PAIA manual

1. Abbreviations

2. Purpose of this manual

This manual helps you to:

• see which of our records you can get without a formal request
• understand the subjects on which we hold records, and the categories of records we hold on each subject, so that you can make a request
• find the Regulator's Guide and contact details
• learn how to request access to a record, what it costs, and what you can do if we refuse
• understand how we process personal information: why, about whom, who receives it, whether it leaves South Africa, and how we protect it

3. Our contact details

3.1 Information Officer

3.2 Deputy Information Officer

No Deputy Information Officer has been appointed.

3.3 Business details

4. The Regulator's Guide on how to use PAIA

The Regulator has updated and published a Guide, under section 10 of PAIA, that explains how to use PAIA and POPIA. It sets out how to make a request, what it costs, the time limits, and the remedies if a request is refused. It is available in all eleven written official languages.

You can get the Guide:

• from the Regulator's website, inforegulator.org.za
• at the Regulator's office during office hours
• from us. We keep a copy in English and Afrikaans at our office for anyone to inspect during office hours. We will give you a copy free of charge if you ask for one, using Form 1 of the PAIA Regulations or a clear written request (regulation 3 of the PAIA Regulations)

The Regulator's contact details are:

5. Records available without a request

There is no notice under section 52(2) of PAIA for our records. The following records are available to anyone without a formal request, as section 52(1) allows:

• the pages of our website, cvpcservices.com, including descriptions of our services, our way of working and our maintenance plans
• our privacy notice, website terms of use and this manual, all on our website

As regulation 5 of the PAIA Regulations requires, we keep this list up to date and make it available on our website, at our office and to the Regulator. If you want a printed copy of one of these records, you pay only the reproduction fee in Annexure B of the PAIA Regulations.

6. Records available under other laws

We keep records that other laws require, and some of them are available as those laws allow.

A record on this list is not necessarily available to the public. The law it is kept under decides who may see it.

7. Subjects and categories of records we hold

A category on this list does not confirm that a particular record exists, or that we must release it. We may or must refuse access on the grounds in Chapter 4 of Part 3 of PAIA (sections 62 to 70), for example to protect another person's privacy, a third party's commercial or confidential information, someone's safety, or legally privileged records. If only part of a record is protected, we will release the rest.

8. How we process personal information

This section sets out the information that section 51(1)(c) of PAIA requires about how we process personal information under POPIA. Our privacy notice gives more detail for website visitors and people who contact us.

8.1 Why we process personal information

• to answer enquiries, carry out site assessments and prepare quotes
• to schedule and carry out work, manage maintenance plans, and keep job records
• to invoice, receive payments and keep accounting and tax records
• to keep our people and our clients' properties safe, and to meet health and safety and COIDA duties
• to employ and pay staff, and to recruit
• to manage suppliers, insurers and service providers
• to run, secure and measure the use of our website
• to handle complaints, insurance claims and legal claims
• to send marketing by email, WhatsApp, SMS and phone call, to people who have consented to it and to customers who have not said no
• to meet our other legal duties

8.2 About whom we process information, and what information

8.3 Who may receive personal information

• Orivue (Pty) Ltd, which builds, hosts and maintains our website and booking form as our operator, runs our Microsoft Clarity project and helps manage our Google Analytics
• Cloudflare, Inc., which hosts and protects our website, runs our booking form, delivers form entries to our mailbox, checks for spam and counts visits, unless a visitor turns analytics off
• Google LLC, for Google Analytics, unless a visitor turns it off
• WhatsApp, a service of Meta, when someone chooses to message us on WhatsApp, and for the marketing messages we send on WhatsApp to people who agreed to receive them
• Microsoft, through Microsoft 365, which hosts our email
• Microsoft, through Microsoft Clarity, which shows us how visitors use our website, only for visitors who choose Allow. For this information Microsoft is a separate responsible party, under its own terms and privacy statement
• our accountant, tax practitioner, bank, insurers and legal advisers
• the South African Revenue Service, the Unemployment Insurance Fund, the Compensation Fund, the Department of Employment and Labour and other public bodies, where the law requires it
• courts and law enforcement, where the law requires it

8.4 Planned transfers outside South Africa

Cloudflare, Google and Meta process information in many countries, including the United States. Our email is hosted on Microsoft 365, which may store it outside South Africa, in Microsoft's data centres. Cloudflare, Google and Microsoft are bound by data processing terms that protect personal information to a standard substantially similar to POPIA (section 72(1)(a) of POPIA); for Microsoft 365, those terms are the Microsoft Products and Services Data Protection Addendum. Microsoft Clarity data is held by Microsoft in its Azure cloud, and Microsoft Corporation is in the United States. Clarity runs only after a visitor chooses Allow, and for its transfer we rely on that consent (section 72(1)(b)); Microsoft is also bound by Clarity's terms of use to comply with data protection law and keep the information secure. When someone sends us the booking form, emails us or chooses to message us on WhatsApp, the transfer is needed to take the steps they asked for (section 72(1)(c)). When someone has agreed to receive our marketing on WhatsApp, we rely on that consent for the transfer (section 72(1)(b)). We plan no other transfers outside South Africa.

