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PAIA

PAIA manual

This manual is published under section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA). It explains what records we hold and how you can ask for access to them.

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About us

Silver Horizon Digital is a software development studio based in South Africa, operating as a sole proprietorship. It is a private body under PAIA.

Contact details

Requests under PAIA and POPIA go to our Information Officer, by email at [email protected].

The Information Regulator’s PAIA Guide

The Information Regulator has published a guide on how to use PAIA and POPIA to request access to information, as section 10 of PAIA requires. It is available in all official languages on the Regulator’s website, inforegulator.org.za. We will also give you a copy free of charge on request.

Records available without a request

The following are freely available on this website without a formal request: our privacy notice, this manual and information about our services.

Records available under other legislation

Depending on our activities, records may be kept or made available under other laws, including, where applicable:

  • the Income Tax Act 58 of 1962 and the Tax Administration Act 28 of 2011;
  • the Value-Added Tax Act 89 of 1991, if we are registered for VAT;
  • the Basic Conditions of Employment Act 75 of 1997, if we employ staff;
  • the Protection of Personal Information Act 4 of 2013.

Subjects and categories of records we hold

  • Client and enquiry records: enquiry emails, correspondence, scopes, quotes and agreements.
  • Project records: specifications, source code, designs and delivery records for work we do.
  • Financial records: invoices, payment records and tax records.
  • Supplier records: agreements and correspondence with service providers.
  • Website records: aggregate, cookieless website statistics and hosting logs.

How to request access

Email a completed request form (Form 2 under the PAIA Regulations, available from the Information Regulator’s website) to our Information Officer at [email protected]. Give enough detail to identify the records and the form of access you want, and, where you need the record to protect or exercise a right, state that right.

We may need to confirm your identity. Unless you are asking for your own personal information, a request fee of R140 is payable before we process your request (PAIA Regulations, 2021, Annexure B). If we grant access, access fees (for example R2 per printed page and time spent searching and preparing records) may also apply; we will tell you the amount in writing before you pay. We will decide within 30 days of receiving your request. We may extend this once, by up to 30 days, only on the grounds in section 57 of PAIA, and if we do we will tell you within the first 30 days, with reasons. Access may be refused only on the grounds PAIA sets out. If you disagree with our decision, you may lodge a complaint with the Information Regulator or apply to a court.

Processing of personal information (POPIA)

Purposes: to respond to enquiries, prepare quotes, deliver and support work for clients, keep business records, meet legal obligations and understand, in aggregate, how our website is used.

Categories of data subjects and information: prospective and existing clients and their contact people (names, email addresses, organisation names and the content of messages); suppliers (contact and payment details); and website visitors (technical information such as IP address and browser type, processed by our host).

Recipients: service providers that help us run the business, namely Google Workspace (email) and Cloudflare (website hosting and analytics), and authorities where the law requires.

Planned transborder flows: Google and Cloudflare operate data centres around the world, so personal information may be stored or processed outside South Africa, including in the United States and Europe, under their data processing terms and as section 72 of POPIA allows.

Security measures: two-step verification on our key business accounts, access limited to people who need it and encrypted (HTTPS/TLS) connections for our website and email.

Availability of this manual

This manual is available on this website and, on request, by email from our Information Officer at [email protected]. We review it regularly and update it when our records or data handling change.