Access to information manual

1. About this manual

The Promotion of Access to Information Act 2 of 2000 (PAIA) gives everyone the right to request records held by a private body where the record is required to exercise or protect a right. This manual explains which records Pattern Interrupt Consulting (Pty) Ltd holds and how to request them, as section 51 of PAIA requires.

2. Contact details

3. The Regulator's guide

The Information Regulator has published a guide on how to use PAIA and POPIA, as section 10 of PAIA requires. It is available in the official languages on the Regulator's website and from its offices:

4. Records available without a request

We have not published a notice under section 52(2) of PAIA. The information on this website, including our privacy notice and this manual, is freely available without a formal request.

5. Records kept under other laws

We keep records as required by laws that apply to us, including, where applicable:

• Companies Act 71 of 2008
• Income Tax Act 58 of 1962
• Tax Administration Act 28 of 2011
• Value-Added Tax Act 89 of 1991
• Electronic Communications and Transactions Act 25 of 2002
• Protection of Personal Information Act 4 of 2013
• Promotion of Access to Information Act 2 of 2000

Some records under these laws, such as documents filed with the Companies and Intellectual Property Commission, are also available from the relevant authority.

6. Categories of records

Listing a category does not mean a requester will receive access to it. Each request is assessed against the grounds for refusal in section 9.

7. How to request a record

• Complete the prescribed form for a request to a private body (Form 2 in the PAIA Regulations, 2021), available on the Information Regulator's website.
• Email it to rene@piconsulting.tech or deliver it to the address in section 2.
• Give enough detail to identify the record and yourself, state the form of access you want, and explain which right you want to exercise or protect and why the record is needed for that.
• If you request on behalf of someone else, include proof of your authority.

We will decide on your request within 30 days and tell you the outcome in writing (s 56). We may extend this once by up to 30 days in the circumstances section 57 allows, and will tell you if we do.

8. Fees

Fees are set by the PAIA Regulations, 2021. A request fee of R140 is payable by requesters, except where you request your own personal information. If access is granted, access fees cover reproduction, search and preparation, for example R2 per printed A4 page. Where the search and preparation is expected to take more than six hours, we may ask for a deposit of up to one third of the access fee. We will tell you in writing what fees apply before any work is done.

9. Grounds for refusal

We may or must refuse access on the grounds in Chapter 4 of Part 3 of PAIA, including to protect:

• the privacy of a third party (s 63);
• a third party's commercial information (s 64);
• confidential information of a third party (s 65);
• the safety of individuals and property (s 66);
• records privileged from production in legal proceedings (s 67);
• our own commercial information (s 68);
• research information (s 69).

Records about a client's business may fall under one or more of these grounds, such as sections 64, 65 or 67, depending on the facts. A record is not exempt merely because it concerns a client. Each request is assessed individually against the applicable statutory requirements and exceptions. We also consider the mandatory public-interest disclosure requirements in section 70 of PAIA.

10. Remedies

We have no internal appeal procedure. If you are unhappy with our decision, you may lodge a complaint with the Information Regulator (s 77A) or apply to court (s 78) within 180 days of being notified of the decision.

11. Processing of personal information

As section 51 of PAIA requires, as amended by POPIA:

Purpose of processing

To respond to enquiries, provide consulting and training services, manage suppliers, keep financial and tax records, and run and secure our website.

Categories of data subjects and information

Recipients

Service providers for the functions they perform (Data Keepers for hosting and email; Cloudflare for website visit statistics; Google for document storage, backups, meeting invitations and forms; Calendly for bookings; Zoom for meetings and meeting summaries; Fathom for call recordings; and AI tools for drafting and research), our accountant, and authorities where the law requires disclosure.

Planned transfers outside South Africa

Information may be processed outside South Africa, mainly in the United States, by Google, Cloudflare, Calendly, Zoom, Fathom and our AI tool providers. We rely on section 72(1)(a) of POPIA, as explained in our privacy notice.

Security measures

Encrypted website connections, password-protected accounts with multi-factor authentication where available, written operator agreements, restricted access to records, and a process for notifying security compromises under section 22 of POPIA.

Requests to access or correct your own personal information can also be made under sections 23 and 24 of POPIA. See our privacy notice.

12. Availability and updates

This manual is available on our website and from the Information Officer on request, free of charge. We review it when our records or practices change.