BrainTrust Business Training (Pty) Ltd
Registration Number 2015/421532/07
Last updated: 21 September 2026
1. Purpose
The Promotion of Access to Information Act, No 2 of 2000 (“PAIA”) gives effect to the constitutional right of access to information. Section 51 of PAIA requires every private body to compile a manual describing the records it holds and how a person may request access to them. This manual sets out how BrainTrust Business Training (Pty) Ltd (“BrainTrust”, “we”, “us” or “our”) holds records, how a request for access may be made, and the particulars in terms of Section 51 of PAIA read with Section 17 of the Protection of Information Act, No 4 of 2013 (“POPIA”).
This manual is not a privacy policy. Our privacy policy, which explains how personal information is collected and used, is published separately at www.btbt.co.za/privacy-policy.
2. Particulars of the Private Body
Registered name: BrainTrust Business Training (Pty) Ltd
Registration number: 2015/421532/07
Physical address: 123 Thomson Street, Colbyn, Pretoria, 0083
Nature of Business: Accredited education and training provider in the South African real estate sector
Telephone: 011 202 5323/010 203 9011
Email: info@btbt.co.za
Website: www.btbt.co.za
3. Information Officer
In terms of Section 1 of PAIA, and Section 56 of POPIA, the head of a private body is the Information Officer. BrainTrust has designated the following person to exercise the powers and perform the duties of the Information Officer:
Information Officer: Keren Gilchrist
Email: info@btbt.co.za
Telephone: 011 202 5323
Physical address: 123 Thomson Street, Colbyn, Pretoria, 0083
4. The Guide in Terms of Section 10 of PAIA
The Information Regulator has compiled a guide, in terms of Section 10 of PAIA, containing information reasonably required by a person who wishes to exercise any right contemplated in PAIA or POPIA. The guide is available in each of the official languages. The guide may be obtained from the Information Regulator:
PO Box 31533, Braamfontein, Johannesburg, 2017
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
Website: www.inforegulator.org.za
Email (PAIA): PAIAComplaints@inforegulator.org.za
Email (General): Inforeg@inforegulator.org.za
5. Records Available Without a Request
The following categories of records are available without a formal request under PAIA, and may be accessed on BrainTrust’s website or obtained on request from the Information Officer:
Course, qualification and CPD module information, including outlines, outcomes and pricing
Accreditation status and accreditation numbers
The BrainTrust privacy policy
This PAIA manual
General marketing and company profile material
Terms and conditions of enrolment, and the refund policy
A learner or Property Practitioner may obtain their own training and assessment records, and their own CPD completion records, directly from BrainTrust on request, without following the PAIA procedure in Section 8 below.
6. Records Held by BrainTrust
BrainTrust’s Own Business Records
These are records about the company itself. They contain no personal information about learners or Property Practioners:
Company & Statutory: Memorandum of Incorporation; CIPC registration documents and filings; share register; director records; board and management resolutions; B-BBEE certificates or affidavits.
Financial: Annual financial statements; accounting records; tax records and SARS correspondence; VAT records; invoices, receipts and statements; banking records; payroll records; asset register.
Accreditation & Quality Assurance: QCTO and Services SETA accreditation records and correspondence; PPRA correspondence; quality management system documents and policies; learning material and version registers; moderation reports; internal audit records; programme review reports.
Commercial: Client agency contracts and service agreements; quotations and proposals; supplier contracts; insurance policies.
Information Technology: Learning platform configuration and administration records; system access logs; backup records; software licenses and service agreements.
Legal: Contracts and agreements; legal correspondence and opinions; litigation records, if any.
Records Containing Personal Information:
These are records about identifiable people. Access to them is restricted, and a request by anyone other than the person concerned will ordinarily be refused under Section 63 of PAIA.
Learners (Qualifications): Enrolment and registration records; identity and contact information; portfolios of evidence; assessment and moderation records; results; certificates; learner support and correspondence records; attendance registers.
Employees: Employment contracts; personnel files; qualifications and identity documents; payroll, leave and benefit records; employment equity and skills development records.
Facilitators & Contractors: Facilitator and assessor agreements; curricula vitae; certified qualifications; assessor and moderator registrations; confidentiality undertakings; invoices and payment records.
Client Agency Representatives: Name, contact details and role; correspondence.
Marketing Contacts: Mailing list and marketing consents; campaign records.
7. Records Held in Terms of Other Legislation
BrainTrust holds records in terms of, among others, the following legislation. This is not an exhaustive list and does not imply that all records are available for inspection.
Companies Act, 71 of 2008: Statutory company records
Income Tax Act, 58 of 1962: Tax and payroll records
Basic Conditions of Employment Act, 75 of 1997: Employment records
Labour Relations Act, 66 of 1995: Employment relations records
Employment Equity Act, 55 of 1998: Employment equity records, where applicable
Skills Development Act, 97 of 1998: Learner, learnership and skills development records
Skills Development Levies Act, 9 of 1999: Levy records
Occupational Health and Safety Act, 85 of 1992: Health and safety records
Protection of Personal Information Act, 4 of 2013: Records of processing and related documentation
National Qualifications Framework Act, 67 of 2008: Qualification and assessment records
8. How to Request Access to a Record
Making a Request
The requester must complete the prescribed request form and submit it to the Information Officer at the address in Section 3. The prescribed form for a request to a private body is Form C of the PAIA Regulations, available from the Information Regulator’s website.
The request must provide sufficient particulars to enable the information officer to identify the record and the requester, and must state the form of access required and the postal address, email address or fax number of the requester.
The requester must state the right that they are seeking to exercise or protect, and explain why the record requested is required to exercise or protect that right.
