1. About this manual
This is the manual of Rusbee Labs (Pty) Ltd, a private company registered in South Africa (registration number 2026/766953/07), the private body that operates Aukly. In this manual "we", "us" and "our" mean Rusbee Labs (Pty) Ltd.
PAIA gives everyone the right to ask a private body for access to a record it holds when the record is needed to exercise or protect a right, subject to the grounds for refusal in PAIA. If you only want to know what personal information we hold about you, or to correct or delete it, you can simply email our Information Officer as our Privacy Policy explains. You don't need a formal PAIA request for that.
2. Who to contact
Requests under this manual go to our Information Officer, who is also the head of the company:
- Information Officer
- Boyd Dolamo (Director and Information Officer)
- Deputy Information Officer
- Andrew Kgapola
- privacy@aukly.co.za
- Telephone
- 076 104 8818
- Address
- Available on request by email
- Website
- https://aukly.co.za
3. The Information Regulator's guide to PAIA
The Information Regulator has published a guide on how to use PAIA and POPIA to request information (section 10 of PAIA). It is available in each of the official languages on the Regulator's website, https://inforegulator.org.za, or from the Regulator:
- Address
- Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191
- enquiries@inforegulator.org.za
- Telephone
- 010 023 5200
You can also ask us by email for a copy of the guide.
4. Records available without a request
We have not published a notice under section 52(2) of PAIA. The following records are freely available on our website, without a request and without charge:
- our Privacy Policy, Terms of Service and Refund Policy;
- our Data & Security page; and
- this manual.
Customers can also see and export their own account information, documents and books at any time inside Aukly.
5. Records kept under other laws
We keep records as required by the following laws, where they apply to us. Some of these records are available only to the people or authorities named in those laws.
- Companies Act 71 of 2008
- Income Tax Act 58 of 1962
- Tax Administration Act 28 of 2011
- Value-Added Tax Act 89 of 1991 (if we are registered for VAT)
- Consumer Protection Act 68 of 2008
- Electronic Communications and Transactions Act 25 of 2002
- Protection of Personal Information Act 4 of 2013
- Promotion of Access to Information Act 2 of 2000
- Basic Conditions of Employment Act 75 of 1997, Labour Relations Act 66 of 1995, Unemployment Insurance Act 63 of 2001 and Compensation for Occupational Injuries and Diseases Act 130 of 1993 (if and when we employ staff)
6. Records we hold
These are the subjects and categories of records we hold. Listing a category doesn't mean a request for it will be granted.
| Subject | Categories of records |
|---|---|
| Company records | Registration documents, Memorandum of Incorporation, director and shareholder records, resolutions and statutory returns. |
| Financial and tax records | Accounting records, bank statements, invoices, payment records, financial statements and tax returns. |
| Customers | Aukly account, billing and support records, and the documents and books customers keep in Aukly, as described in our Privacy Policy. Agreements and correspondence with clients of our software services. |
| Suppliers and service providers | Agreements, data-processing terms, invoices and correspondence. |
| Information technology and security | Source code and technical documentation, system and security records, back-office audit records and security policies. |
| Staff (if any) | Employment contracts, payroll and tax records, and leave records. |
7. Processing of personal information
Section 51(1)(c) of PAIA, as amended by POPIA, requires this summary. Our Privacy Policy gives the full detail.
| Item | Summary |
|---|---|
| Purposes | Providing Aukly and our software services; billing; support; keeping our systems secure; meeting legal, tax and accounting obligations. |
| Categories of people | Customers and website visitors; people whose details appear in documents customers upload; clients; suppliers and service providers and their contact people; staff (if any). |
| Categories of information | Names and contact details; account and sign-in records; billing and payment references (never card numbers); uploaded financial documents and the transactions read from them; support messages; connection data kept by our hosting providers; supplier and client contract details. |
| Recipients | The service providers listed in our Privacy Policy (payments, hosting, database, file storage, document reading, AI categorisation and email), professional advisers, and authorities where the law requires it. |
| Transfers outside South Africa | To our providers in the countries listed in our Privacy Policy, under written data-processing terms and because the transfers are needed to provide the service (POPIA section 72(1)(a) and (c)). |
| Security measures | Encryption in transit and at rest, separation of each customer's data, hashed passwords, two-step verification and audit logging for back-office access, file checks on upload, monitoring and alerts. See our Data & Security page. |
8. How to request a record
- Use the prescribed form. Complete Form 2 ("Request for access to record") of the PAIA Regulations, 2021. It is on the Information Regulator's website, or we can send it to you.
- Send it to our Information Officer by email to privacy@aukly.co.za.
- Give enough detail for us to identify the record and you, say how you want access (a copy, an electronic copy or an inspection), and give the right you want to exercise or protect and why the record is needed for it.
- Include proof of identity, and if you ask on behalf of someone else, proof of your authority to do so.
- Pay the request fee if it applies (see section 10). We will tell you if a fee is payable before we process the request.
We will decide within 30 days of receiving a complete request and tell you the decision in writing. We may extend that by up to 30 more days in the cases PAIA allows (section 57), and we will tell you before the first period ends. If a record contains information about a third party, we must first give that person a chance to respond, as sections 71 to 73 of PAIA require. If we don't reply within the time allowed, the request is regarded as refused.
9. Grounds for refusal
We may or must refuse access only on the grounds in Chapter 4 of Part 3 of PAIA, which include protecting:
- the privacy of a third party who is a natural person (section 63);
- a third party's commercial information (section 64);
- confidential information of a third party (section 65);
- the safety of people and property (section 66);
- records privileged from production in legal proceedings (section 67);
- our own commercial information, such as trade secrets and information whose disclosure would harm us (section 68); and
- research information (section 69).
We must still grant access where section 70 of PAIA (the public interest override) applies. Where only part of a record can be refused, we will give access to the rest.
10. Fees
These are the fees prescribed for private bodies in Annexure B of the PAIA Regulations, 2021. We don't charge more. If you ask only for records containing your own personal information, you don't pay the request fee, but the access fees may still apply.
| Item | Fee |
|---|---|
| Request fee (not payable by a personal requester) | R140.00 |
| Photocopy or printed copy, per A4 page or part of a page | R2.00 |
| Electronic copy on a flash drive you provide | R40.00 |
| Electronic copy on a compact disc you provide | R40.00 |
| Electronic copy on a compact disc we provide | R60.00 |
| Transcription of an audio record, per A4 page | R24.00 |
| Search for and preparation of the record, for each hour or part of an hour after the first hour | R145.00, up to R435.00 in total |
| Postage, email or other electronic transfer | Actual cost, if any |
If the search will take more than six hours, we may ask for a deposit of one third of the access fee before we start. If access is refused, any deposit is repaid. We will tell you the fee in writing before charging it.
11. If you disagree with a decision
There is no internal appeal against a decision of a private body. If you are unhappy with our decision on your request, our fee or an extension, you may lodge a complaint with the Information Regulator (South Africa) within 180 days of the decision (PAIA, Part 4, Chapter 1A), at POPIAComplaints@inforegulator.org.za or Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191. After that process, you may apply to court as PAIA provides.
12. Where to find this manual
This manual is published at https://aukly.co.za/paia-manual. You can also ask for a free copy by email. We update it when our details or the law change; the date at the top shows the latest version.