This Manual applies to information held by:
Cellfind (Pty) Ltd.

In terms of section 51(2) of the Promotion of Access to Information Act, this Manual will be updated as and when the need arises.  

  1. Introduction
  2. Objectives of Manual
  3. List of Records and Information
  4. Entry Point for Requests
  5. Who may RequestInformation or Records in Terms of the Act
  6. Request Procedure
  7. Request Fees
  8. Granting or Refusal of Requests
  9. Appeal
  10. The Human Rights Commission Guide
  11. Other Legislation in Terms of which Information may be Requested -section 51 (d)
  12. Description of Subjects and Categories of Information on which the Aforementioned Companies Hold Records -section 51(e)
  13. Form C
  14. Charge Sheet




The Promotion of Access to Information Act, 2 of 2000 ("the Act") came into operation on 9 March 2001 . The Act seeks to give natural and/or juristic persons the right of access to records held by either a private or public body, subject to certain limitations, in order to enable them to exercise or protect their rights.

Section 51 of the Act obliges private bodies to compile a Manual which would assist a person to obtain access to information held by such a private body and stipulates the minimum requirements a manual has to comply with. Section 51 requires a manual to contain the following:

•  Postal and street address, phone and fax number and, if available, the electronic mail address of the head of the private body;

•  A description of the guide referred to in section 10 of the Act , if available , and how to obtain access to it.

•  Categories of information available without formal request, if any .

•  A description of the records available in accordance with any other legislation

•  A description of the subjects on which the body holds records and the categories of records held on each subject,

•  Such other information as may be prescribed.

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The objectives of this Manual are:

•  To provide a list of all records held by the mentioned companies;

•  To set out the requirements with regard to who may request information in terms of the Act as well as the grounds on which a request may be denied ;

•  To define the manner and form in which a request for information must be submitted;

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The information held by the aforementioned companies has been divided into two hundred categories. These categories have been grouped into twelve subjects, each of which describes a single business entity, for example, "Human Resources". For ease of understanding and navigation, an additional level has been added between the "subject" and "category" levels. This additional level describes more accurately the sub-set of categories that falls under it. For example, under the additional level, the subject "Performance and Remuneration" is made up of information categories describing payroll, bonus and incentives, and employee performance information. The categories of information are not exhaustive but are merely meant to give a broad indication of the information subject and categories held by Cellfind, without specification. A category may therefore contain sub-categories and sub-sets of information, which are not specifically listed. (See Page 9 below )

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In order to ensure that the mentioned Cellfind companies comply with the Act the managing directors of the mentioned companies have designated Cellfind Client Services as the onlyentry point through which any request in terms of the Act must be channelled.

All requests in terms of the Act must be addressed to:


Cellfind Client Services:

Physical Address :

Cellfind Client Services 
1 st Floor, Renaissance Park
082 Vodacom Blvd

Postal Address :

Cellfind Client Services
PO Box 7085
Halfway House

Other :

Telephone: (011) 848 8200

Facsimile: (011) 848 8205

Electronic mail:

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5.1 The Purpose for which Information is required

The Act provides that a person may only request information in terms of the Act, if the information is required for the exercise or protection of a right.

Information will therefore not be furnished unless a person clearly provides sufficient particulars to enable the company to identify the right the requester is seeking to protect as well as an explanation of why the requested information is required for the exercise or protection of that right.

5.2 Requester Categories :

The capacity in which a requester requests information will determine the category he or she falls in. Please note that the requester category has a bearing on the charges pertaining to the access to information. ( See Page 31 and Request Fees below ).

Requesters have been classified into four categories :

•  A Personal Requester: - requests personal information about himself/herself .

•  A Representative Requester: - requests information on behalf of someone else .

•  A Third Party Requester: - requests personal information of another person .

•  A Public Body: - requests information in the public interest .

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6.1 Completion of Form C

Any request for information in terms of this Act must be contained in Form C. ( See Page 17 ). This formality is prescribed by the Act.

Form C must be completed in full and returned to Cellfind Client Services together with any other information that the mentioned companies require in order to consider and decide on the request. A request, which does not comply with the formalities, as prescribed by the Act will be forwarded back to the requester with advice on the necessary steps for compliance. This includes Forms that are not completed in full.

