Prepared in terms of Section 51 of the Promotion of Access to Information Act, No. 2 of 2000 (as amended) and the Protection of Personal Information Act, No. 4 of 2013.
For: TalentEdge Recruitment & Advisory
Owned by: Lulutho Investments (Pty) Ltd
Effective Date: 01 August 2026
1. Introduction and Purpose
This Manual is compiled to assist individuals in exercising their constitutional right to access information held by Lulutho Investments (Pty) Ltd t/a TalentEdge Recruitment & Advisory under the Promotion of Access to Information Act, No. 2 of 2000 ("PAIA") and the Protection of Personal Information Act, No. 4 of 2013 ("POPIA"). As a specialist recruitment and advisory consultancy operating within South Africa, we process personal information of job seekers, corporate clients, and internal employees. This manual outlines our record categories, data processing operations, and the steps required to submit a formal request for access.
2. Company Contact Details
- Registered Company Name: Lulutho Investments (Pty) Ltd t/a TalentEdge Recruitment & Advisory
- Registration Number: 2024/196617/07
- Physical Address: 31 Jan Groentjie Avenue, Johannesburg, 2194
- Postal Address: Same as physical
- Telephone Number: +27 82 694 2268
- Official Website: www.talentedge.co.za
3. Information Officer Contact Details
The designated Information Officer is responsible for handling all statutory compliance, POPIA enquiries, and formal PAIA access requests:
- Information Officer Name: Ms Lulu Mzili
- Designation: Managing Director
- Direct Email Address: info@talentedge.co.za
- Direct Telephone Number: +27 82 694 2268
4. Guide on How to Use PAIA
The Information Regulator of South Africa has compiled a comprehensive guide (available in all 11 official languages) on how to use PAIA to exercise your rights.
- The Guide is available for public inspection at the offices of the Information Regulator or directly on their official website: https://inforegulator.org.za/.
Contact Details for the Information Regulator South Africa:
- Physical Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
- Postal Address: P.O Box 31533, Braamfontein, Johannesburg, 2017
- General Enquiries Email: enquiries@inforegulator.org.za
- PAIA Complaints Email: PAIAComplaints@inforegulator.org.za
- POPIA Complaints Email: POPIAComplaints@inforegulator.org.za
5. Records Available in Terms of Other Legislation
Where applicable and required by law, our organisation maintains records in accordance with the following South African statutory legislation:
- Basic Conditions of Employment Act No. 75 of 1997
- Companies Act No. 71 of 2008
- Employment Equity Act No. 55 of 1998
- Labour Relations Act No. 66 of 1995
- Protection of Personal Information Act No. 4 of 2013
- Skills Development Levies Act No. 9 of 1999
- Unemployment Insurance Act No. 63 of 2001
- Value Added Tax Act No. 89 of 1991
- Income Tax Act No. 58 of 1962
6. Schedule of Records Held by the Private Body
This section lists the subjects and categories of information held by TalentEdge:
A. Automatically Available Records (No formal request required)
- Public marketing brochures, pamphlets, and corporate profiles.
- Publicly accessible content hosted on our official corporate website.
B. Corporate Administration & Act Records (Formal request via Form 2 required)
- Documents of incorporation and registration certificates.
- Minutes of Board/Director meetings.
- Statutory registers and corporate appointment records (Directors, Public Officer, Auditors).
- Intellectual property and trademark registrations.
C. Financial and Accounting Records (Formal request via Form 2 required)
- Annual Financial Statements (Audited or Reviewed).
- Tax Returns and supporting accounting ledgers.
- Banking records, statements, and electronic banking transactions.
- VAT records, supplier invoices, and asset registers.
D. Operational Recruitment & Placement Records (Formal request via Form 2 required)
- Candidate/Job Seeker Records: Curricula Vitae (CVs), certified ID documents, academic and professional qualification certificates, background check verifications (criminal, credit, and employment history), psychometric assessment results, interview scorecards, and consultant notes.
- Client/Employer Records: Service Level Agreements (SLAs), client company registration profiles, commercial billing information, detailed job specifications, and placement communication logs.
E. Human Resources Records (Formal request via Form 2 required)
- Employee employment contracts and non-disclosure agreements.
- Internal disciplinary codes, records, and dispute proceedings.
- Salary registers, payroll data, and statutory PAYE, UIF, and COIDA records.
- Leave records, training manuals, and performance review evaluations.
7. Protection of Personal Information (POPIA) Requirements
Our organisation processes personal information to safely and efficiently match high-performing job seekers with corporate employment vacancies and manage client partnerships.
A. Categories of Data Subjects and Information Processed
- Candidates: Full name, contact credentials, qualifications, employment history, financial history (remuneration expectations), gender, and race (solely for Employment Equity reporting metrics).
- Clients/Employers: Corporate representative names, business contact info, physical operating addresses, and financial banking coordinates.
- Suppliers: Vendor corporate names, contact details, trade references, and banking account credentials.
B. Recipients of Personal Information
- Prospective corporate employers looking to acquire specialized talent.
- Vetted background screening agencies (with explicit candidate consent).
- Regulatory authorities such as the South African Revenue Service (SARS) and the Department of Employment and Labour.
C. Transborder Flows of Personal Information
We do not typically transfer or store personal information outside the borders of the Republic of South Africa. If a specific placement requires a cross-border data transfer, it will only take place with the candidate's explicit prior written consent or through binding agreements that guarantee equivalent data protection levels as prescribed under Section 72 of POPIA.
D. Technical and Organisational Information Security Measures
- Encrypted cloud-based systems and secure physical storage files with restricted access controls.
- Advanced network firewalls, active anti-malware, and regular vulnerability scanning.
- Mandatory password protection policies combined with multi-factor authentication (MFA) on all user devices.
8. Procedure to Request Access to Records (PAIA)
To request access to a record held by TalentEdge that is not automatically available, the requester must complete the following steps:
- Step 1: Complete Form 2 (Request for Access to Record) in full. This form can be accessed on the Information Regulator South Africa official portal.
- Step 2: Submit the completed Form 2 directly to the Information Officer at info@talentedge.co.za.
- Step 3: The form must provide sufficient particulars to enable the Information Officer to identify the requested record/s and the identity of the requester.
- Step 4: The requester must explicitly specify which form of access is required and outline a physical postal address or email address within the Republic.
- Step 5: Clearly identify the constitutional right being protected or exercised and explain why the requested record is strictly required to protect that right.
- Step 6: If the request is made on behalf of another individual, the requester must submit reasonable proof of their legal capacity to represent the data subject.
9. POPIA Objection, Correction, or Deletion Requests
Data subjects have the right to object to the processing of their Personal Information, or request the correction or deletion of their records under Sections 11(3) and 24 of POPIA.
- To Object to Processing: Complete Form 1 (Objection to the Processing of Personal Information) and submit it to our Information Officer.
- To Correct or Delete Information: Complete Form 2 (Request for Correction or Deletion of Personal Information) and submit it to our Information Officer.
Both statutory forms are available directly on the website of the Information Regulator of South Africa.
10. Prescribed Fees
- Request Fee: A standard, non-refundable request fee is payable upfront before TalentEdge processes the request.
- Access Fee: If access is officially granted, additional fees are charged to cover reproduction, physical searches, and time-allocation costs.
- The exact fee schedule is determined by the Information Regulator and is published in the Government Gazette. In accordance with the regulations, any physical postage or transmission costs are for the account of the requester.
11. Availability of this Manual
This manual is available for inspection at our physical head office and is permanently published for download in the footer of our official website: www.talentedge.co.za.