PAIA Manual
This manual is published in terms of Section 51 of the Promotion of Access to Information Act, 2 of 2000 (PAIA). It describes the records held by Sinneo Financial Technologies (Pty) Ltd, operating the Sorae platform, and explains how any person may request access to those records.
Company Details
The following details identify the private body responsible for this manual and to whom all PAIA-related correspondence should be addressed.
| Field | Detail |
|---|---|
| Legal entity name | Sinneo Financial Technologies (Pty) Ltd |
| Trading name / Platform | Sorae |
| Parent group | Sinneo Group |
| Company registration no. | [Registration number — to be inserted] |
| Physical address | [Street address, City, Province, Postal code] |
| Postal address | [PO Box / PostNet Suite, City, Postal code] |
| Telephone | [+27 XX XXX XXXX] |
| General email | hello@sorae.co.za |
| Website | https://sorae.co.za |
Information Officer
In terms of section 1 of PAIA, as amended by POPIA, the head of a private body is deemed to be the Information Officer. The Information Officer may delegate responsibilities to a Deputy Information Officer in terms of section 17 of POPIA.
Designated Information Officer
| Field | Detail |
|---|---|
| Full name | [Full name of Information Officer] |
| Designation / Title | [e.g., Chief Executive Officer] |
| Email address | paia@sorae.co.za |
| Telephone | [+27 XX XXX XXXX] |
| Postal address | [Same as company postal address above] |
Responsibilities of the Information Officer
The Information Officer is responsible for encouraging compliance with PAIA within the company, dealing with requests for access to records, working with the Information Regulator in relation to investigations, and ensuring that the company's PAIA Manual is updated and available as required by law.
Guide to Records Held
Sinneo Financial Technologies (Pty) Ltd holds records across several categories. The tables below describe each category, the purpose for which those records are maintained, and the legal basis for retention.
3.1 Corporate & Statutory Records
| Record type | Description | Retention basis |
|---|---|---|
| Memorandum of Incorporation | Constitutional documents of the company | Companies Act 71 of 2008 |
| Share register | Register of shareholders and issued shares | Companies Act 71 of 2008 |
| Minutes & resolutions | Board and shareholder meeting records | Companies Act 71 of 2008 |
| Annual financial statements | Audited / reviewed financials | Companies Act; SARS requirements |
| CIPC filings | Annual returns, director changes, registered address | Companies Act 71 of 2008 |
3.2 Employee & HR Records
| Record type | Description | Retention basis |
|---|---|---|
| Employment contracts | Signed agreements with all employees | Basic Conditions of Employment Act |
| Payroll records | Salary, tax, and UIF information | SARS; POPIA |
| Leave records | Annual, sick, and family responsibility leave | Basic Conditions of Employment Act |
| Performance records | Reviews, PIPs, and appraisals | Internal policy |
| Disciplinary records | Warnings, hearings, and outcomes | Labour Relations Act 66 of 1995 |
3.3 Financial & Tax Records
| Record type | Description | Retention basis |
|---|---|---|
| VAT returns & records | Input/output VAT schedules | Value-Added Tax Act 89 of 1991 |
| Income tax records | Provisional and annual tax returns | Income Tax Act 58 of 1962 |
| Invoice & billing records | Client invoices and payment records | SARS; POPIA |
| Banking records | Bank statements and transaction records | Internal policy; SARS |
| Client contracts | API subscription and SLA agreements | Internal policy |
3.4 Operational & Technical Records
| Record type | Description | Retention basis |
|---|---|---|
| API usage logs | Metadata logs of API calls (no statement content) | Internal policy; POPIA |
| Account & authentication records | Client account credentials, API keys (hashed) | POPIA; security policy |
| Support correspondence | Emails and tickets from clients or users | POPIA; internal policy |
| System audit logs | Security and access audit trails | Information security policy |
| Agreements with data processors | DPAs and vendor contracts | POPIA; internal policy |
How to Request Access
Any person wishing to request access to a record held by Sinneo Financial Technologies (Pty) Ltd must follow the procedure set out below. Requests must comply with section 53 of PAIA.
4.1 Prescribed Form
Requests for access to records must be made using Form C as prescribed by the South African Human Rights Commission (SAHRC) in terms of section 53(1) of PAIA. Form C is available from the SAHRC website at www.sahrc.org.za and may also be requested directly from our Information Officer.
4.2 Contents of the Request
In terms of section 53(2) of PAIA, a request must include the following:
- Full name, address, and contact details of the requester
- If the requester is acting on behalf of another person, the capacity in which the requester is acting and the name and contact details of the person on whose behalf the request is made
- A description of the record or records to which access is sought, sufficient to enable the Information Officer to identify the record
- The form of access required (e.g., paper copy, electronic copy, inspection in person)
- The right the requester wishes to exercise or protect and an explanation of why the record is required for that purpose
- Confirmation that the requester is not subject to a prohibition under section 54 of PAIA
- If applicable, proof of identity of the requester
4.3 Where to Submit the Request
Completed requests must be submitted to the Information Officer by one of the following methods:
| Method | Address / Contact |
|---|---|
| Email (preferred) | paia@sorae.co.za |
| Post | [Postal address of the company, as listed in Section 1] |
| Hand delivery | [Physical address of the company, as listed in Section 1] |
4.4 Request Fee
A requester who seeks access to a record containing personal information about themselves is not required to pay a request fee. All other requesters must pay a request fee of R50.00 (or such other amount as prescribed by regulation from time to time) before the request will be processed. The Information Officer will notify the requester of the applicable fee and provide payment details.
