PAIA Section 51 Manual

This manual is published in terms of Section 51 of the Promotion of Access to Information Act, 2000 (Act 2 of 2000) ("PAIA"), as amended, read together with the Protection of Personal Information Act, 2013 (Act 4 of 2013) ("POPIA").

The purpose of this manual is to inform the public of the records held by Tapnet Solutions (Pty) Ltd (trading as TradeJournal) and to explain the procedure to follow when requesting access to such records.

This policy applies to tradejournal.co.za and all other websites, applications, and digital services operated by Tapnet Solutions (Pty) Ltd.

The Information Officer of Tapnet Solutions (Pty) Ltd is responsible for encouraging compliance with the conditions for lawful processing of personal information and for dealing with requests made in terms of PAIA.

The Information Officer is registered with the Information Regulator in accordance with Section 55 of POPIA.

The Information Regulator has compiled a guide in terms of Section 10 of PAIA to assist members of the public who wish to exercise any right contemplated in the Act.

The guide is available from the Information Regulator at the contact details provided in Section 11 below, or on their website: https://inforegulator.org.za

The following categories of records are freely available on the TradeJournal website and may be accessed without submitting a formal PAIA request:

• Public website content (pages, marketing materials, legal policies)
• Published pricing and subscription plan details
• Educational articles and trading-related guides
• Public tools available on the platform

Tapnet Solutions (Pty) Ltd holds records in the following categories. Please note that the inclusion of a category does not mean that access will automatically be granted; each request is assessed on its merits in accordance with PAIA.

Records may be available in terms of the following legislation, to the extent that it applies to Tapnet Solutions (Pty) Ltd:

• Companies Act 71 of 2008
• Income Tax Act 58 of 1962
• Value-Added Tax Act 89 of 1991
• Electronic Communications and Transactions Act 25 of 2002
• Protection of Personal Information Act 4 of 2013 (POPIA)
• Consumer Protection Act 68 of 2008

To request access to records held by Tapnet Solutions (Pty) Ltd, you must complete the prescribed Form C (as set out in Annexure B of the PAIA Regulations) and submit it to the Information Officer.

Your request must include:

• Your full name and contact details
• A clear description of the records you wish to access
• The form of access required (e.g. copy, inspection)
• Proof of identity (certified copy of ID document)

Upon receipt of a valid request, the Information Officer will process it as follows:

• Acknowledgement: You will receive an acknowledgement of your request within 14 days of receipt.
• Decision: A decision on your request will be made within 30 days of receipt. This period may be extended by a further 30 days if the request requires a search through a large volume of records, or consultation with a third party is necessary.
• Notification: You will be notified in writing of the decision. If the request is refused, reasons for the refusal will be provided.

Access to records may be refused on the grounds set out in Chapter 4 of Part 3 of PAIA, including but not limited to:

• Mandatory protection of the privacy of a third party who is a natural person
• Protection of commercial information of a third party or the company
• Records that are privileged from production in legal proceedings
• Mandatory protection of the safety of individuals
• Records that would prejudice or impair law enforcement or legal proceedings

If you are dissatisfied with the decision of the Information Officer regarding your request for access, you may pursue the following remedies:

• Internal appeal: Lodge an internal appeal with Tapnet Solutions (Pty) Ltd within 60 days of receiving the decision.
• Complaint to the Information Regulator: Lodge a complaint with the Information Regulator (see contact details in Section 11 below).
• Application to court: Apply to a court of competent jurisdiction for appropriate relief.

The Information Regulator is an independent body established in terms of POPIA to, among other things, monitor compliance with PAIA and POPIA.

This manual is available:

• On the TradeJournal website at tradejournal.co.za/paia
• For inspection in person at the company's registered address during normal business hours: 594 Bombani Street, Elarduspark, Gauteng, 0181, South Africa

A copy of this manual is also available for inspection at the offices of the Information Regulator.