Cellfind Client Services will not consider a request unless it is contained in Form C. Cellfind Client Services will make copies of the mentioned form available on request.

6.2 Proof of Identity:

Proof of identity is required to authenticate the request and the requester. In view hereof, a requester will, in addition to Form C, be required to submit acceptable proof of identity such as a certified copy of their identity document or other legal forms of identity.

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Section 54 if the Act entitles a company to levy a charge or request fee to enable the company to recover the cost of processing a request and giving access to records in terms of the Act. The fees that may be charged have been published by the Minister of Justice and are set out on page 33.

Note that where a decision to grant a request has been taken, the record will not be disclosed until the necessary fees have been paid in full.

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All requests complying with the requirements set out above will be processed and considered expeditiously.

Please note that the Act stipulates the following grounds for refusing requests for information:

•  Mandatory protection of the privacy of a third party who is a natural person [ section 63 ]

•  Mandatory protection of commercial information of a third party [section 64]

•  Mandatory protection of certain confidential information of a third party [ section 65 ]

•  Mandatory protection of safety of individuals and protection of property [ section 66 ]

•  Mandatory protection of records privileged from production in legal proceedings [ section 67]

•  Commercial information of the private body [ section 68 ]

•  Mandatory protection of research information of third party and of the private body [ section 69 ].

Whatever decision is taken, the requester will be given notice of the decision in writing. The Act requires that such notification be given within 30 days of the decision being made. In case of a request being refused, the notification will include the reasons for the refusal.

Please note that Cellfind Client Services may extend the thirty-day notice period if it is necessary due to the nature of the request and the amount of time required to gather the requested information. The requester will however be given notice of the extension prior to the 30 day period's expiry.

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The Act does not require a company to establish an internal appeal structure for the purpose of allowing a requester who is aggrieved by a decision of the company to appeal such a decision. This requirement only applies to a public body.

A requester aggrieved by Cellfind's decision must therefore approach a court of law.

The Human Rights Commission's Guide might contain information on appeal procedures.

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Section 10 of the Act imposes a duty on the Human Rights Commission to "compile in each official language a guide containing such information, in an easily comprehensible form and manner, as may reasonably required by a person who wishes to exercise any right contemplated in the Act

Details on how to obtain access to the mentioned guide were at the time of publication of this Manual not available. The Human Rights Commission may be contacted in this regard on the Human Rights Advice Line at 0860 120 120, during office hours between Monday and Friday.

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Information is furnished in terms of legislation other than the Promotion of Access to Information Act, as and when requested in terms of the relevant legislation below :

•  Criminal Procedure Act, 1977, Act 51 of 1977;

•  Drugs and Drug-trafficking Act, Act 140 of 1992;

•  Interception and Monitoring Prohibition Act, Act 127 of 1992;

•  Prevention of Organised Crime Act, Act 121 of 1998;

•  Public Prosecution Authority Act, Act 32 of 1998;

•  Income Tax Act, Act 58 of 1962

•  Inside Trading Act, Act 135 of 1998

•  Intelligence Services Act No 38 of 1994

•  General Laws 6 Amendment Act, 204 of 1993

•  Environmental Conservation Act, 1989

•  Aviation Act, Act 74 of 1962.

•  Telecommunications Act, Act 103 of 1996

•  Value Added Tax Act, Act 89 of 1991

•  Pension Funds Act, Act 24 of 1956

•  Basic Conditions Of Employment Act, Act 75 of 1997

•  Unemployment Insurance Act, Act 30 of 1966

•  Skills Development Act, Act 97of 1998

•  Skill Development Levies Act, Act 9 of 1999

•  Employment Equity Act, Act 55 of 1998

•  Companies Act, Act 61 of 1973 (as amended)

•  Competition Act, Act 89 of 1998

•  Consumer Affairs Act, Act 23 of 1999

•  Occupational Health and Safety Act, Act 85 of 1993

•  Labour Relations Act, Act 127 of 1998

•  Electronic Communications and Transactions Act, Act 25 of 2002

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Business partners

Information Category

Information Category Description

Commercial agreement with business partners

This is the document, which records the agreement with the business partner, and is the output of contractual negotiations undertaken previously. It is co-owned by the business unit(s) involved and Legal.

