PAIA Manual
How to request access to records held by GTC Global SA (Pty) Ltd, which records are already available without a request, and the fees, timelines and remedies that apply under PAIA.
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About This Manual
This Manual is published by GTC Global SA (Pty) Ltd, trading as GTCFX, Registration No. 2020/810937/07, an authorised financial services provider (FSP No. 51545) regulated by the Financial Sector Conduct Authority under the FAIS Act. It is prepared in terms of section 51 of the Promotion of Access to Information Act, 2000 (as amended).
GTC Global SA renders intermediary services only in respect of derivative instruments under a Category I licence. It gives no advice, is not a market maker, product issuer or counterparty, and does not hold client money. The trading platform is provided, orders are executed and client money is held by GTC Global Trading LTD, the Broker, which is registered in Anjouan, Union of Comoros. Records relating to trading accounts may therefore be held by the Broker rather than by GTC Global SA.
This Manual tells you which records are available without a formal request, the subjects and categories of records held, how to make a request, what fees apply, when access may be refused, and what remedies are available. It was last updated on 10 October 2026 and is reviewed at least annually.
KEY POINTS
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Published by GTC Global SA (Pty) Ltd, Registration No. 2020/810937/07, FSP No. 51545, in terms of section 51 of PAIA.
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Our key disclosures, policies and this Manual are available on our website, with no PAIA request needed.
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Requests must be made on prescribed Form 2 and sent to compliance@gtcfx.com.
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A decision is made within 30 days of receipt, extendable once by up to a further 30 days with written reasons.
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A request fee of R140.00 applies, except where you ask only for a record containing your own personal information.
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If you are dissatisfied with a decision, you may complain to the Information Regulator within 180 days or apply to a court.
List of Acronyms and Abbreviations
The abbreviations set out below are used throughout this Manual and have the meanings given to them here.
Entities, Regulators and Office Holders
GTC Global SA: GTC Global SA (Pty) Ltd, Registration No. 2020/810937/07, authorised FSP No. 51545
Broker: GTC Global Trading LTD, the product supplier for which GTC Global SA renders intermediary services, registered in Anjouan, Union of Comoros, Company No. 16283, Licence No. L16283/GTC issued by the Anjouan Offshore Finance Authority
FSCA: Financial Sector Conduct Authority
Regulator: Information Regulator (South Africa)
Minister: Minister of Justice and Correctional Services
IO: Information Officer
DIO: Deputy Information Officer
Legislation
PAIA: Promotion of Access to Information Act, 2000 (as amended)
POPIA: Protection of Personal Information Act, 2013
FAIS Act: Financial Advisory and Intermediary Services Act, 2002
FICA: Financial Intelligence Centre Act, 2001
Purpose of This PAIA Manual
This PAIA Manual is published by GTC Global SA in terms of section 51 of PAIA. It is useful for members of the public for the purposes set out below.
To check the categories of records held by GTC Global SA which are available without a person having to submit a formal PAIA request.
To have a sufficient understanding of how to make a request for access to a record of GTC Global SA, through a description of the subjects on which GTC Global SA holds records and the categories of records held on each subject.
To know the description of the records of GTC Global SA which are available in accordance with any other legislation.
To access all the relevant contact details (compliance@gtcfx.com) for assistance with the records they intend to access.
To know the description of the Guide on how to use PAIA, as updated by the Regulator, and how to obtain access to it.
To know whether GTC Global SA processes personal information, the purpose of that processing, and the categories of data subjects and of the information or categories of information relating to them.
To know the recipients or categories of recipients to whom the personal information may be supplied.
To know whether GTC Global SA has planned to transfer or process personal information outside the Republic of South Africa, and the recipients or categories of recipients to whom the personal information may be supplied.
To know whether GTC Global SA has appropriate security measures to ensure the confidentiality, integrity and availability of the personal information which is to be processed.
Key Contact Details for Access to Information
Requests for access to records must be sent to compliance@gtcfx.com.
The particulars of the private body, and the contact for requests for access to records, are set out below.
