted exclusively on our official website and through verified channels.

If you’ve received any suspicious messages:

  1. Do not engage or provide any personal details.
  2. Block and report the sender through the respective platform.
  3. Contact us directly if you have any questions or concerns regarding job offers.

Your security is our top priority. Thank you for your vigilance and for being a valued member of our community.

Synergy Evolution Team