PAIA Manual
PREPARED IN TERMS OF SECTION 51 OF THE PROMOTION OF ACCESS TO INFORMATION ACT 2 OF 2000
About This Manual
This is the manual of Academic Connect (Pty) Ltd, trading as Septa, prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 ("PAIA").
PAIA gives effect to the right of access to information in section 32 of the Constitution. Every private body must have a manual like this one, and must make it available. Its purpose is to tell you what records we hold, how to ask for one, what it may cost, and what you can do if we say no.
Septa is a tutoring marketplace and learning community used mainly by school learners and by university students who tutor. Many of the people whose information we hold are under 18. That shapes what we hold and how carefully we hand it over, and it is dealt with plainly below.
This manual should be read with our Privacy Policy and POPIA Notice, which explains how we handle personal information, and with our Terms of Use.
Who We Are and How to Reach Us
| Detail | Value |
|---|---|
| Legal entity | Academic Connect (Pty) Ltd, trading as Septa |
| Registration number | 2025/692608/07 |
| Head of the private body | Clinton Mgoduswa, Director |
| Information Officer | Clinton Mgoduswa |
| Deputy Information Officer | Luntu Sambela |
| Street address | 1 Inyanga Cl, Sunninghill, Sandton, Johannesburg, 2157, South Africa |
| Postal address | 1 Inyanga Cl, Sunninghill, Sandton, Johannesburg, 2157, South Africa |
| Telephone | +27 71 927 8051 / +27 64 651 3589 |
| Email for PAIA requests | hello@septa.co.za |
| Website | septa.co.za |
We do not operate a facsimile line.
A request may be sent to the email address above or delivered to the street address. It reaches the Information Officer either way.
The Guide on How to Use PAIA
The Information Regulator has published a guide on how to use PAIA, as section 10 of the Act requires. It explains the right of access, how to make a request to a public or a private body, what a body may refuse and why, and what you can do about a refusal.
The guide is available free of charge from the Information Regulator. You can obtain it from the Regulator's website, or by writing to the Regulator at the address given under If We Refuse, or Do Not Answer. It is published in the official languages, and the Regulator will supply it in braille on request.
If you would rather ask us, write to hello@septa.co.za and we will tell you where to get a copy. We cannot amend the guide or answer for it, but we can point you at it.
Records Available Without a Request
No notice has been published in terms of section 52(2) of PAIA listing categories of our records that are automatically available. If that changes we will say so here.
Separately, and without any request at all, the following are published on septa.co.za and free to read, download and keep:
- our Terms of Use and our Privacy Policy and POPIA Notice;
- this manual;
- the bursary listings, including closing dates, requirements and application links;
- the university, college and course information, including admission requirements;
- the APS calculator and how it works.
None of that needs a PAIA request. If what you want is on the site, take it.
Records We Hold Under Other Legislation
Some of our records are kept because another law requires it. Those laws do not by themselves give anybody a right to see the records, but they explain why the records exist and how long we keep them.
- Companies Act 71 of 2008: incorporation documents, the register of directors, share records, annual returns and financial records.
- Income Tax Act 58 of 1962 and the Tax Administration Act 28 of 2011: tax registration and returns, and the records supporting them.
- Protection of Personal Information Act 4 of 2013: records of consent, of requests made to us, and of any security compromise.
- Electronic Communications and Transactions Act 25 of 2002: records of electronic transactions and of take-down notifications.
- Consumer Protection Act 68 of 2008: records relating to agreements, cancellations and refunds.
Academic Connect has no employees. Employment legislation, including the Basic Conditions of Employment Act, the Labour Relations Act, the Employment Equity Act and the Compensation for Occupational Injuries and Diseases Act, therefore does not apply to us and we hold no records under it. If we employ anyone this manual will be updated before we do.