Particulars of the Private Body
Name of private body: GTC Global SA (Pty) Ltd, trading as GTCFX
Registration number: 2020/810937/07
FSP number: 51545
Regulator: Financial Sector Conduct Authority (FSCA), South Africa
Physical and postal address: 18 Cavendish Road, Claremont, Cape Town, Western Cape, 7708
Website: https://www.gtcfx.com/en-za
Requests for Access to Records
Email: compliance@gtcfx.com
Guide on How to Use PAIA
The Regulator has, in terms of section 10(1) of PAIA, updated and made available the revised Guide on how to use PAIA, in an easily comprehensible form and manner, as may reasonably be required by a person who wishes to exercise any right contemplated in PAIA and POPIA.
The Guide is available in each of the official languages and in braille. It describes, among other things, the objects of PAIA and POPIA, the contact details of information officers, the manner and form of a request for access to a record of a public or private body, the assistance available from the Regulator, the remedies available including a complaint to the Regulator and an application to court, the requirement to compile a manual and how to obtain access to it, the voluntary disclosure of categories of records, the fees payable for access, and the regulations made under PAIA.
Members of the public can inspect or make copies of the Guide at the offices of the Regulator, or obtain it from the Regulator's website at https://inforegulator.org.za/. A copy of the Guide is available for inspection at the offices of GTC Global SA during normal business hours, and may be requested from compliance@gtcfx.com.
Records Available Without a Request
The categories of records set out below are available without a person having to request access in terms of PAIA, in the manner shown alongside each category.
Client Disclosures and Agreements
FAIS Disclosure (Upfront Disclosure): On request, free of charge
Customer Terms Agreement (Tri-Partite Client Agreement): On request, free of charge
Risk Disclosure Statement: On request, free of charge
Order Execution Policy of the Broker: Website
Policies, Licence and Marketing Material
Conflict of Interest Management Policy: Website
Data Protection and Privacy Policy: Website
Complaints Handling Policy: Website
This PAIA Manual: Website and offices of GTC Global SA
FSP licence certificate: On request, free of charge
Marketing and product information: Website
Records Available Under Other Legislation
A reference to legislation in this section does not mean that the records are available without a request in terms of PAIA. Access remains subject to PAIA and to the legislation concerned.
GTC Global SA keeps records in accordance with the legislation set out below, as applicable to its business.
Corporate and Financial Services Legislation
Companies Act, 71 of 2008: Memorandum of incorporation, registers of directors and securities, minutes and resolutions
Financial Advisory and Intermediary Services Act, 37 of 2002: FSP licence, disclosures, records of financial services, complaints and compliance reports
Financial Intelligence Centre Act, 38 of 2001: Customer due diligence and transaction records
Financial Sector Regulation Act, 9 of 2017: Regulatory correspondence and returns
Financial Markets Act, 19 of 2012: Records relating to derivative instruments, where applicable
Information and Electronic Records Legislation
Protection of Personal Information Act, 4 of 2013: Records of processing, consents and data subject requests
Promotion of Access to Information Act, 2 of 2000: PAIA requests and decisions
Electronic Communications and Transactions Act, 25 of 2002: Electronic agreements and records of acceptance
Cybercrimes Act, 19 of 2020: Records relating to reportable cyber incidents
Tax Legislation
Income Tax Act, 58 of 1962: Tax returns, assessments and supporting records
Value-Added Tax Act, 89 of 1991: Tax returns, assessments and supporting records
Tax Administration Act, 28 of 2011: Tax returns, assessments and supporting records
Employment and Workplace Legislation
Basic Conditions of Employment Act, 75 of 1997: Employment contracts, personnel and payroll records
Labour Relations Act, 66 of 1995: Employment contracts, personnel and payroll records
Employment Equity Act, 55 of 1998: Employment contracts, personnel and payroll records
Skills Development Act, 97 of 1998, and Skills Development Levies Act, 9 of 1999: Training and levy records
Unemployment Insurance Act, 63 of 2001, and Unemployment Insurance Contributions Act, 4 of 2002: UIF contribution records
Compensation for Occupational Injuries and Diseases Act, 130 of 1993, and Occupational Health and Safety Act, 85 of 1993: Workplace safety and injury records
Financial Crime and Exchange Control Legislation
Prevention of Organised Crime Act, 121 of 1998: Records relating to reporting obligations
Protection of Constitutional Democracy against Terrorist and Related Activities Act, 33 of 2004: Records relating to reporting obligations
Prevention and Combating of Corrupt Activities Act, 12 of 2004: Records relating to reporting obligations
Currency and Exchanges Act, 9 of 1933, and the Exchange Control Regulations, 1961: Records relating to cross-border transactions, where applicable
Subjects and Categories of Records Held
GTC Global SA holds records on the subjects set out below. The categories of records held on each subject are listed alongside that subject.