Where a request is made on behalf of another person, proof of the capacity in which the requester is making the request must be submitted.
Where a requester is unable to make a written request because of illiteracy or disability, the request may be made orally and the Information Officer will reduce it to writing and provide a copy to the requester.
Fees
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 is required to pay the prescribed request fee before the request is processed.
Where access is granted, an access fee is payable for the reproduction, search and preparation of the record, calculated in accordance with the PAIA Regulations. The Information Officer will notify the requester of the access fee payable and may require a deposit where the search and preparation is likely to exceed the prescribed period.
Current request and access fees are those prescribed in the PAIA Regulations, which are available from the Information Regulator. Fees are amended from time to time.
Decision
The Information Officer will decide the request and notify the requester of the decision within 30 days of receiving it. That period may be extended by a further 30 days where the request is for a large number of records, or where a search through a large number of records is required, and the requester will be notified of any extension and the reasons for it.
If the request is granted, the notice will state the access fee payable, the form in which access will be given and that the requester may lodge a complaint or application regarding the fee or the form of access. If the request is refused, the notice will state adequate reasons for the refusal, the provisions of PAIA relied on, and that the requester may lodge a complaint with the Information Regulator or an application with a court.
9. Grounds For Refusal
Access to a record may or must be refused on the grounds set out in Chapter 4 of Part 3 of PAIA, including where the record contains:
The personal information of a third party, the disclosure of which would be unreasonable (section 63)
Commercial information of a third party, including trade secrets, financial, commercial, scientific or technical information the disclosure of which is likely to cause harm (section 64)
Information supplied in confidence by a third party, where disclosure would breach a duty of confidence (section 65)
Information that could reasonably be expected to endanger the life or physical safety of an individual (section 66)
Information whose disclosure would prejudice the protection of property (section 67)
Commercial information of BrainTrust itself, including trade secrets and information whose disclosure would put BrainTrust at a disadvantage in contractual or other negotiations or prejudice it in commercial competition (section 68)
Information protected by legal professional privilege (section 67), or research information of BrainTrust or a third party (section 69)
A request may also be refused where it is manifestly frivolous or vexatious, or where the work involved in processing it would substantially and unreasonably divert BrainTrust’s resources.
Access must nevertheless be granted where the disclosure of the record would reveal evidence of 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 contemplated (section 70).
10. Remedies Available to a Requester
There is no internal appeal against a decision of the Information Officer of a private body.
A requester who is dissatisfied with a decision may lodge a complaint with the Information Regulator in terms of section 77A of PAIA, or apply to a court for appropriate relief in terms of section 78.
11. Particulars in Terms of POPIA
Purpose of Processing
BrainTrust processes personal information for the following purposes: enrolment, delivery, assessment and certification of training and CPD; statutory reporting to education authorities and regulators; learner support; contract management and invoicing; employment and contractor administration; marketing of its services, subject to consent where required; and compliance with its legal obligations.
Categories of Data Subjects & Personal Information
Learner & Property Practitioners: Name, identity number, contact details FFC reference number, employer or agency, qualification and assessment records, CPD enrolment and completion records, payment records.
Employees: Name, identity number, contact details, banking details, qualifications, employment and payroll records.
Facilitators, assessors and contractors: Name, identity number, contact details, qualification and registrations, banking details, agreements.
Client Agency Representatives: Name, contact details, correspondence.
Website and Platform Users: Name, contact details, account credentials, usage and progression data.
Suppliers: Contact and banking details.
Recipients of Personal Information
BrainTrust may share personal information with:
Education and regulatory authorities, including the Quality Council for Trades and Occupations, the Services Sector Education and Training Authority, the South African Qualifications Authority and the Property Practitioners Regulatory Authority, where required for registration, certification or statutory reporting
Facilitators, assessors and moderators engaged to deliver or quality assure training
Employers, agencies or funders who sponsor a learner, limited to what is required to report on that learner
Service providers who process information on behalf of BrainTrust under written agreement, including the learning platform provider, payment processors, and cloud hosting, e-mail and customer relationship management providers
Professional advisers, including auditors, attorneys and accountants
Law enforcement or regulatory authorities where required by law
BrainTrust does not sell personal information.
Security Safeguards
BrainTrust secures the integrity and confidentiality of personal information in its possession by taking appropriate, reasonable technical and organisational measures, including role-based access control limited to personnel whose function requires access; encryption of information in transit and at rest; multi-factor authentication on administrative accounts; regular backups to a separate location; secure disposal of records at the end of the retention period; confidentiality undertakings in employment and facilitator contracts; and periodic review of access logs.
BrainTrust maintains a documented procedure for responding to a compromise of personal information, providing for notification to the Information Regulator and to affected data subjects as required by section 22 of POPIA.
Retention
Personal information is retained only for as long as is required for the purpose for which it was collected, to meet education and assessment record requirements, or to comply with legal, contractual, tax or regulatory obligations. CPD assessment and completion records are retained for five years.
Data Subject Rights
A data subject may request confirmation of whether BrainTrust holds personal information about them, request access to that information, request correction or deletion of information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or unlawfully obtained, and object to processing on reasonable grounds. Requests should be directed to the Information Officer using the prescribed forms under the POPIA Regulations.
12. Manual Availability
This manual is available:
On the BrainTrust website at www.btbt.co.za
For inspection at the BrainTrust head office during normal business hours, free of charge
From the Information Officer on request
To the Information Regulator, on request or as submitted
This manual is available in English.
13. Changes to this policy
We may reviw this manuel when our practices, services or legal obligations change. The current version will be published on this website.