Timelines & Fees
The timelines and fees set out below are prescribed by PAIA and the regulations made thereunder. Sinneo Financial Technologies (Pty) Ltd is obligated to adhere to these timelines unless a specific ground for extension applies.
5.1 Response Timelines
| Event | Timeline |
|---|---|
| Decision on request | Within 30 days of receiving the request (s.56(1)) |
| Extension where third-party notification required | Up to 30 additional days (s.57(1)) |
| Extension where request is large or complex | Up to 30 additional days (s.57(2)) |
| Notification of decision to requester | Immediately upon decision (s.56(3)) |
| Deemed refusal if no decision communicated | After 30-day period lapses (s.58) |
5.2 Fee Schedule
Access fees are those prescribed under the PAIA Regulations (as published in Government Notice R187 of 2002 and subsequently amended). The current fee schedule is summarised below. All fees are inclusive of VAT.
| Fee type | Amount |
|---|---|
| Request fee (non-personal records) | R50.00 |
| Reproduction — photocopy per A4 page | R1.10 per page |
| Reproduction — printed A4 page | R0.75 per page |
| Reproduction — electronic (CD/USB) | R70.00 per disc / drive |
| Transcription of visual image per A4 page | R40.00 |
| Search and preparation (per hour after first hour) | R30.00 per hour |
| Inspection of records (per hour) | R30.00 per hour |
| Personal information — own records | No fee payable |
Grounds for Refusal
The Information Officer may refuse a request for access to a record on one or more of the grounds set out in Chapter 4 of PAIA (sections 63–70). Where access is refused, the requester will be notified in writing with reasons.
Grounds on which access may be refused include, among others:
- The record contains personal information about a third party who has not consented to disclosure, and disclosure would constitute an unjustifiable infringement of that persons privacy(s.63)
- Disclosure would reveal a commercial secret or confidential business information that could harm the competitive position of the company or a third party (s.64)
- The record is protected by legal professional privilege (s.65)
- The information is protected by statutory confidentiality obligations (s.66)
- Disclosure would endanger the life, physical safety, or freedom of an individual (s.67)
- Disclosure could reasonably be expected to prejudice the defence, security, or international relations of the Republic (s.68)
- The record does not exist or cannot be found after all reasonable steps have been taken (s.55(3))
The Information Officer must disclose any severable portion of a record that does not itself fall within a ground for refusal, even if other portions are withheld (s.28).
Internal Appeal
In terms of section 74 of PAIA, a requester who is aggrieved by a decision of a private body's Information Officer may apply to a court for relief. There is no internal appeal mechanism applicable to private bodies under PAIA.
A requester who has been refused access, or who is dissatisfied with the information provided, may approach the Information Regulator for assistance or may institute proceedings in a court with jurisdiction. The requester must do so within 30 days of being notified of the decision (s.78).
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
PO Box 31533, Braamfontein, 2017
Email: inforeg@justice.gov.za · Web: www.inforegulator.org.za
POPIA & Privacy Policy
Sinneo Financial Technologies (Pty) Ltd processes personal information in its capacity as a responsible party under the Protection of Personal Information Act, 4 of 2013 (POPIA). The company is committed to processing personal information lawfully, in a manner that does not infringe on the privacy of data subjects.
8.1 Relationship Between PAIA and POPIA
PAIA and POPIA are complementary statutes. PAIA grants rights of access to information, while POPIA governs the conditions under which personal information may be collected, processed, and retained. Where a PAIA request concerns personal information of a third party, POPIA conditions will be applied to determine whether disclosure is permissible.
8.2 Rights of Data Subjects
Under POPIA, data subjects have the right to be notified of the collection of their personal information, to request access to their personal information, to request the correction or deletion of their personal information, to object to the processing of their personal information, and to lodge a complaint with the Information Regulator. These rights may be exercised by contacting the Information Officer at paia@sorae.co.za.
8.3 Privacy Policy
The company's full Privacy Policy, which sets out in detail how personal information is collected, used, shared, and protected in the context of the Sorae platform, is published at sorae.co.za/privacy. The Privacy Policy should be read alongside this PAIA Manual.
Availability of Manual
In terms of section 51(3) of PAIA, this manual must be made available in the prescribed manner. Sinneo Financial Technologies (Pty) Ltd makes this manual available as follows:
- Published on the company website at sorae.co.za/paia, free of charge
- Available in printed form upon written request to the Information Officer — a reproduction fee of R0.75 per A4 page applies
- Submitted to the South African Human Rights Commission (SAHRC) in terms of s.51(3)
- Updated as required whenever there are material changes to the records held or the applicable legal framework
A copy of this manual will also be made available at the company's registered physical address during normal business hours, upon reasonable request to the Information Officer.