Corporate, Financial and Compliance Records
Corporate and statutory: Memorandum of incorporation, incorporation documents, share register, register of directors, minutes and resolutions, annual returns
Financial: Annual financial statements, accounting records, bank statements, invoices, asset register, tax returns and tax records
Regulatory and compliance: FSP licence and conditions, FSCA correspondence, compliance reports, fit and proper records of the Key Individual and representatives, conflicts of interest and gifts registers, complaints register, professional indemnity and fidelity insurance
Policies and procedures: Internal policies, procedures and manuals
Client, Counterparty and Operational Records
Clients: Applications and onboarding records, FICA customer due diligence records, disclosures and acknowledgements, records of acceptance of the Customer Terms Agreement, communications, complaints, and records received from the Broker
Product supplier and third parties: Agreement with the Broker, due diligence on the Broker, service provider and operator agreements
Personnel: Employment contracts, conditions of employment, payroll, leave, disciplinary and training records, tax and UIF records
Information technology and security: Information security policies, access logs, incident registers, business continuity records
Marketing: Marketing material, website content, direct marketing consent and opt-out records
Processing of Personal Information
Personal information of clients is transferred to the Broker in the Autonomous Island of Anjouan, Union of Comoros, so that client trading accounts can be opened and operated, and may be processed by service providers in other countries. Such transfers are made only as permitted by section 72 of POPIA, as described in the Data Protection and Privacy Policy.
Purpose of processing. GTC Global SA processes personal information to render intermediary services and introduce clients to the Broker, to identify and verify clients and comply with FICA, to make disclosures and keep records as required by the FAIS Act, to handle complaints and queries, to manage its employees, service providers and business, to secure its systems and prevent fraud, to comply with other legal obligations, and, with consent where required, for direct marketing.
Recipients of personal information. Personal information may be supplied to the Broker, related companies that provide support services, operators such as identity verification, screening, IT, hosting and administrative service providers, auditors, legal and other professional advisers, insurers, and the FSCA, the Financial Intelligence Centre, the South African Revenue Service, the Regulator and other public bodies where required by law.
Security measures. GTC Global SA protects personal information through measures that include role-based access control and least privilege, multi-factor authentication for privileged access, encryption in transit and at rest, logging and monitoring, secure backups, written agreements with operators, confidentiality undertakings and training for staff, and an incident response procedure that includes notification of security compromises under section 22 of POPIA.
Categories of data subjects and personal information. The categories of data subjects, and the personal information processed in respect of each category, are set out below.
Clients and Prospective Clients
Clients (natural persons): Identity and contact details, identity documents, biometric verification results, financial information, source of funds and wealth, tax information, employment information, trading knowledge and experience, account and trading information, communications, screening results
Clients (legal entities) and their representatives: Entity name, registration details, address, ownership and control structure, financial statements, and the identity and contact details of directors, beneficial owners and authorised persons
Prospective clients and website visitors: Contact details, application data, technical data such as IP address and device information, cookie data
Personnel and Third Parties
Employees and job applicants: Identity and contact details, qualifications, employment history, remuneration, banking and tax details, performance and disciplinary records
Product supplier, service providers and other third parties: Names, contact details and business details of contact persons, contractual and financial information
Procedure for Requesting Access
A request for access to a record must be made on Form 2 (Request for Access to Record) prescribed under the Regulations relating to PAIA, which is available on the Regulator's website, and submitted to compliance@gtcfx.com.
The requester must provide sufficient particulars to enable the Information Officer to identify the record and the requester, indicate the form of access required and the postal address or email address for the response, and identify the right the requester seeks to exercise or protect and explain why the record is required for the exercise or protection of that right.
A person making a request on behalf of another person must submit proof of the capacity in which the request is made. A requester who is unable to read or write, or who has a disability, may make the request orally, and the Information Officer will reduce it to writing.