Contractual issues with Business Partners

All information related to reaching an agreement with a business partner, for example correspondence and minutes of meetings prior to the actual agreement, including details related to the agreement itself.

Corporate Social Investment

Information Category

Information Category Description

Corporate Social Investment - Application for Funding

The details of all Corporate Social Investment applications received for funding by Cellfind.

Corporate Social Investment - Projects

Details of the projects that have been approved and are underway.

Corporate Social Investment - Cellfind response

The information relating to process of approval or rejection of the applications received for Corporate Social Investment.

External Communication

Information Category

Information Category Description

External Publication

All publications for external bodies, includes all press clippings

Press Release/Communiqué

Issuing of media statements, press releases, official speeches etc.

Web and Magazine Content

Content available on Cellfind internet sites (for e.g.

Government Protocol

Information Category

Information Category Description

South African Government structure

Details of the structure and holders of the South African government

South African Parliament structure

Details of the structure and holders of the South African parliament

Visiting Foreign Governments structure

Details of the positions held by foreign government visitors to South Africa


Information Category

Information Category Description

Finalised litigation

Litigation that has been concluded by court process or mutual consent


Information Category

Information Category Description

Board reports & meeting minutes

Reports prepared for the board meetings, and the subsequent minutes recording these meetings.

Project Activity and Schedule

Details of projects (tasks, resources, dependencies, durations, etc.)

Project Lifecycle and Macro Plan Information

This records the status and overarching objectives of the project. Project planning is undertaken according to the "Manage by Project" standard and all projects are registered in a project register.


Information Category

Information Category Description

Compliance certification

Compliance to international standards such as ISO9000 and COBIT

Compliance to license

The criteria related to the Mobile Telecommunications License conditions, as well as the performance against those conditions. Some metrics are number of subscribers, network rollout, performance and coverage, community, Client Services and emergency services, documented in the Cellular Operator's Report.

Policies and procedures

The documented policies and procedures of Cellfind's business processes and practices, for example relating to customer complaints.

Regulatory Submissions

Information Category

Information Category Description

Draft Legislations, Draft Regulations, Policy Directives

Information on draft legislation, regulations and policy directives

VIP events

Information Category

Information Category Description

VIP event management

Cellfind Events with business partners and other third parties and including staff functions of a high profile.


Customer Information

Information Category

Information Category Description

Customer Contract Details

Contract customer details received during application process (if applicable)

Customer Credit Checking

Criteria and results of the credit checking process for customers requiring a contract (if applicable)

Customer Detail

All other customer details recorded during customer creation process, which are not covered by information categories Customer Contract Details and Customer Credit Checking, and including customer preferences.

Customer passwords & identification

Passwords, for e.g., and identification required for release

Customer Profile

Information relating to the customer profile, for e.g. which services are activated

Customer Type

Information relating to the customer type, for e.g. reflects type of tariff plan.

Loyalty Award

Information relating to awards given to loyal customers.

Number and growth of subscribers

The count of active subscribers as measured at a certain period, and the growth this reflects.

Payment History

Information relating to payments made.

Subscriber demographics

The subset of customer information which describes the demographic information of that subscriber.

Customer Management

Information Category

Information Category Description


The number of subscribers disconnected from the network, expressed as a percentage of all subscribers users.

Customer Satisfaction Metrics

Research and measurement of customer satisfaction.

Customer Segments/Markets

The categories into which the market (potential customers) and active customers are divided.

Customer Sensitivity Analysis

The information measuring the customers' propensity to churn.

Customer Survey

The information relating to a customer survey (survey, respondents, feedback etc.)

Retail account

Information Category

Information Category Description

Account Holder

Information relating to the entity (individual or organisation) to whom the bill is addressed

Account Information

Information about the account (balance, status etc.)

Contract Customer Bill

The billing information prepared for post-paid customers

Contract Payment

Payment details (payment date, amount, method etc.)

