SADV (Pty) Ltd — PAIA Manual (Private Body)

Manual prepared in accordance with section 51 of the Promotion of Access to Information Act, 2000 (PAIA).

1. Introduction and Application

PAIA gives effect to the constitutional right of access to information in records held by public and private bodies that is required for the exercise or protection of any rights. This Manual serves as SADV’s information manual and explains what records SADV holds and how to request access to them.

The Manual may be amended from time to time. Enquiries can be directed to the Information Officer (see section 6).

2. Scope of the Manual

This Manual applies to SADV and is limited to records held by the company in connection with its operations.

3. Definitions

Customer: a natural or juristic person who receives services and/or products from SADV.

Data Subject: the person to whom Personal Information relates (may include Employees and Third Parties).

Employee: any person who works for or provides services to SADV and receives (or is entitled to) remuneration; includes Third Parties acting under SADV’s authority.

Information Officer: SADV’s designated information officer responsible for compliance with POPIA, PAIA and this Manual.

Manual: this PAIA manual, as amended, available on https://www.sadv.co.za and at SADV’s offices.

PAIA: Promotion of Access to Information Act 2 of 2000.

Personal Information: as defined in POPIA (includes special personal information).

POPIA: Protection of Personal Information Act 4 of 2013.

Processing: any operation concerning Personal Information (collection, storage, use, dissemination, deletion, etc.).

Record: any recorded information, regardless of form or medium, in SADV’s possession or control.

Requester: any person/entity requesting access to a record under SADV’s control (including on behalf of a Data Subject).

SADV: SADV (Pty) Ltd, reg. no. 2019/588585/07, including its brands/trade names and subsidiaries from time to time.

Third Party: any service provider, agent, supplier, contractor, consultant or other representative of SADV.

4. How to Use PAIA to Access Information

Requests must follow PAIA’s prescribed procedures and fees (see section 10). The Information Regulator has issued a Guide in terms of section 10(1) of PAIA, available on the Regulator’s site or via SADV’s Information Officer.

Information Regulator (South Africa)
Physical: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
Postal: P.O Box 31533, Braamfontein, Johannesburg, 2017
E-mail: enquiries@inforegulator.org.za / PAIAComplaints@inforegulator.org.za
Website: https://inforegulator.org.za/
Tel: 010 023 5200

The Guide explains request procedures, forms, fees, remedies and related provisions of PAIA and POPIA.

5. Overview of the Structure and Functions of SADV

SADV (reg. no. 2019/588585/07) is an Internet Service Provider (ISP) specialising in broadband internet services, including FTTH connectivity, customer support, and related value-added digital services to residential and business customers.

6. SADV’s Contact Details

Name of Body: SADV (Pty) Ltd

Physical & Postal: 31 Georgian Crescent East, Bryanston, 2191, Johannesburg, Gauteng

Telephone: 012 443 1000

Website: https://www.sadv.co.za

Email (POPIA/PAIA): POPI@sadv.co.za

Head of Body: Venita Engelbrecht — Venita.Engelbrecht@sadv.co.za

Information Officer: Heydon Hall — information-officer@sadv.co.za

7. SADV’s Processing of Personal Information (POPIA)

7.1 Purpose of Processing

SADV Processes Personal Information for business purposes consistent with providing ISP services (provisioning, support, billing, marketing, compliance, audits, fraud prevention, employment, etc.). Retention is for as long as necessary for lawful business purposes or as permitted/required by law.

7.2 Categories of Data Subjects

Customers; service providers; partners/distributors/resellers; employees/personnel; website visitors; beneficiaries of employees; directors; application users; new job applicants.

7.3 Examples of Personal Information

Depending on the Data Subject category, this may include identification data, contact details, addresses, KYC/FICA, financials, employment history, qualifications, biometric/access records, CCTV, etc.

7.4 Recipients/Categories of Recipients

Disclosures may occur where required by law/court order; to authorised service providers under appropriate safeguards; in corporate transactions; to regulators, retirement funds, medical aids, insurers, recruiters, law enforcement, SARS, and other categories as applicable.

7.5 Planned Transborder Flows

Personal Information may be transferred to foreign jurisdictions (including cloud/data centres) with consent or as otherwise permitted by POPIA’s cross-border provisions.

7.6 Information Security Measures

SADV maintains reasonable technical, administrative and physical security measures (restricted access, training, unique IDs, passwords, MFA/2-step where applicable, backups and testing, malware protection, vulnerability scanning, network monitoring, incident logging, and periodic reviews).

8. Information Held by SADV in Terms of PAIA

Categories include company, accounting, customer, HR, operations, marketing and Third-Party records. Availability is subject to PAIA’s grounds for refusal and applicable conditions.

9. Information Kept in Accordance with Other Legislation

Records are kept in accordance with applicable legislation (e.g., Companies Act, ECTA, ICASA Act, Income Tax Act, Labour Relations Act, OHS Act, POPIA, PAIA, RICA, VAT Act, etc.).

10. Access Requests

10.1 Form of Request

Use the prescribed PAIA form (download from the Information Regulator) and submit it to the Information Officer. Provide sufficient detail to identify the record, your contact details, form of access, the right to be exercised/protected, and (if applicable) proof of authority when acting on behalf of another.

10.2 Fees

Request fee: R140 (payable before processing; you may apply to court against the fee).
Access & reproduction fees: payable if access is granted.

Reproduction	Fee (ZAR)
Photocopy/scan of A4 page (hard copy or emailed scan)	R2.00 per page
Printed A4 page from electronic source	R2.00 per page
Copy on flash drive (provided by Requester)	R40.00
Copy on compact disc (provided by Requester)	R40.00
Copy on compact disc (provided by SADV)	R60.00
Transcription of visual images (per A4 page)	Outsourced — per quotation
Copy of visual images	Outsourced — per quotation
Transcription of audio record (per A4 page)	R24.00
Copy of audio record on flash drive (provided by Requester)	R40.00
Copy of audio record on compact disc (provided by Requester)	R40.00
Copy of audio record on compact disc (provided by SADV)	R60.00
Search & preparation (per hour or part thereof, excluding first hour)	R145.00 (max R435.00)
Deposit (if search exceeds 6 hours)	One-third of total (items above)
Postage / e-mail / other electronic transfer	Actual costs

11. Timelines for Consideration of a Request

The Information Officer will decide within 30 days whether to grant or refuse the request (extendable once for up to 30 days in defined circumstances). You will be notified of any extension and reasons.

12. Grounds for Refusal of Access to Records

Requests must be refused where disclosure would, for example, unreasonably reveal Personal Information of a third party, disclose certain third-party commercial information, breach confidence, endanger life/safety, reveal privileged information, or expose protected research. Requests may be refused in additional circumstances (e.g., prejudice security, reveal SADV trade secrets or sensitive commercial information, reveal SADV computer programs, or expose research to serious disadvantage).

13. Remedies Available to a Requestor

If dissatisfied with SADV’s decision, you may lodge a complaint with the Information Regulator within 180 days. After exhausting the Regulator’s process, you may apply to a court of competent jurisdiction within 180 days of the Regulator’s decision (section 82 of PAIA). Third parties similarly have recourse where access is granted.