The Records We Hold
These are the subjects on which we hold records, and the categories of record under each. Listing them here does not mean they are available on request. It means you know they exist, which is what PAIA asks of us.
| Subject | Categories of record |
|---|---|
| Company and statutory | Incorporation and registration documents, director records, financial and tax records, and contracts with service providers. |
| Learner accounts | Name, username, email address, telephone number, school or institution, grade or year, profile photograph and profile content, the answer to whether the account holder is 18 or older, and where they are not, the parent or guardian details and the record of the consent given. |
| Tutor accounts | Profile and subjects, verification documents supplied as proof of qualification or identity, banking details for payouts (stored encrypted), and where a tutor is under 18, their parent or guardian email address and the record of that permission. |
| Parents and guardians | Name, contact details, relationship to the learner, the consent records they gave, and a record of which tutors they agreed to where both learner and tutor are under 18. |
| Sessions and bookings | Booking details, session times and subjects, and video session data. |
| Payments and payouts | Where a payment is taken or a tutor is paid: billing name, payment reference and amount, and payout records. We do not receive or store full card numbers. |
| Content | What users post and add to their profiles, and the bursary, university and course information we publish. |
| Communications | Messages sent between users through the Service, emails we send about accounts, sessions and consent, and correspondence with support. |
| Safety and moderation | Reports about users, content or sessions, take-down notifications, and the decisions we take on them. |
| Technical | Usage records, IP address, device and browser details, log-in times, error reports, and security logs. |
Most of these contain the personal information of somebody other than the person asking, and often of a child. That matters for what we can release, and is dealt with under When We May Refuse.
Personal Information We Process
Our Privacy Policy and POPIA Notice sets this out in full: what we collect, why, on what legal ground, who processes it on our behalf, where it goes, how long we keep it and what rights you have over it. It is published at septa.co.za/privacy and forms part of the picture this manual describes.
In summary, the people whose personal information we hold are learners, parents and guardians who give consent for a learner, tutors, and people who write to us. The operators who process it on our behalf are named in Schedule A of that notice.
If what you want is your own personal information, or your child's, the quicker route is usually a request under section 23 of POPIA rather than PAIA. We do not charge for that, your settings page can produce an immediate export of your own data, and the Privacy Policy explains how to ask. PAIA and POPIA are different statutes with different procedures and different fees, and we will not push you from one to the other to avoid answering.
How to Ask for a Record
Use Form 2 of the PAIA Regulations, the form headed Request for Access to Record. It is the prescribed form and we are required to ask for it. You can get it from the Information Regulator's website, or write to hello@septa.co.za and we will send it to you.
Send the completed form to hello@septa.co.za, or deliver it to the street address above, marked for the attention of the Information Officer.
The form asks you to:
- identify yourself, and attach proof of identity;
- say whether you are asking in your own name or on behalf of somebody else, and if on behalf of somebody else, attach proof that you are authorised;
- describe the record you want, with enough detail for us to find it;
- say what form you want it in and how you want it sent to you;
- give an address, and a telephone number or email address, where we can reach you; and
- state the right you are seeking to exercise or protect, and explain how the record will help you do that.
That last one is not a formality, and it is where most requests to a private body fail. Section 50 of PAIA gives you a right to a record of a private body only where the record is required for the exercise or protection of a right. A general interest, or a belief that you are entitled to it, is not enough. Tell us which right, and how the record helps. If we think you have not shown it we will say so and give you a chance to explain before we refuse.
We will decide within 30 days of receiving your request, as section 56 requires. If the request is for a large number of records, or if we have to consult somebody else, we may extend that, and we will tell you why and by how long before the 30 days are up.
Where a record contains somebody else's personal information we may have to tell that person and give them a chance to object. That takes time, and we will tell you it is happening.
Fees
PAIA prescribes two kinds of fee for a private body. A request fee, payable before we start work, and an access fee for the reproduction, search and preparation of the record. The amounts are prescribed by regulation and change from time to time, so we do not print them here where they would go stale.
What we commit to instead: we will tell you in writing what the fee is before we do any work, and we will not begin until you have decided whether to go ahead. Where searching for and preparing a record will take longer than the prescribed hours we may ask for a deposit, and the notice will say how much and why.
If we refuse your request after you have paid a deposit, we refund it.
Requests under section 23 of POPIA for your own personal information are free, as our Privacy Policy says. That is a different route under a different Act, and the fees on this page do not apply to it.