The Information Officer will decide on the request within 30 days of receiving it, and may extend that period once by up to a further 30 days in the circumstances permitted by section 57 of PAIA, by written notice giving reasons. If the Information Officer does not respond within the applicable period, the request is regarded as refused.
Where the request concerns a record containing information about a third party, the Information Officer will take reasonable steps to inform the third party within 21 days and give the third party an opportunity to make representations before deciding on the request.
If access is granted, the requester will be notified of the access fee payable and the form of access. If access is refused, the requester will be given adequate reasons and informed of the available remedies.
PAIA does not apply to a record requested for the purpose of criminal or civil proceedings after the commencement of those proceedings, where the production of or access to that record is provided for in any other law.
Fees
The request fee is not payable by a personal requester, being a requester who seeks access to a record containing only the requester's own personal information.
The fees set out below are prescribed for requests to private bodies.
Where the search for and preparation of a record is expected to take more than six hours, the requester may be required to pay a deposit of one third of the access fee before the search begins. The deposit will be refunded if access is refused.
Request and Copying Fees
Request fee, payable by every requester other than a personal requester: R140.00
Photocopy or printed black and white copy of an A4-size page, per page or part of a page: R2.00
Copy in computer-readable form on a flash drive provided by the requester: R40.00
Copy on a compact disc provided by the requester, or provided by GTC Global SA: R40.00 or R60.00
Postage, email or other electronic transfer: Actual expense
Transcription, Search and Preparation Fees
Transcription of visual images, or copy of visual images: Outsourced, per quotation
Transcription of an audio record, per A4-size page: R24.00
Copy of an audio record on a flash drive or compact disc provided by the requester, or on a compact disc provided by GTC Global SA: R40.00 or R60.00
Search for and preparation of the record, for each hour or part of an hour after the first hour: R145.00
Maximum search and preparation fee: R435.00
Grounds for Refusal of Access
Despite these grounds, access must be granted where section 70 of PAIA requires disclosure in the public interest.
The Information Officer may refuse access to a record, or must refuse access where PAIA requires it, on the grounds set out in Chapter 4 of Part 3 of PAIA. Those grounds include the following.
The mandatory protection of the privacy of a third party who is a natural person (section 63).
The mandatory protection of the commercial information of a third party (section 64).
The mandatory protection of confidential information of a third party (section 65).
The mandatory protection of the safety of individuals and the protection of property (section 66).
The mandatory protection of records privileged from production in legal proceedings (section 67).
The protection of the commercial information of GTC Global SA (section 68).
The protection of research information of a third party and of GTC Global SA (section 69).
Remedies
GTC Global SA does not have an internal appeal procedure.
A requester or third party who is dissatisfied with a decision of the Information Officer may, within 180 days of the decision, lodge a complaint with the Regulator using the prescribed form, or apply to a court for appropriate relief in terms of PAIA.
Information Regulator (South Africa)
Physical address: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191
Telephone: 010 023 5200 / 0800 017 160 (toll free)
General enquiries: enquiries@inforegulator.org.za
POPIA complaints: POPIAComplaints@inforegulator.org.za
PAIA complaints: PAIAComplaints@inforegulator.org.za
Website: inforegulator.org.za
How to Take a Decision Further
Internal appeal: Not available, as GTC Global SA has no internal appeal procedure
Time limit: Within 180 days of the decision of the Information Officer
Complaint to the Regulator: On the form prescribed under PAIA, available from the Regulator
Court application: An application to a court for appropriate relief in terms of PAIA
Availability and Updating of This Manual
This Manual is available on our website at https://www.gtcfx.com/en-za, for inspection free of charge at the offices of GTC Global SA during normal business hours, and to the Regulator on request. A copy may be obtained on payment of the prescribed fee for copies.
GTC Global SA will review and, where necessary, update this Manual at least annually.
This Manual was last updated on 10 October 2026 and is issued by the Information Officer of GTC Global SA (Pty) Ltd.
Other policies
Every policy that applies to your use of GTCFX websites and services, in one place.
Request access to a record held by GTC Global SA
Requests for access to records, and questions about this Manual, should be sent to compliance@gtcfx.com. A copy of this Manual is also available for inspection at our offices during normal business hours.