PAIA Manual

This manual is published by Nexus Logic (Pty) Ltd ("Nexus Logic", "we", "us" or "our") in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 ("PAIA"), as amended by the Protection of Personal Information Act 4 of 2013 ("POPIA"). It explains what records we hold and how you can request access to them.

This is the single PAIA manual for Nexus Logic and applies to all of its products:

• Service Sense (www.servicesense.co.za): a customer and staff feedback platform for businesses, using QR codes.
• Work Marketplace (www.workmarketplace.co.za): a platform connecting job seekers with employers.
• Mi Service Provider (www.miserviceprovider.co.za): an online service provider platform.

1. Purpose of this manual

PAIA gives effect to the constitutional right of access to information held by another person that is required for the exercise or protection of any rights (section 32 of the Constitution). Under section 50 of PAIA, a requester must be given access to a record of a private body if the record is required for the exercise or protection of a right, the requester complies with the procedure in PAIA, and no ground of refusal applies.

2. Contact details

• Name of private body: Nexus Logic (Pty) Ltd
• Registration number: 2026/756972/07
• Information Officer: Norman Hunt
• Deputy Information Officer: Carlo Swiegelaar
• Email: info@nexuslogic.co.za (marked "Attention: Information Officer")
• Telephone: 044 874 4395
• Physical and postal address: 138 Merriman Street, George, 6529, South Africa
• Website: nexuslogic.co.za

Security notice: We will never ask you for passwords, one-time PINs, card details or banking logins in connection with a PAIA request. Report suspicious messages to info@nexuslogic.co.za.

3. Information Regulator's guide

The Information Regulator has published a guide on how to use PAIA and POPIA, in terms of section 10 of PAIA. It explains your rights and how to exercise them. The guide is available on the Information Regulator's website at inforegulator.org.za, and a copy may be inspected at our address during normal business hours.

4. Records automatically available

The following records are available without a formal request, free of charge, on our websites:

• This PAIA Manual (nexuslogic.co.za/paia)
• The Terms of Service and Privacy Policy of each product, published on that product's website
• Product information and pricing on each product's website

5. Records held under other legislation

We keep records as required by the following legislation, where applicable. Access to these records is subject to the requirements of the relevant Act and of PAIA.

• 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
• Consumer Protection Act 68 of 2008
• Electronic Communications and Transactions Act 25 of 2002
• Employment Equity Act 55 of 1998, insofar as it applies to recruitment through Work Marketplace
• Basic Conditions of Employment Act 75 of 1997, Labour Relations Act 66 of 1995, Unemployment Insurance Act 63 of 2001, and Compensation for Occupational Injuries and Diseases Act 130 of 1993 (to the extent we have employees)

6. Subjects and categories of records

7. Processing of personal information

This section contains the information required by section 51(1)(c) of PAIA. More detail is available in the Privacy Policy of each product.

7.1 Purposes of processing

• Providing and supporting our products, and managing user accounts
• Billing and processing payments
• Storing and displaying feedback on behalf of Service Sense subscribers, as their operator
• Matching job seekers with employers on Work Marketplace, and providing CV services
• Verifying, appointing and paying agents and resellers
• Keeping financial, tax and statutory records
• Securing our platforms and preventing fraud and abuse
• Marketing our services, with consent or as permitted by section 69 of POPIA

7.2 Categories of data subjects and personal information

7.3 Recipients of personal information

• Service Sense subscribers, in respect of feedback collected through their QR codes
• Employers on Work Marketplace, in respect of job seeker profiles the job seeker makes available to them, and job seekers in respect of vacancies
• Agents and resellers, limited to the information needed to calculate their commission
• Service providers for hosting, databases, email delivery, domain and security services, and payment processing
• Our bank, for making payments
• Regulators, law enforcement and courts, where required by law

7.4 Transfers outside South Africa

Some of our databases and service providers are located outside South Africa, including in the European Union. We only transfer personal information outside South Africa as permitted by section 72 of POPIA.

7.5 Security measures

We protect personal information with encrypted connections (HTTPS), role-based access controls, verification of user accounts, restricted administrator access to identity and banking details, and reputable service providers with their own security controls. We will notify the Information Regulator and affected persons of security compromises as required by section 22 of POPIA.

8. How to request access

1. Complete Form 2: Request for Access to Record, prescribed by the PAIA Regulations, 2021. The form is available on the Information Regulator's website, or we can email it to you on request.
2. Send the completed form to the Information Officer at info@nexuslogic.co.za, or deliver it to 138 Merriman Street, George, 6529.
3. Give enough detail to identify the record and yourself, state which product it relates to (if any), state the form of access you want, give your contact details, and identify the right you want to exercise or protect and explain why the record is needed for it.
4. If you are requesting on behalf of someone else, provide proof of your authority to do so.
5. We will ask you to pay the request fee (see clause 9) before we process the request. We may need to verify your identity.
6. We will decide on your request within 30 days of receiving it and notify you of our decision, any access fee payable, and your rights if you disagree. We may extend this period once, by up to 30 days, in the circumstances allowed by section 57 of PAIA, and will tell you if we do.

If you only want to access or correct your own personal information, you may also contact the product concerned directly, as described in its Privacy Policy.

9. Fees

• Request fee: R140, payable before we process the request. No request fee is payable by a person requesting access to their own personal information.
• Access fee: payable before access is given, for reproducing, searching for and preparing the record, at the rates in Annexure B of the PAIA Regulations, 2021. If the search and preparation is likely to take more than the time allowed in the Regulations, we may ask for a deposit of up to one third of the access fee.
• If your request is refused, any deposit paid will be refunded.

10. Grounds for refusal

We may or must refuse access to a record on the grounds set out in Chapter 4 of Part 3 of PAIA (sections 62 to 70), including where access would:

• involve the unreasonable disclosure of personal information about another person;
• disclose trade secrets or confidential commercial, financial or technical information of Nexus Logic or a third party;
• breach a duty of confidence owed to a third party;
• endanger the safety of a person or the security of property or systems;
• disclose records privileged from production in legal proceedings; or
• disclose research information that could expose Nexus Logic or a third party to serious disadvantage.

We may also refuse a request that is manifestly frivolous or vexatious, or that would require a substantial and unreasonable diversion of resources.

11. Remedies

We do not have an internal appeal procedure. If you are not satisfied with our decision, including a refusal, the fees charged, an extension of time or the form of access, you may, within 180 days of being notified of the decision:

• lodge a complaint with the Information Regulator; or
• apply to a court with jurisdiction for appropriate relief, in terms of section 78 of PAIA.

12. Availability and updating of this manual

This manual is available at nexuslogic.co.za/paia, is linked from each of our product websites, and may be inspected at our address during normal business hours. A copy will be provided to the Information Regulator on request. We will review and update this manual regularly, and whenever we add or close a product, as required by section 51(2) of PAIA.