How to request a record from us.
The manual required by section 51 of the Promotion of Access to Information Act 2 of 2000, as amended by the Protection of Personal Information Act 4 of 2013. Version 4, 14 October 2026.
On this page
1. Purpose of this manual
Firearmdesk is a trading name of Attestra Tech (Pty) Ltd, a private company and a private body under the Promotion of Access to Information Act 2 of 2000 (PAIA) and a responsible party under the Protection of Personal Information Act 4 of 2013 (POPIA). This manual tells a person how to request access to a record we hold, what it costs and what remedies exist; which records are available without a request and which are kept under other legislation; the subjects on which we hold records and the categories held on each; and how we process personal information.
2. Contact details
- Head of the private body and Information Officer: Wayne de Jager, director.
- Street and postal address: 97 Davidson Road, George, Western Cape, 6529.
- Telephone: 081 770 2885. Email: support@firearmdesk.co.za, the address for every request under PAIA or POPIA; it reaches the Information Officer directly.
- No Deputy Information Officer has been designated. Requests, objections and complaints go to the Information Officer.
- The Information Regulator (South Africa): Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191; P.O. Box 31533, Braamfontein, 2017; telephone 010 023 5200 or 0800 017 160; enquiries@inforegulator.org.za; inforegulator.org.za.
3. The Guide on how to use PAIA
The Information Regulator has published, under section 10(1) of PAIA, the Guide on how to use the Promotion of Access to Information Act (Notice 1504 of 2021, Government Gazette 45492, 16 November 2021). It explains the objects of PAIA and POPIA, how to make a request, the help available from the Regulator and every remedy. It is available in all eleven official languages and in braille from inforegulator.org.za/paia, at the Regulator’s office, and from us on request. Copies in English and Afrikaans may be inspected at our address during business hours, by arrangement with the Information Officer.
4. Records available without a request
Published on this website and free to read or download: this manual; the privacy notice, the terms of service and the security and chain-of-custody page; the fee schedule; the legal basis and updates, with the judgment of the High Court in case 2025-104362 of 15 September 2026; the capability statement, the sample closure pack and the custody partner pack; the custody partner agreement, linked from the partner sign-up page; and the guides, questions and answers, about and contact pages.
5. Records held under other legislation
We keep the following records because legislation requires them. Access to them is given as that legislation and PAIA provide.
| Category of records | Legislation |
|---|---|
| Memorandum of incorporation, registers of directors and shareholders, resolutions, annual returns, accounting records and financial statements | Companies Act 71 of 2008 |
| Tax registrations, returns, assessments and supporting records; value-added tax records once registered | Income Tax Act 58 of 1962; Tax Administration Act 28 of 2011; Value-Added Tax Act 89 of 1991 |
| Records of each estate firearm, its custody, movement, valuation and lawful disposal, kept as the executor's agent; section 21 and Registrar correspondence and evidence of external steps | Firearms Control Act 60 of 2000 and its regulations |
| Letters of executorship, executors' instructions and mandates, settlement statements and closure packs | Administration of Estates Act 66 of 1965 |
| Supplier identity on the website and in documents; electronic records, signatures and signing logs | Electronic Communications and Transactions Act 25 of 2002 |
| This manual, the privacy notice, consents, records of processing, requests and objections | PAIA; POPIA |
| Employment and contractor records, payroll, tax and statutory registrations, where applicable | Basic Conditions of Employment Act 75 of 1997; Labour Relations Act 66 of 1995; Unemployment Insurance Act 63 of 2001; Compensation for Occupational Injuries and Diseases Act 130 of 1993 |
6. Subjects and categories of records
The records below are held in the secure portal and in the company’s files. Records of a matter are available to the referring firm and the executor through the portal without a request.
