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PAIA Manual

Promotion of Access to Information Act 2 of 2000  ·  Section 51 Manual  ·  Approved  · 

Contents

  1. Introduction
  2. Contact details of the Information Officer
  3. Guide on how to use PAIA
  4. Records held by the company
  5. Records available under other legislation
  6. How to request access to records
  7. Fees
  8. Grounds for refusal
  9. Availability of this manual

Part A — Introduction

The Promotion of Access to Information Act 2 of 2000 ("PAIA") gives effect to the constitutional right of access to information held by both public and private bodies. This manual has been compiled by ("the Company") in accordance with section 51 of PAIA.

The Company is a private body as defined in PAIA. Its principal business activity is providing a free WhatsApp-based CV-building service to job seekers in South Africa.

Part B — Contact details of the Information Officer

The following person has been designated as Information Officer and is responsible for facilitating requests for access to records:

Information Officer
Name:
Title:
Email:
Phone:

Company

Registration no.:
Physical address:


Postal address:


Email:
Website:

Part C — Guide on how to use PAIA

The South African Human Rights Commission (SAHRC) has compiled a guide on how to use PAIA. This guide is available from the SAHRC:

  • Website: www.sahrc.org.za
  • Telephone: 011 877 3600
  • Email: paia@sahrc.org.za

The Information Regulator also maintains guidance on POPIA and PAIA compliance:

  • Website: www.inforegulator.org.za
  • Email: inforeg@justice.gov.za

Part D — Records held by the company

The Company holds the following categories of records. Not all records are automatically accessible — a formal PAIA request may be required for some categories.

D.1 Records relating to data subjects (CV users)

Category Description Retention
Session records Name, phone number, email (if provided), location, session state, consent timestamps years from last interaction
CV content Education history, employment history, skills, languages, profile statement, availability years from last interaction
Generated CVs PDF CV files stored in secure cloud storage years from last interaction
Sensitive attributes Race, gender, right-to-work status (if voluntarily provided) Deleted with session record
Feedback records Voluntary feedback messages submitted by users years

D.2 Records relating to website visitors

Category Description Retention
Contact form submissions Name, email address, subject, message body years

D.3 Corporate and administrative records

Category Description
Company records Memorandum and Articles of Association, company registration documents, director records
Financial records Management accounts, tax records, invoices
Contracts Service agreements with operators and third-party providers
Employment records Staff and contractor agreements, payroll records (if applicable)
Compliance records POPIA processing records, PAIA requests log, consent records

Part E — Records available under other legislation

The Company is subject to the following legislation relevant to its records:

  • Companies Act 71 of 2008
  • Income Tax Act 58 of 1962
  • Value-Added Tax Act 89 of 1991
  • Labour Relations Act 66 of 1995 (if employees are engaged)
  • Basic Conditions of Employment Act 75 of 1997 (if employees are engaged)
  • Protection of Personal Information Act 4 of 2013
  • Promotion of Access to Information Act 2 of 2000
  • Electronic Communications and Transactions Act 25 of 2002
  • Consumer Protection Act 68 of 2008

Part F — How to request access to records

F.1 Who may request

Any person (a requester) may submit a request for access to records held by the Company. A person requesting access to their own personal information (a personal requester) has enhanced rights under both PAIA and POPIA.

F.2 How to submit a request

Requests must be submitted using the prescribed Form C (available from the South African Human Rights Commission at www.sahrc.org.za), or by written letter/email containing at minimum:

  1. Your full name and contact details
  2. A description of the records you are requesting
  3. The form in which you require access (inspection, copy, etc.)
  4. If requesting access to another person's information, the reason for the request and your right or legitimate interest

Submit your request to the Information Officer at the contact details in Part B.

F.3 Response time

The Company will respond to a request within 30 days of receiving it, as required by PAIA section 56. This period may be extended by a further 30 days in exceptional circumstances, in which case the requester will be notified.

F.4 Personal requesters

If you are requesting access to your own personal information, you may also exercise your data subject rights directly and without a formal PAIA request by:

  • Sending RESTART on WhatsApp to delete your data immediately
  • Contacting the Information Officer by email to request a copy or correction

Part G — Fees

G.1 Request fee

A request fee of R50.00 is payable before the Company searches for the records requested, except where:

  • The requester is seeking access to their own personal information (personal requesters are exempt from the request fee)
  • The requester is indigent (proof of social grant or similar required)

G.2 Access fee

If the request is granted, access fees (for reproduction of records) are charged in accordance with the Regulations to PAIA. Current prescribed fees include:

ItemFee
Photocopy (per A4 page)R1.10
Electronic copy (per megabyte)R0.75
Postal or courier deliveryActual cost

Fees are prescribed by the Minister of Justice and may be updated by regulation. Personal requesters are exempt from access fees for their own personal information.

G.3 Deposit

If the estimated access fee exceeds R600.00, a deposit of one third of that fee is payable before processing begins.

Part H — Grounds for refusal

The Company may refuse a request for access to records on the grounds set out in PAIA sections 62–69, including but not limited to:

  • The records contain personal information about a third party who has not consented to disclosure
  • Disclosure would constitute a breach of confidentiality owed to a third party
  • The records contain commercially sensitive information whose disclosure would cause harm to the Company's competitive position
  • Disclosure would be in contempt of court or breach a legal privilege
  • The request is clearly frivolous, vexatious, or would substantially and unreasonably divert resources
  • The records concern research that has not yet been published or publicly announced

Where a request is refused, the Company will provide written reasons, notify the requester of their right to internal appeal (section 74), and of the right to apply to court (section 78) if the internal appeal is unsuccessful.

Part I — Availability of this manual

This manual is available:

  • On our website at
  • In printed form from the Information Officer upon request (no fee for a single copy)
  • At the registered office of the Company (see Part B)

A copy of this manual has been submitted to the South African Human Rights Commission as required by section 51(3) of PAIA.

This manual was approved by on and supersedes any previously published version.


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