1.Purpose of this manual
1.1
This manual is published under section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA). It explains what records Kairos Intelligence (Pty) Ltd holds, how to ask for access to them, and how we process personal information as required by section 51(1)(c) of PAIA read with the Protection of Personal Information Act 4 of 2013 (POPIA).
1.2
This manual applies to Kairos Intelligence (Pty) Ltd only. Where we process personal information on behalf of a customer as an operator, the customer is the responsible party and a request for that information should be made to the customer.
2.Our details
- Name: Kairos Intelligence (Pty) Ltd
- Registration number: 2026/501947/07
- Physical and postal address: Atterbury House, Hampton Office Park, 20 Georgian Crescent, Bryanston, 2191, South Africa
- Telephone: +27 76 545 2494
- Email: [email protected]
- Website: https://kairosintel.co.za
3.Information Officer
3.1
Our Information Officer is Jason Basterfield, a director of Kairos Intelligence (Pty) Ltd. Requests under this manual are addressed to the Information Officer at the address and email above.
4.Guide on how to use PAIA
4.1
The Information Regulator has compiled a guide, under section 10 of PAIA, on how to exercise any right under PAIA and POPIA. It is available in each official language from the Information Regulator (South Africa), JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001, and at https://inforegulator.org.za.
4.2
A copy of the guide may also be inspected at our offices during business hours.
5.Records available without a request
5.1
The following are available without a formal request, on our website or by email to the Information Officer:
- Product and service information published on our website
- Our Terms and Conditions of Service, Privacy Policy, and Refund and Cancellation Policy
- This manual
6.Records kept under other legislation
We keep records in accordance with the following legislation, to the extent it applies to us:
- Companies Act 71 of 2008
- Income Tax Act 58 of 1962
- Tax Administration Act 28 of 2011
- Protection of Personal Information Act 4 of 2013
- Electronic Communications and Transactions Act 25 of 2002
- Consumer Protection Act 68 of 2008
- Financial Intelligence Centre Act 38 of 2001, where applicable
- Labour legislation, including the Basic Conditions of Employment Act 75 of 1997, where we employ staff
7.Subjects and categories of records
- Company records — memorandum of incorporation, registration documents, securities register, director records, resolutions and minutes
- Financial records — accounting records, financial statements, tax returns and assessments, banking records
- Customer records — agreements, subscription and billing records, account and user details, support correspondence
- Service records — configuration of customer connections, audit trails, and security and access logs
- Supplier and operator records — agreements with hosting, technology, payment and professional service providers
- Marketing records — website enquiries, consent records and opt-out records
- Information technology records — security policies, incident records and system documentation
- Personnel records — where we engage employees or contractors, their contracts, payroll and statutory records
7.1
Listing a category does not mean that every record in it will be released. Access is subject to the grounds of refusal in Part 3, Chapter 4 of PAIA.
8.Processing of personal information
In line with section 51(1)(c) of PAIA, our Privacy Policy sets out in full:
- the purposes for which we process personal information (section 7)
- the categories of data subjects and of personal information we process (sections 3 and 5)
- the recipients to whom personal information may be supplied (section 10)
- planned transfers of personal information outside South Africa (section 11)
- the security measures we apply (section 12)
9.How to request access
9.1
A request must be made on Form 2 prescribed under the PAIA Regulations, 2021, available from the Information Regulator's website, and sent to the Information Officer by email or delivered to our address.
9.2
The requester must give enough detail to identify the record, state the form and language of access required, and, where the request is made on behalf of another person, provide proof of that capacity. A requester who wants access to a record to exercise or protect a right must identify the right and explain why the record is required.
9.3
We will decide on a request within 30 days of receiving it. We may extend this once by up to 30 days in the circumstances set out in section 57 of PAIA, and will tell you if we do.
9.4
A request fee and an access fee may be payable, at the amounts prescribed in the PAIA Regulations. We will tell you of any fee before processing the request.
9.5
A request for a data subject's own personal information may also be made under section 23 of POPIA, as described in section 16 of our Privacy Policy.
10.Remedies
10.1
We do not have an internal appeal procedure. A requester who is dissatisfied with our decision, or with a fee or extension, may lodge a complaint with the Information Regulator under section 77A of PAIA, or apply to court under section 78, within the periods PAIA prescribes.
11.Availability of this manual
11.1
This manual is available on our website at kairosintel.co.za/paia and at our offices for inspection during business hours, free of charge. We will update it when our details or records change.