| Subject | Categories of records |
|---|---|
| Company and governance | Incorporation and CIPC documents, resolutions, decisions register, policies, insurance policies, agreements with service providers and advisers |
| Finance and tax | Bank statements and imports, invoices and credit notes, payments and allocations, charges and fee schedules, settlement accounts and statements, custody partner statements, invoices and payouts, storage statements, accounting records, tax returns |
| Referrals and matters | Referrals, matter records and status history, estate details, executor and beneficiary records, tasks, exceptions, notifications sent, consents, external steps with the South African Police Service, the Central Firearms Registry, the Registrar and the Master, with their evidence |
| Documents | Letters of executorship, identity evidence, firearm licences and competency certificates, valuation reports, signed instructions, document versions and malware-scan verdicts, generated closure packs, template versions |
| Firearms and custody | Firearm records and photographs, custody sites and their credentials, storage areas and positions, storage assignments and site allocations, custody events (receipt, movement, release), stocktakes and capacity records, delivery authorities and signatures, section 21 deposits and holders' requests, release authorisations, surrender hand-ins and police receipts, dispositions in place, heirs' keeping records and consent letters, refused-entry reports |
| Transport | Transport bookings and quotes, handoff records, transporter invoices and insurance details |
| Valuation and disposal | Valuation assignments and valuations, disposition instructions, sale transactions, heirs' approvals, executor mandates and their wording versions, custody mandate endings |
| Custody partners | Applications and sign-ups, agreements and acceptance records, onboarding and credential submissions, designated firearms officer agreements, staff training records, payout accounts, confirmations, indemnity claims and reserve confirmations |
| Users and security | User accounts, roles and memberships, sessions, passkeys and trusted devices, invitations, sign-in attempts, recovery codes (stored as hashes) |
| Legal rules and audit | Legal rules and their versions with sources and approvals, the append-only audit trail, integration and idempotency records |
| Staff and contractors | Contracts, identity, tax and payroll records, training and security briefings, access records |
| Correspondence and complaints | Email and letters, meeting notes, support requests, complaints, PAIA and POPIA requests and responses |
| Website and outreach | Public site content, aggregate page statistics, outreach records with firms and licensed dealers |
7. How to request a record
A person has a right of access to a record we hold if the record is required for the exercise or protection of a right, the request complies with PAIA and no ground for refusal applies (section 50(1)). Complete Form 2 (Request for access to record) of the PAIA Regulations, 2021, available from inforegulator.org.za/paia or from us, and send it to the Information Officer at support@firearmdesk.co.za or by post or hand to 97 Davidson Road, George, Western Cape, 6529. The form identifies the record and the requester (with proof of identity), the form of access wanted, a postal address or fax number in South Africa, how you wish to be told of the decision, and the right you seek to exercise or protect and why the record is required for it. A request made for another person attaches proof of the authority to act.
Fees (Annexure B, Part II, of the PAIA Regulations, 2021): a request fee of R140.00, payable before the request is processed; access fees of R2.00 per A4 page for a printed copy, R40.00 for a copy on a flash drive you supply, R40.00 on a compact disc you supply or R60.00 on one we supply, R24.00 per A4 page for a transcription of an audio record, and postage or electronic transfer at cost; search and preparation at R145.00 for each hour after the first, to a maximum of R435.00; and a deposit of one third of the access fee where search and preparation will exceed six hours.
Decision. We decide as soon as reasonably possible and within 30 days of receiving the request and the request fee, and tell you in writing (section 56). The period may be extended once by up to 30 days where section 57 allows, with written reasons. Where a record concerns a third party, we first notify that party and consider its representations (sections 71 to 74). A request not decided in time is taken to have been refused (section 58).
Grounds for refusal are those in Chapter 4 of Part 3 of PAIA, among them another person’s personal information (section 63), a third party’s commercial information (section 64), information held in confidence (section 65), records whose disclosure could endanger a person’s life or safety or the security of property (section 66), which covers records showing where firearms are held and the identity of a custody site, legally privileged records (section 67) and our own commercial information (section 68), unless the public interest override in section 70 applies. Where part of a record can be severed, the rest is given (section 59).
Your own personal information. Under section 23 of POPIA you may ask, free of charge, whether we hold personal information about you, for a description of it and for the identity of those who have had access to it. We charge no fees for giving you a copy of your own personal information. You may ask for its correction or deletion (section 24) and object to processing (section 11(3)). Some records must be kept notwithstanding, for example a signed instruction or a chain-of-custody receipt, and we will say so.
Remedies. There is no internal appeal against the decision of the head of a private body. Within 180 days you may complain to the Information Regulator on Form 5 at PAIAComplaints@inforegulator.org.za or through eservices.inforegulator.org.za (section 77A), or apply to a court (section 78). A complaint about personal information goes to POPIAComplaints@inforegulator.org.za.
