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VIRTUTECH SOLUTIONS

PAIA Manual

Manual in terms of section 51 of the Promotion of Access to Information Act 2 of 2000.

Company
VirtuTech Solutions (Pty) Ltd
Email
+27 73 331 3840
Website
www.virtutech.co.za
Information Officer
Nosipho Mahlangu
Information Officer Email
nosipho@virtutech.co.za

VirtuTech Solutions (Pty) Ltd ("VirtuTech") is a private technology and digital transformation company operating in South Africa.

This Manual has been prepared in accordance with section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA).

PAIA gives effect to the constitutional right of access to information and establishes procedures through which persons may request access to records held by public and private bodies.

The Information Regulator states that PAIA manuals provide guidance regarding information held by a body and the procedures for requesting access to records.

This Manual must be read together with VirtuTech's Privacy Policy and other applicable policies.

The purpose of this Manual is to:

  1. Provide information about VirtuTech;
  2. Identify the categories of records held by VirtuTech;
  3. Explain how a person may request access to records;
  4. Explain the procedures applicable to access requests;
  5. Explain applicable fees;
  6. Identify circumstances in which access may be refused;
  7. Provide information regarding the Information Officer;
  8. Promote transparency and accountability;
  9. Assist persons in exercising their rights under PAIA and POPIA.

VirtuTech Solutions (Pty) Ltd is a South African technology and digital transformation company.

VirtuTech provides services including:

  • Software Development;
  • Website Development;
  • Mobile Application Development;
  • UI/UX Design;
  • Digital Marketing;
  • Branding and Creative Services;
  • Business Automation;
  • Digital Transformation;
  • Technology Consulting;
  • Software and Website Maintenance.

VirtuTech may also provide physical branding, printing, embroidery, corporate clothing, promotional products, and related services through VirtuBrand.

VirtuTech may develop and operate proprietary digital products and software platforms, including SaaS and technology solutions.

Physical Address: Johannesburg, South Africa

Email: info@virtutech.co.za

Website: www.virtutech.co.za

In terms of applicable legislation, VirtuTech has designated an Information Officer responsible for matters relating to access to information and privacy compliance.

Information Officer: Nosipho Mahlangu

Position: Information Officer

Email: nosipho@virtutech.co.za

The Information Officer is responsible for, among other matters:

  • Facilitating compliance with PAIA;
  • Facilitating compliance with POPIA;
  • Handling requests for access to information;
  • Assisting requesters where appropriate;
  • Maintaining this Manual;
  • Liaising with the Information Regulator;
  • Promoting awareness of PAIA and POPIA within the organisation.

The Information Regulator notes that Information Officers have responsibilities relating to compliance frameworks, personal-information impact assessments, PAIA manuals, internal information-request systems, and POPIA compliance.

The Promotion of Access to Information Act 2 of 2000, as amended, gives effect to the constitutional right of access to information.

In respect of a private body, access to a record may be requested where the record is required for the exercise or protection of rights and the applicable procedural requirements have been complied with, subject to lawful grounds for refusal.

The Information Regulator confirms that PAIA provides a framework for requesting access to records held by private bodies.

The Protection of Personal Information Act 4 of 2013 (POPIA) regulates the processing of personal information.

VirtuTech recognises the importance of protecting personal information and aims to process personal information in accordance with applicable legal requirements.

POPIA establishes conditions for lawful processing and provides data subjects with rights relating to their personal information.

VirtuTech's Privacy Policy provides further information regarding how personal information is collected, used, stored, protected, and disclosed.

The following information may be made available without a formal PAIA request where appropriate:

  • Company profile;
  • General service information;
  • Public website content;
  • Marketing materials;
  • Public announcements;
  • Publicly available contact information;
  • Publicly available product information;
  • General information about VirtuTech's services;
  • Publicly available policies.

Certain records may be withheld where disclosure would breach confidentiality, privacy, intellectual-property rights, security requirements, contractual obligations, or other legal protections.

VirtuTech may hold records relating to its business operations, customers, suppliers, employees, contractors, financial activities, technology platforms, projects, and administration.

The existence of a category of records does not mean that every record within that category will necessarily be provided following a request.

Access remains subject to PAIA and other applicable laws.

The following categories of records may be held by VirtuTech.

  • Company registration documents;
  • Memoranda and corporate records;
  • Shareholder information where applicable;
  • Director information;
  • Corporate governance records;
  • Company policies;
  • Internal procedures;
  • Business plans;
  • Strategic documents.
  • Invoices;
  • Accounting records;
  • Financial statements;
  • Payment records;
  • Tax records;
  • Banking records;
  • Budgets;
  • Financial reports;
  • Supplier payment records.

Access may be restricted where disclosure would reveal confidential information or prejudice legitimate business interests.

  • Employment records;
  • Employment contracts;
  • Personnel records;
  • Payroll records;
  • Leave records;
  • Performance records;
  • Recruitment records;
  • Training records;
  • Disciplinary records.

Access to these records may be restricted by privacy and employment-related legal protections.

  • Customer contracts;
  • Quotations;
  • Proposals;
  • Invoices;
  • Project records;
  • Customer communications;
  • Support records;
  • Service agreements;
  • Account information.
  • Supplier agreements;
  • Quotations;
  • Purchase records;
  • Invoices;
  • Supplier communications;
  • Service agreements.
  • Software documentation;
  • System documentation;
  • Technical specifications;
  • Architecture documentation;
  • API documentation;
  • Development records;
  • Security records;
  • System logs;
  • Platform documentation.

Access to technical information may be restricted where disclosure could compromise security, intellectual property, trade secrets, or third-party confidential information.