Prepaid Customer Account Balance

Details of the prepaid customer's account balance

Customer Support

Call Centre Management

Information Category

Information Category Description

Call Center Performance

The performance of the call centre in answering and resolving customer enquiries

Call Centre Agent Schedule

The planned and actual schedule of call centre agents (includes bonus schedule).

Call Centre Benchmark Result

The results of special tests (benchmarks) when performance is monitored for specific reasons

Customer Interaction

Information Category

Information Category Description

Call Centre Call Data

The details of calls handled by the call centre (call centre agent, time, duration, query, etc.)

Customer Complaint

Details of specific customer complaints which are (or have been) communicated to ASA (Advertising Standards Authority)

Customer Frequently Asked Questions (FAQ) database

Information on the most frequently asked questions

Customer Inquiry

Details of general customer inquiries

Customer Service Request

A service request is the recording of an issue raised by a customer which requires attention.

Outbound Response

Information relating to responses communicated to customers

VIP customer complaints

The complaints of customers categorised as VIP customers

Distribution Channel

Distribution Channel Management

Information Category

Information Category Description

Dealer Competitive Information

Information relating to the market conditions and environment for dealers

Dealer Promotion

Information relating to dealer promotions (type of handset, price, conditions etc.)

Distribution Channel Structure

Information Category

Information Category Description


Dealer information


Information about the outlet (location, size, type, etc.)


Retailer information

Sales Cluster

The geographic area within South Africa in which a sale took place



Information Category

Information Category Description


Budget information (amount, code, responsibility)

Cash / Bank Transaction

Information generated by a financial transaction as a result of the flow of information to or from Cellfind


Creditor information (name, amount, status, etc.)


Debtor information (name, amount, status, etc.)

Financial transactions

Information generated by a financial transaction

General Ledger Account

General Ledger Account information (code, name, responsibility)

Payment terms

The details of payment terms with creditors and debtors

Cellfind Invoice

Invoices from Cellfind to debtors


Information Category

Information Category Description


All assets.

Financial Performance

Information Category

Information Category Description

Financial Management Statistics

The description, definition and measurement of financial metrics which measures the financial performance of the organisation and which are reported in the monthly management report

Financial Target

The planned goal of a financial metric (for example "Earnings before Income Tax, Depreciation and Amortisation")

Wholesale Bill

Information Category

Information Category Description

3rd Party Contract Wholesale Bill

Wholesale Billing information prepared related to contract customers' revenue, forwarded as invoices to Networks

Human Resources

Internal Communication

Information Category

Information Category Description

Internal Communiqué

The information contained within any internal communication, via email or physical (paper) distribution.

Policy and Procedure Tracking and Documentation

The dissemination and implementation of policy and procedure information

Reference Material

Reference material used in internal communications

Research Material

Research material used in internal communications

Organisation Structure and Position

Information Category

Information Category Description

Archive of Senior Management Photographs

Photographs of senior management

Job Profiling

The categorisation of responsibilities associated with an employment position

Organisational Structure

The structure of the organisation into business units, commonly depicted in an organogram. This usually includes the top "n" levels of an organisation, for example the executive directors, name of departments reporting into their business units and position.


The title and responsibilities of employment positions, including information related to the role and current incumbents. This includes information on contractors and other non-permanent staff members.

Performance and Remuneration

Information Category

Information Category Description

Employee Performance Record

The records relating to the employee performance, for example performance awards

Employee Timesheet Information

The records relating to the working hours' availability of an employee


All information related to payment of an employee, for example payment method, bank account details, payment amount, payment date


Information related to the "package" of an individual, for example gross salary, PAYE amount etc.

Personnel Detail

Information Category

Information Category Description

Curriculum Vitae (CV) and Application Detail

Details of applicants for employment, including CV details

Disciplinary Record

Records of disciplinaries, for example, person, reason, status

Employee Lifecycle Information

The information about an employee "life" at Cellfind, i.e. when joined, promoted, positions held etc.

