PAIA Manual

1. About this manual

The Promotion of Access to Information Act gives effect to the constitutional right of access to information. Section 51 requires a private body to publish a manual explaining what records it holds and how to request them. This is that manual for INNOVACE (Pty) Ltd, registration number 2025/316516/07.

It is available free of charge on this website, and on request from our Information Officer.

2. Contact details

Information Officer
INNOVACE (Pty) Ltd
Email: privacy@innovace.co.za
Website: innovace.co.za
22 Umhlanga Boulevard, Umhlanga, 4321
South Africa

3. The Information Regulator's guide

The Information Regulator has compiled a guide, in terms of section 10, on how to use PAIA. It is a plain-language explanation of your rights and how to exercise them. You can obtain it from:

The Information Regulator (South Africa)
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
Email: enquiries.IR@justice.gov.za
PAIA complaints: PAIAComplaints@inforegulator.org.za
inforegulator.org.za

4. Records available without a request

Some information is published and needs no PAIA request at all. You can simply read it:

• our public website content, including our product information and company information;
• our Privacy Policy, which explains how we handle personal information;
• our public API documentation at docs.innovace.co.za;
• this manual.

We have not submitted a notice under section 52(2) listing categories of records that are automatically available on request.

5. Records held, by category

The categories below describe the kinds of records we keep. Listing a category here does not mean the record will be released: every request is assessed on its merits against the grounds for refusal in the Act.

Company records

• founding and statutory documents, and records held under the Companies Act;
• financial and accounting records, tax records, and banking details;
• insurance, contracts and agreements with suppliers and customers.

Employee records

• personnel and recruitment records for our own staff;
• payroll, leave and attendance records, and records held under employment and tax legislation.

Customer and enquiry records

• enquiries submitted through this website, and the correspondence arising from them;
• customer account and billing records, and support correspondence.

Operational and technical records

• system, security and audit logs;
• source code, technical documentation and internal procedures.

Records we hold on behalf of our customers

We host personal information that our customers process about their own employees and job applicants. We hold those records as an Operator, on the customer's instructions. We are not the party who decides about access to them. A request for those records must be directed to the customer concerned, as the Responsible Party and the body that holds them for PAIA purposes.

6. How to request a record

1. Complete the prescribed PAIA request form (Form 2, available from the Information Regulator's website).
2. Send it to our Information Officer at the address in section 2 above.
3. Provide enough detail to identify the record and to let us contact you, and state the right you are seeking to exercise or protect, and why the record is required for it.
4. If you are asking on behalf of someone else, include proof of your authority.
5. Pay the applicable fees (section 7).

We will respond within 30 days. That period may be extended in the circumstances the Act allows, and we will tell you in writing if it is. If we refuse, we will give reasons and explain how to appeal.

A requester who is asking for their own personal information does not use this route: that is a data-subject request under POPIA, and our Privacy Policy explains how to make one.

7. Fees

PAIA allows a private body to charge the prescribed fees:

• a request fee, payable before the request is processed (not payable by a personal requester seeking their own records);
• an access fee for the time spent searching for and preparing the record, and for reproduction and postage.

Current amounts are those prescribed by regulation from time to time. We will quote you before doing the work, and you may lodge an internal appeal against a fee you consider unreasonable.

8. Grounds for refusal

The Act obliges or permits us to refuse access in certain cases, including where release would:

• unreasonably disclose someone else's personal information;
• reveal commercial information, trade secrets or confidential information belonging to us or a third party;
• breach a duty of confidence owed to a third party;
• prejudice someone's safety, or the protection of property;
• disclose privileged legal information;
• disclose research information in a way that would prejudice the researcher.

Where a ground applies to only part of a record, we will give you access to the remainder.

9. If you are unhappy with our decision

You may lodge a complaint with the Information Regulator, or apply to a court, in the circumstances the Act allows. The Regulator's details are in section 3.

10. Records held under other legislation

We keep records as required by, among others, the Companies Act, the Income Tax Act, the Value Added Tax Act, the Basic Conditions of Employment Act, the Labour Relations Act, the Employment Equity Act, the Unemployment Insurance Act, the Compensation for Occupational Injuries and Diseases Act, and the Protection of Personal Information Act.

11. Updates

We will update this manual whenever our details or our categories of records change. The date at the top of the page shows when it last changed.