  • Marketing strategies;
  • Campaign records;
  • Advertising records;
  • Market research;
  • Customer communications;
  • Social media records;
  • Marketing analytics.
  • Contracts;
  • Agreements;
  • Legal correspondence;
  • Legal opinions;
  • Dispute records;
  • Compliance records.

Access may be restricted where legal privilege or another ground for refusal applies.

VirtuTech may process personal information relating to:

  • Customers;
  • Prospective customers;
  • Employees;
  • Contractors;
  • Suppliers;
  • Business partners;
  • Website users;
  • Platform users;
  • Service providers.

Personal information may include:

  • Names;
  • Contact information;
  • Addresses;
  • Identification information;
  • Financial information;
  • Employment information;
  • Transaction information;
  • Communication records;
  • Technical information;
  • Account information.

Access to personal information will be handled in accordance with PAIA, POPIA, and other applicable legal requirements.

Other records may include:

  • Intellectual property records;
  • Project documentation;
  • Business correspondence;
  • Internal communications;
  • Operational records;
  • Compliance documentation;
  • Insurance records;
  • Risk-management records;
  • Security documentation.

A requester seeking access to a record must submit a request in accordance with the applicable PAIA procedure.

Requests should be directed to the Information Officer.

The Information Regulator identifies Form 02: Request for Access to Record as the prescribed form for access requests.

A request should:

  1. Be made using the prescribed form where applicable;
  2. Identify the record requested;
  3. Identify the requester;
  4. Specify the right the requester seeks to exercise or protect where required;
  5. Provide sufficient information to enable VirtuTech to identify the requested record;
  6. Specify the preferred form of access;
  7. Include the applicable request fee where required.

Requests should be submitted to:

Information Officer

VirtuTech Solutions (Pty) Ltd

Email: nosipho@virtutech.co.za

Certain requests may be subject to fees permitted under PAIA.

Fees may include:

  • Request fees;
  • Access fees;
  • Reproduction fees;
  • Search and preparation costs;
  • Postage or delivery costs where applicable.

Any applicable fee will be communicated to the requester in accordance with the applicable legal requirements.

The Information Regulator provides prescribed forms for communicating outcomes of requests and fees payable.

VirtuTech may refuse access to a record where PAIA permits or requires refusal.

Potential grounds may include protection of:

  • Personal information of another person;
  • Confidential information;
  • Trade secrets;
  • Commercially sensitive information;
  • Intellectual property;
  • Third-party information;
  • Privileged information;
  • Safety and security;
  • Legal proceedings;
  • Other information protected under PAIA.

A refusal will be communicated in accordance with applicable legal requirements.

VirtuTech will consider each request in accordance with PAIA and applicable legislation.

Where access is granted, the requester will be informed of:

  • The decision;
  • The form of access;
  • Applicable fees;
  • Any conditions relating to access.

Where access is refused, the requester will be informed of the decision and applicable remedies.

Where a requester is dissatisfied with a decision concerning access to information, the requester may have remedies available under applicable law.

Depending on the circumstances, these may include:

  • Requesting reconsideration where applicable;
  • Lodging a complaint with the Information Regulator;
  • Approaching a court with appropriate jurisdiction.

The Information Regulator provides procedures for PAIA complaints and identifies Form 05 for complaints regarding access to information.

VirtuTech recognises that access to information must be balanced against the constitutional right to privacy.

Where a PAIA request involves personal information, VirtuTech will consider the applicable provisions of POPIA and PAIA before disclosing the information.

Information will only be disclosed where there is a lawful basis to do so.

VirtuTech takes reasonable measures to protect records and personal information against:

  • Unauthorised access;
  • Loss;
  • Damage;
  • Unauthorised alteration;
  • Unauthorised disclosure;
  • Unauthorised destruction.

Security measures may include:

  • Access controls;
  • Authentication;
  • Password protection;
  • Encryption;
  • Secure hosting;
  • Backups;
  • Monitoring;
  • Physical security;
  • Employee awareness;
  • Technical safeguards.

The Information Regulator is the statutory authority responsible for monitoring and enforcing compliance with PAIA and POPIA.

Information Regulator

Website: https://inforegulator.org.za/

Email: enquiries@inforegulator.org.za

Telephone: 010 023 5200

Physical Address: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg

The Regulator's eServices platform provides services including PAIA Manual submissions, PAIA complaints, POPIA complaints, Information Officer registration, and compliance assessments.

This Manual will be made available:

  1. On the VirtuTech website;
  2. At VirtuTech's principal place of business;
  3. Upon request, subject to any applicable fee permitted by law;
  4. Through other legally permitted means.

The Information Regulator states that private bodies should make their PAIA Manual available on their website and at their principal place of business.

VirtuTech may update this Manual periodically to reflect:

  • Changes in legislation;
  • Changes in business operations;
  • Changes in information systems;
  • Changes in the categories of records held;
  • Changes in Information Officer details;
  • Guidance issued by the Information Regulator.

The latest version will be made available on the VirtuTech website.

VirtuTech Solutions is committed to promoting transparency, accountability, privacy, and responsible information management.

This Manual is intended to assist members of the public, customers, employees, suppliers, business partners, and other interested parties in understanding the information held by VirtuTech and the procedures for requesting access to such information.

Requests for information should be directed to the VirtuTech Information Officer using the contact details contained in this Manual.

VirtuTech Solutions (Pty) Ltd

Information Officer: Nosipho Mahlangu

Email: nosipho@virtutech.co.za

Telephone: +27 73 331 3840

Website: www.virtutech.co.za

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