Employee Personal Detail

Personal details kept on employees, for example, next of kin

Personnel Development

Information Category

Information Category Description

Employee Promotion criteria

The criteria for promotion

Skill Level

The skills required for positions

Training Event / Course

Details of training courses available and held



Information Category

Information Category Description

Bookings & appointments

Details of bookings for infrastructure elements, for example parking for visitors or video conference facilities

Facility/Security Access Record

Records of access to buildings by individuals

Loan Item

Items loaned to employees, for example training material

Office Layout and Maintenance

Details on office layout and maintenance performed, for example air-conditioning maintenance


Audit Information

Information Category

Information Category Description

Inspection/Audit Result

Results of inspections and audits

Risk and Control

Details of known risks and measures to control those risks

Contract / SLA Management

Information Category

Information Category Description

Service Level Agreement

The details of service levels agreed between two parties.

Service Level Rating

The measurement of a service level's performance.

Supplier and Partner Contract/Agreement

The contract between a supplier and/or a business partner.


Information Category

Information Category Description

Information Service Provider

The information about an information service provider.


Details related to a manufacturer who produces goods for Cellfind, for example Name, Address, Goods produced

Procurement decisions

Information related to procurement decisions

Request for Information (RFI)

Details contained within a request for information document, for example services and deliverables required

Statement of Work

The details related to a Statement of Work, including the deliverable specifications, due date, price, risks etc


Details relating to Supplier for example, registered name, banking details, status

Supplier demographics

Demographics of suppliers, with specific attention to the Historically Disadvantaged Individual (HDI) indicators

Supplier Invoice

Details related to an invoice received from suppliers

Cellfind Purchase Order

Details related to the purchase order process which controls the operational and capital expenditure of Cellfind

Sales and Marketing

Product / Service Management

Information Category

Information Category Description

Brand promotion

Information about promotions on Cellfind brands, including venue, date, format, leaflets, competition entry forms.

Brand tracking & research

Research and measurement of Cellfind's brands, done formally quarterly.

Price List (wholesale and retail)

Details of the available tariff plans, including prices, bundled minutes, services available etc

Product Launch

Information related to the launch of a new or revamped product

Product Life Cycle

The product life cycle is a sequence of stages (status) a product moves through from inception to decommissioning.

Product Performance Information

The metrics and performance of products

Product Specification

The specifications of a product


Information about the sponsorships Cellfind is involved with which leverage the brand. These include Sport, cultural, CSR and broadcast.

Value Added Service

The information about value added services, for example voicemail.

Sales Management

Information Category

Information Category Description

Advertisements and Promotions

Information related to advertising schedules, standards & content, as well as management of advertising agencies


Information on the commission a distribution channel receives for customer transactions, which may be a new subscription or usage.

Incentive and Target

Information on the incentives and targets a distribution channel receives for customer transactions, which may be a new subscription or usage.

Sales Figure and Target

Information on the actual sales as well as the target sales figures for the distribution channels



Information Category

Information Category Description

Diagnostic Support Information

The information generated by the diagnostic tests done on a faulty network element.

Trouble Ticket

Information on the faults logged (manually or automatically) for example date and time logged, element involved, type of problem. Also known as a service request.

Trouble Ticket Resolution

Information on the resolution of a trouble ticket, for example, time resolved.

Works Order

The information on planned engineering activity to network elements in order to install, maintain or upgrade it.

Service Event

Information Category

Information Category Description

Credit Card Recharge Transaction

The information generated during a credit card recharge transaction, for example date, amount.

Recharge Transaction

The information generated during a non-credit card recharge transaction, for example date, amount.

Service Event Information

The information related to events when services requested by a subscriber, for example, a request for the data service.

Service Profile

Information Category

Information Category Description

Service Profile

The information on which services a subscriber has currently access to.

Service Profile History

The history of events relating to service requests from subscribers


Legal & Criminal

Information Category

Information Category Description

Police Case

The information on police cases being investigated with the assistance of Cellfind.

Procedures & policies with regard to stolen phones

The information on the specific procedures and policies relating to the recording or handling of stolen phones.

Subpoena Request

The information on a subpoena request.

Suspected Fraud Alert

The information on alerts, which are triggered when fraud is suspected.

Usage Event

Information Category

Information Category Description

Short Message Service (SMS) Event Record

The information generated during an SMS event, for example, date and time, number SMS'ed etc.

Traffic info

The information generated by aggregated traffic

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