PAIA Manual

1. Particulars of the responsible party

This manual is published by eduSYMS, a private body (as defined in PAIA) that operates the eduSYMS platform — the unified operating system for African education and skills.

2. Section 10 guide on how to use the Act

The Information Regulator has produced a guide under section 10 of PAIA that explains how members of the public can use PAIA to request access to records held by public and private bodies. The guide is available, in each official South African language, at:

https://inforegulator.org.za

Anyone may inspect or copy the guide at the offices of the Regulator during normal business hours. eduSYMS will provide a copy on request, on payment of the reproduction fee set out in section 8.

3. Information Officer

The Information Officer of eduSYMS is responsible for receiving and processing requests under PAIA, and for ensuring that eduSYMS complies with the Protection of Personal Information Act, 4 of 2013 (POPIA).

The Information Officer may delegate routine handling of requests to a Deputy Information Officer; ultimate accountability remains with the named Information Officer.

4. Records held by eduSYMS

eduSYMS holds the following broad categories of records. Some are automatically available; others are available only on request and only to the extent permitted by PAIA.

• Customer records — institutional and individual customer accounts, contracts, billing, support tickets.
• Operational records — learner, staff, and parent data processed on behalf of institutional customers (under operator agreements; the institution remains the responsible party).
• Marketing records — leads, demo requests, brochure requests, academy enrolments captured through the public website.
• Employee records — staff personal information, payroll, performance, training.
• Compliance records — POPIA registers, breach logs, processing records, operator agreements.
• Statutory and tax records — required by South African company, tax, and labour law.
• Public records — published policies, public-facing content, marketing collateral.

5. Records automatically available

Under section 52 of PAIA, the following categories are made available without a request and without payment:

• This PAIA Manual.
• Privacy Policy, Terms of Service, Cookie Policy, Acceptable Use Policy.
• Marketing material on the eduSYMS website (product pages, audience pages, brochures, course outlines).
• Public press releases and announcements.
• Other content explicitly marked as publicly available on the website.

6. Records available on request

Records that are not automatically available may be requested under PAIA, subject to the grounds for refusal listed below. These include but are not limited to:

• Internal policies and procedures (employee handbook, security procedures, retention schedules).
• Contracts and operator agreements with institutional customers.
• Personal information held about the requester, where the requester is the data subject.
• Records held about an institution where the requester is duly authorised by that institution.
• Records that the requester needs to exercise or protect a right.

Requests are processed under PAIA's procedures. Where the records contain personal information of someone other than the requester, eduSYMS will consult the third party as required by PAIA before granting or refusing access.

7. How to request a record

1. Use the prescribed form. Requests must be made on Form C (request for access to a record of a private body), available from the Information Regulator at https://inforegulator.org.za.
2. Identify yourself. Provide enough information to identify yourself and (if relevant) the person on whose behalf you are requesting.
3. Identify the record. Describe the record clearly enough to allow it to be located. Vague requests may be returned for clarification.
4. State a ground. Where required by PAIA, indicate the right you wish to exercise or protect, and explain why the record is needed.
5. Choose a delivery method. Indicate how you would like to receive the record (electronic, posted copy, inspection at our office).
6. Submit the form. Email the completed form to [email protected] with the subject line "PAIA Request", or post it to the Information Officer at the address above.

eduSYMS will acknowledge a request within five business days and will respond on substantive grounds within 30 calendar days, in line with PAIA. The 30-day period may be extended once by a further 30 days where the request is voluminous or requires consultation with third parties.

8. Fees

PAIA prescribes two fees: a request fee (payable on submission of certain requests) and an access fee (covering reproduction, search, and preparation costs). The current fees are set by regulation and published by the Information Regulator.

• Personal requests: No request fee is payable when you request your own personal information. An access fee may apply if reproduction is involved.
• Non-personal requests: The current request fee is R50 (subject to change by regulation).
• Access fees: Charged per page or per electronic copy in line with the prescribed schedule. eduSYMS will provide a fee estimate before processing where the access fee is likely to exceed R200.
• Payment: By electronic transfer to the bank details supplied on the fee notice. Records will be released after payment is received.

9. Grounds for refusal

PAIA contains specific grounds on which eduSYMS may, or in some cases must, refuse access to a record. These include where granting access would:

• Unreasonably disclose personal information about a third party (section 63).
• Disclose commercial information of eduSYMS or a third party that could harm the commercial interests of that party (section 64).
• Breach a duty of confidence owed in terms of an agreement (section 65).
• Endanger life or physical safety, or compromise security (section 66).
• Prejudice ongoing legal proceedings or constitute privileged information (sections 67–68).
• Constitute commercially sensitive research (section 69).
• Where the request is manifestly frivolous or vexatious (section 70).

eduSYMS will provide reasons in writing where a request is refused, and will reference the specific section relied on.

10. Appeals & remedies

If you are dissatisfied with eduSYMS' response to a PAIA request, you may:

1. Lodge an internal review with the Information Officer in writing, setting out your grounds.
2. Lodge a complaint with the Information Regulator, who may investigate and issue a decision under PAIA and POPIA.
3. Apply to a competent court for an order under section 78 of PAIA.

The Information Regulator's contact details are published at https://inforegulator.org.za.

11. Availability and updates

This manual is published on the eduSYMS website at edusyms.com/paia-manual and is reviewed at least annually, and whenever a material change occurs. Hard copies are available on request from the Information Officer at the cost of reproduction.

The version date and version history are recorded at the foot of this page.

Version 1.0 · Published 9 May 2026 · Reviewed: 9 May 2026