8.5 How we protect personal information

• Our website is served only over encrypted (HTTPS) connections, with strict browser security settings.
• Our booking form is protected from spam by Cloudflare Turnstile and sends entries straight to our mailbox. The website keeps no separate database of enquiries.
• Google Analytics and Microsoft Clarity never receive form entries. Microsoft Clarity runs only for visitors who choose Allow. Any visitor can turn off Google Analytics, Microsoft Clarity and Cloudflare Web Analytics.
• Only the people who need personal information to do their work can see it.
• Our operator, Cloudflare and Google, and Microsoft for our email, may process personal information only on our instructions, under written terms that require them to keep it confidential and secure, as sections 20 and 21 of POPIA require. For Clarity, Microsoft acts under its own terms.
• We keep personal information only as long as we need it or the law requires, and then delete or destroy it.
• If we believe personal information has been accessed without permission, we will tell the Regulator and the people affected, as section 22 of POPIA requires.

9. How to request access to a record

9.1 Your own personal information

If you want to know what personal information we hold about you, you can ask under section 23 of POPIA. You do not need to use the PAIA request form. We will confirm free of charge whether we hold personal information about you. If a copy of the information carries a fee, we will give you a written estimate before we do the work. You can also ask us, at any time and free of charge, to correct or delete your information or to stop using it, by email, phone, WhatsApp, SMS, post or by hand. Our privacy notice explains how.

9.2 Other records

The Information Regulator publishes the PAIA forms. You can download two of them here:

• Form 2, Request for access to record (PDF, 146 KB): the request form.
• Form 3, Outcome of request and of fees payable (PDF, 147 KB): the form we use to give you our decision and the fees.

1. Complete Form 2 of the PAIA Regulations (Request for access to record). You can download it above, from the Regulator's PAIA forms page, or ask us for a copy.
2. Send it to our Information Officer by email to info@cvpcservices.com, or by post or by hand to 1B Wahlberg Eagle St, Centurion, 0157, South Africa.
3. Give enough detail for us to identify the record and you, say in what form you want access, and give a postal address or fax number in South Africa where we can reach you, and an email address if you have one.
4. Say which right you want to use or protect, and explain why you need the record to do so (section 53 of PAIA).
5. If you are asking on behalf of someone else, include proof that you may act for them.

If you cannot read or write, or have a disability that makes the form difficult, you may make your request orally. Our Information Officer will complete Form 2 for you and give you a copy (regulation 7 of the PAIA Regulations). Our Information Officer will also help you with any other part of your request.

9.3 Fees

The fees are set in Annexure B of the PAIA Regulations. For a private body like ours, they are:

We will tell you in writing what fees apply. We may keep a record until the fees are paid. If we refuse your request after you paid a deposit, we will repay it. If you disagree with a fee or deposit, you may complain to the Regulator.

9.4 Time limits and our decision

We will decide on your request and tell you within 30 days of receiving it with all the required details (section 56 of PAIA). If the request involves many records, needs a search in another place, or needs us to consult others, or if you agree, we may extend this once, by up to 30 more days. We will tell you in writing before the first 30 days end (section 57). If we do not decide in time, the law treats your request as refused (section 58).

If a record concerns someone else, we must first tell that person and give them 21 days to respond before we decide (section 71). We will let you know if this applies.

If we refuse your request, we will give you the reasons and the sections of PAIA we rely on, without revealing what the record contains.

9.5 If you are not satisfied

You may complain to the Regulator within 180 days of our decision (section 77A of PAIA), using the Regulator's PAIA complaint form (Form 5), sent to PAIAComplaints@inforegulator.org.za. After the complaint process, you may apply to court within 180 days (section 78).

10. Availability of this manual

As section 51(3) of PAIA requires, this manual is available:

• on our website at cvpcservices.com/paia
• at our principal place of business, 1B Wahlberg Eagle St, Centurion, 0157, South Africa, for anyone to inspect during normal business hours
• to anyone who asks for a copy, for a reasonable fee to cover the cost of copying
• to the Regulator, on request

11. Updating this manual

We review this manual regularly, as section 51(2) of PAIA requires, and whenever our records, service providers or contact details change. The dates at the top show the current version.

Issued by the Information Officer of Clear View Property Care (Pty) Ltd.

Ryno Kilian, Director and Information Officer