PAIA MANUAL (ACCESS TO INFORMATION)

Prepared in terms of Section 51 of the Promotion of Access to Information Act 2 of 2000 (as amended)

1. Introduction

KT Opportunities (Pty) Ltd (trading as KTO Digital / J-Cred) respects the right of access to information as entrenched in the South African Constitution. This manual provides an outline of the types of records held by the company and explains how you may submit a request to access these records in terms of the Promotion of Access to Information Act (PAIA) and the Protection of Personal Information Act (POPIA).

2. Company Contact Details

For all PAIA and POPIA related requests, please contact our Information Officer.

  • Head of Body: The CEO
  • Information Officer: The CIO
  • Physical Address: Unit 16 No.526 16th Road Constantia Square Office Park Randjespark Gauteng 1685
  • Postal Address: Same as above
  • Telephone: +27 10 224 0589
  • Email: legal@kto.co.za
  • Website: www.j-cred.co.za

3. The PAIA Guide

The Information Regulator has compiled a guide on how to use PAIA. This guide is available in all official languages and provides details on how to exercise your rights under the Act. You can access the guide via the Information Regulator’s website: https://inforegulator.org.za/

4. Records We Hold

We hold records in the following categories. Please note that the presence of a category here does not mean that a request for access will automatically be granted; certain records are protected by confidentiality or legal privilege.

A. Internal Records

  • Memorandum of Incorporation (MOI)
  • Minutes of Board of Directors Meetings
  • Financial Records (Annual Financial Statements, Tax Returns, VAT, Asset Registers)
  • Operational Policies and Procedures

B. Personnel Records

  • Employment Contracts and Letters of Appointment
  • Payroll Records (PAYE, UIF, SDL)
  • Disciplinary Records
  • Training Manuals and Workplace Skills Plans

C. Customer & Client Records

  • Service Level Agreements (SLAs)
  • Client Confidentiality Agreements
  • J-Cred User Data (strictly controlled in terms of POPIA)
  • Invoices and Statements

D. Information Technology

  • Software Licenses
  • Disaster Recovery Plans
  • IT Security Policies (Information Security, Password Policies)

5. How to Request Access to Information

If you wish to request access to a record held by KTO Digital / J-Cred, please follow this procedure:

  1. Download Form 2: Use the prescribed Request for Access to Record (Form 2). Request link: https://j-cred.co.za/contact/
  2. Complete the Form: Provide sufficient detail to enable the Information Officer to identify the record and the requester. You must also indicate which right you are seeking to exercise or protect.
  3. Submit the Request: Email the completed form to legal@kto.co.za.
  4. Pay the Request Fee: A non-refundable request fee of R140.00 is payable upon submission (excluding personal requests).
  5. Await Response: We will respond within 30 days of receiving your request. We may extend this period by a further 30 days if the request is complex.

6. Prescribed Fees

The following fees apply to requests (in accordance with the 2021 Regulations):

  • Request Fee: R140.00 (payable upfront).
  • Access Fees: Calculated based on time spent searching/preparing (R145.00 per hour or part thereof) and reproduction costs (e.g., R2.00 per A4 page).
  • Deposit: If the search requires more than 6 hours, a deposit of one-third of the access fee is required.

7. Grounds for Refusal

We may refuse access to records under certain circumstances, including:

  • Protection of personal information of a third party (privacy).
  • Protection of commercial information of a third party (trade secrets).
  • Protection of confidential information protected by an agreement.
  • Protection of the safety of individuals or property.
  • Protection of privileged information in legal proceedings.

8. Remedies

If your request for access is refused, you may:

  1. Contact the Information Officer to discuss the refusal.
  2. Lodge a complaint with the Information Regulator (using Form 5).
  3. Apply to a court of law for appropriate relief.