When We May Refuse
PAIA sets out the grounds on which a private body must or may refuse access, in Chapter 4 of Part 3 of the Act. We do not have a discretion to hand over a record the Act requires us to protect. The grounds most likely to apply to us are:
- the personal information of somebody other than you, where disclosing it would be unreasonable. On Septa that is usually a learner, and often a child, so this is the ground we expect to rely on most;
- commercial information belonging to a third party, such as a tutor or a supplier;
- information given to us in confidence, where releasing it could harm the person who gave it;
- information that could endanger the life or physical safety of a person. On a service used by children we take this seriously, and we will not release a record that puts a child at risk;
- records privileged in legal proceedings; and
- our own commercial information, where release would harm us commercially.
Section 70 of the Act requires disclosure in some cases anyway, where the record would reveal a substantial contravention of the law or an imminent and serious risk to public safety or the environment, and the public interest in disclosure clearly outweighs the harm. We will apply that provision honestly rather than hide behind a ground of refusal.
If we refuse, we will tell you in writing which ground we relied on, in enough detail for you to understand the decision, and what you can do about it.
If We Refuse, or Do Not Answer
PAIA does not provide an internal appeal against a decision of a private body, so there is nobody further up inside Septa to appeal to. You have two routes, and you may use either.
You may lodge a complaint with the Information Regulator, in terms of section 77A of PAIA. The Regulator can investigate and may issue an enforcement notice. Complaints can be lodged through the Regulator's online portal.
| Information Regulator (South Africa) | |
|---|---|
| Physical address | Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg |
| Postal address | P.O. Box 31533, Braamfontein, Johannesburg, 2017 |
| Telephone | 010 023 5200, or toll free 0800 017 160 |
| enquiries@inforegulator.org.za | |
| Online complaints | eservices.inforegulator.org.za |
Or you may apply to a court for appropriate relief in terms of section 78 of PAIA.
Tell us first if you would rather. We are a small company, a misunderstanding is more likely than a refusal in bad faith, and we would rather fix it than have you go to the expense of a court.
Records That Cannot Be Found or Do Not Exist
If we cannot find a record you have asked for, or it does not exist, you are entitled to be told so in an affidavit or affirmation, and we will provide one. It will set out the steps we took to find the record.
We will not tell you a record does not exist in order to avoid answering. If a record exists and we are refusing it, we will say that instead and give the ground.
How Long We Keep Records
Our Privacy Policy sets out the retention periods that apply to personal information. In short, we keep an account and the records attached to it while the account is active, delete an account that has not been used for 36 months, and keep some records longer where a law or the protection of a child requires it. Financial records are kept for 5 years, as the tax legislation requires, with personal identifiers removed when an account is deleted. That is why closing an account does not delete every trace of a payment.
Where we have lawfully disposed of a record before your request arrives, we will tell you that it has been disposed of rather than leave you waiting.
Availability of This Manual
This manual is available:
- on our website at septa.co.za/paia, free of charge, at any time;
- at 1 Inyanga Cl, Sunninghill, Sandton, Johannesburg, during normal business hours, on request;
- by email, on request to hello@septa.co.za; and
- to the Information Regulator on request.
We do not charge for a copy sent by email. A printed copy collected in person is free as well, because charging a person for the document that tells them how to exercise a right would be a strange way to begin.
Updating This Manual
The Information Officer reviews this manual at least once a year, and updates it sooner where something material changes: a change of address or Information Officer, the appointment of a payment provider, the employment of staff, or a change in the records we hold.
The version and date at the top of this manual tell you which version you are reading.
In Plain Language
If you want to see something we hold about you or your child, the fastest route is your settings page, which can produce an immediate copy of your own data, or an email to hello@septa.co.za. That is free, and it is usually what people actually want.
PAIA is the formal route, and it is mostly used to ask for records about somebody or something else. If you use it, you have to tell us which right you are trying to exercise or protect and how the record helps, because the law only gives access to a private company's records on that basis.
We will not make this harder than it needs to be. If your request is unclear we will ask rather than refuse, and if you are asking for the wrong thing we will tell you what the right thing is.