PAIA Manual
1. About this manual
This manual is published in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 (“PAIA”). It describes the records Celagenix Business Advisory (Pty) Ltd (“Celagenix”, “we”, “us”, “our”) holds as a private body, and how to request access to them under PAIA.
This is distinct from your rights under the Protection of Personal Information Act 4 of 2013 (“POPIA”) to access your own personal information, which are described in our Privacy Policy. See Section 9 below for how the two relate.
2. The head of the body
Celagenix Business Advisory (Pty) Ltd t/a Celagenix Agency
Registered address: 4th Floor West Wing, Nelson Mandela Square, Sandton City, Sandton, Johannesburg, 2196
Phone: 012 755 5528
Email: popi@celagenix.com
3. How to use PAIA
The Information Regulator maintains and makes available the guide required by PAIA section 10 on how to use the Act, including how to draft a request and what a public or private body must do with it. Responsibility for the guide passed to the Regulator when POPIA's amendments to PAIA took effect on 30 June 2021. It is available from the Information Regulator: www.inforegulator.org.za.
4. Records available without a request
The following are published on our website and do not require a PAIA request:
- Privacy Policy (our POPIA-required disclosures, including what we collect and why)
- Terms of Service
- This PAIA Manual
5. Records held, by category
Celagenix holds the following broad categories of records. This is a description of categories, not an exhaustive index of every document. PAIA does not require the latter.
- Customer and subscriber records: account, billing and correspondence records for organisations and individuals who use PopiGuard's Snapshot quiz, paid Assessment, or Compliance Hub subscription. See our Privacy Policy for what personal information this includes.
- Compliance Hub content, held as an operator: records our Compliance Hub subscribers enter into the platform (tasks, policy documents, data subject requests, breach records). Celagenix processes this only on the subscriber's instruction; the subscribing organisation (not Celagenix) is the responsible party and the correct body to approach for a PAIA request about its own records.
- Corporate and financial records: company registration, tax and accounting records, and vendor/supplier agreements.
- Employee and contractor records: personnel records for our own staff.
- Marketing and correspondence records: website enquiries, support correspondence, and marketing lists (opt-in/opt-out records).
6. Information Officer
Celagenix's Information Officer is responsible for encouraging compliance with PAIA and POPIA within the company, and is the point of contact for a PAIA request. Direct any PAIA request or query to popi@celagenix.com, addressed to “The Information Officer,” or to the registered address in Section 2 above.
7. How to request a record
A request for access to a record held by Celagenix must be made using the prescribed form (PAIA “Form 2,” available from the Information Regulator's website) and submitted to the Information Officer at the address or email in Section 2 above. The request must provide sufficient detail to enable us to identify the record and the requester, and to process the request in the manner and format requested, if reasonably possible.
We will respond within 30 days of receiving a request that meets the Act's requirements, as required by PAIA section 56. If a request is refused, we will provide written reasons, and the requester may complain to the Information Regulator or apply to a court, as PAIA provides for private bodies (PAIA's internal-appeal mechanism applies only to public bodies).
8. Fees
A request fee and, where applicable, an access fee may apply, calculated according to the fee structure prescribed under the PAIA regulations. Where the request is for your own personal information, any fee position is governed by the current PAIA fee regulations read with POPIA section 23. Confirm the applicable fee (if any) with the Information Officer when submitting your request.
9. Records your own subscription holds about you
If you are asking about your own personal information (for example as a Compliance Hub subscriber, or as someone whose information an estate, HOA or law firm subscriber processes using the platform), that is a POPIA access request (section 23), not a PAIA request, and is usually faster: see Section 11 of our Privacy Policy. If your request concerns records your own organisation holds about you (rather than your relationship with Celagenix directly), it should be directed to that organisation's own Information Officer, not to Celagenix, which processes that data only as an operator on the organisation's instruction.