8. Processing of personal information
Purposes. To open, administer and close each estate firearm matter a firm refers (verifying the executor’s authority, licensed custody, transport, valuation, the executor’s instruction, the lawful disposal and the closure pack) under the Administration of Estates Act 66 of 1965 and the Firearms Control Act 60 of 2000; to conclude and perform agreements with custody partners, transporters and valuers; to invoice, reconcile settlements and keep financial and tax records; to keep the chain-of-custody, audit and legal-rule records; to secure the platform; to send status notifications and secure links and contact firms about the service; to run the company; and to count visits to the public pages in aggregate and answer requests, objections and complaints.
| Data subjects | Personal information processed |
|---|---|
| Staff of referring firms: attorneys, fiduciary practitioners, trust company and bank staff | Name, role, firm, email address, mobile number, file reference, sign-in and activity records |
| Executors | Name, email address and telephone number, identity number and identity document, letters of executorship, signatures and signing records (time, IP address, browser), the estate account that receives sale proceeds |
| Heirs, legatees, surviving spouses and other beneficiaries | Name, identity number, contact details, firearm licence details, consents, approvals and keeping records |
| Buyers and transferees | Name, contact details, licence and competency details, evidence of payment |
| Persons holding or delivering firearms: section 21 holders, relatives, licensed heirs | Name, identity number, authorisation and licence details, the address where firearms are kept, identity confirmed at handoff |
| The deceased (estate information, not personal information in law, protected with the same care) | Name, date of death, Master's reference, licences, firearm details |
| Custody partners: owners, directors, signatories, designated firearms officers and named staff | Names, capacities, identity number of a sole proprietor, contact details, acceptance records, training records, bank account and tax details |
| Transporters: contact persons and named staff | Names, contact details, permit and identity details, insurance details, invoices |
| Valuers | Name, qualifications, contact details, bank details |
| Our employees and contractors | Identity, contact, tax, bank, contract, training and access records |
| Suppliers and professional advisers | Contact persons, contracts, invoices |
| Website visitors and partner applicants | Aggregate page statistics without the IP address; the details given on the partner sign-up page |
| Requesters and complainants | Name, contact details, proof of identity, correspondence |
Recipients. The referring firm, for its own matters, and the executor, for the matter they are invited to; the licensed custody partner allocated to the matter and the valuer briefed on the firearms, for their part only; a permitted transporter booked for the estate; buyers, heirs and their licensing steps, only where the executor’s signed instruction leads there; the South African Police Service, the Central Firearms Registry, the Registrar of Firearms, the Master of the High Court and the courts, where the law requires it or the executor’s instruction leads to an application; our hosting and email provider, and our bank, accountants, auditors, attorneys and insurers, for our own operations; and the South African Revenue Service, the Information Regulator and other authorities where the law requires. Personal information is never sold, and is not shared with marketers, data brokers or third-party analytics or advertising services.
Transborder flows. The platform, its database, document storage and email run on a server operated for us by Hetzner Online GmbH in Helsinki, Finland, with encrypted backup copies on separate Hetzner storage in Germany. Hetzner is subject to the General Data Protection Regulation and processes the information under a written data processing agreement with us (section 72(1)(a) of POPIA). No other transfer outside South Africa is planned.
Security measures. Encryption in transit; uploaded and generated documents encrypted at rest; identity numbers and sign-in secrets sealed in the database and passwords stored only as salted hashes; access scoped on the server to the firm, the matter and the role; two-factor verification for administrative, finance, compliance and custody-management roles, with a second person’s approval for sensitive actions; malware scanning before any upload can be opened; signed, short-lived document links; an append-only audit trail enforced in the database; nothing sensitive by email or SMS; custody partners’ premises addresses and storage positions shown only to those who need them; nightly encrypted backups to a separate location, with a restore tested on 2 October 2026; and a signed security briefing and least access for staff and contractors. Records are kept for at least five years after a matter closes (ten where it had exceptions, waivers or a legal hold); at the end of the period the personal details of living persons are removed under a two-person approval, while the records of the estate, the firearms, the custody chain, the finances and the audit trail are kept, and signed documents stay unaltered until ten years after the last custody event, or ten years after closure where no firearm entered custody, and are then destroyed. More on the security and chain of custody page and in the privacy notice.
9. Availability and updating
This manual is available on this page and as a PDF; at 97 Davidson Road, George, Western Cape, 6529, for inspection during business hours by arrangement with the Information Officer; to any person on request, at R2.00 per A4 page plus postage, or free by email; and to the Information Regulator on request. The Information Officer reviews it when our details, records or processing change, and at least once a year.