PAIA MANUAL

SOMS DIGITAL (PTY) LTD

Prepared in terms of Section 51 of the Promotion of Access to Information Act 2 of 2000 (as amended)

LIST OF ACRONYMS AND ABBREVIATIONS

2. PURPOSE OF THIS PAIA MANUAL

This PAIA Manual has been compiled in accordance with Section 51 of the Promotion of Access to Information Act No. 2 of 2000 (as amended). It is useful to members of the public to:

• Understand the categories of records held by SOMS Digital that are available without a formal PAIA request;
• Understand how to make a formal request for access to a record held by SOMS Digital, including a description of the subjects on which records are held and the categories of records on each subject;
• Identify the categories of records available in terms of other applicable legislation;
• Obtain the relevant contact details of the Information Officer who will assist the public with records they wish to access;
• Access the guide on how to use PAIA, as updated by the Regulator, and how to obtain access to it;
• Understand how SOMS Digital processes personal information, including the purpose of processing, categories of data subjects, and applicable security measures (in terms of POPIA).

KEY CONTACT DETAILS

Information Officer

Deputy Information Officer

No Deputy Information Officer has been designated at this time. All requests should be directed to the Information Officer above.

General / Head Office Contact

GUIDE ON HOW TO USE PAIA

The Information Regulator has, in terms of Section 10(1) of PAIA (as amended), updated and made available a Guide on how to use PAIA (“the Guide”) in an easily comprehensible form and manner, as may reasonably be required by a person who wishes to exercise any right contemplated in PAIA and POPIA.

The Guide is available in each of the official languages and in Braille.

The Guide contains descriptions of:

• The objects of PAIA and POPIA;
• The contact details of the Information Officers of public and private bodies;
• The manner and form of requests for access to records;
• Assistance available from the Information Regulator;
• All remedies available regarding any act or failure to act in respect of rights or duties under PAIA and POPIA.

The Guide can be obtained:

• From the website of the Information Regulator: https://inforegulator.org.za
• Upon request to the Information Officer of SOMS Digital
• At the offices of the Information Regulator during normal working hours

The Information Regulator’s contact details are:

RECORDS AVAILABLE WITHOUT A FORMAL PAIA REQUEST

In terms of Section 52(1) of PAIA, the following categories of records are available to members of the public without a person having to submit a formal PAIA request:

RECORDS AVAILABLE IN TERMS OF OTHER LEGISLATION

The following categories of records are created and maintained by SOMS Digital in accordance with applicable South African legislation:

DESCRIPTION OF RECORDS HELD BY SOMS DIGITAL

The following table describes the subjects on which SOMS Digital holds records, and the categories of records held on each subject:

PROCESSING OF PERSONAL INFORMATION (POPIA)

This section is included in compliance with Section 17 of POPIA, which requires the responsible party (SOMS Digital) to include its processing activities in its PAIA Manual.

Purpose of Processing Personal Information

SOMS Digital processes personal information for the following purposes:

• Providing digital marketing and social media management services to clients
• Managing employee and contractor relationships
• Maintaining supplier and vendor relationships
• Complying with legal and regulatory obligations
• Invoicing, financial administration, and tax compliance
• Operating digital platforms and tools necessary for service delivery
• Marketing and communicating about SOMS Digital’s own services

Categories of Data Subjects and Information Processed

Recipients of Personal Information

Personal information processed by SOMS Digital may be shared with the following recipients in the ordinary course of business:

SOMS Digital will not sell, rent, or trade personal information to third parties.

Transborder Flows of Personal Information

SOMS Digital makes use of cloud-based software tools and social media platforms, some of which may store or process data outside the Republic of South Africa. These include, but are not limited to:

• Meta Business Suite (United States)
• Google Workspace / Google Ads (United States)
• LinkedIn Campaign Manager (United States)

SOMS Digital takes reasonable steps to ensure that such international processors maintain adequate data protection standards consistent with POPIA.

Information Security Measures

SOMS Digital implements the following security measures to ensure the confidentiality, integrity, and availability of personal information:

• Password protection and multi-factor authentication on all business accounts and platforms
• Encryption of sensitive data in transit and at rest (where applicable)
• Access controls limiting personal information to authorised personnel only
• Regular software updates and security patching
• Secure email communication practices
• Data retention and disposal policies in line with POPIA

REQUEST PROCEDURE

How to Submit a Request

Any person who wishes to request access to a record held by SOMS Digital must:

Step 1: Complete the prescribed Form 2 (Regulation 7) Request for Access to Record of a Private Body which is available from the Information Regulator’s website at https://inforegulator.org.za or from the Information Officer upon request.

Step 2: Submit the completed form, together with:

• A copy of your identity document (ID or passport)
• Payment of the prescribed request fee (see Section 10 below)

Step 3: Submit the request to the Information Officer at:

• Email: [email protected]
• Physical Address: 9th Floor, Atrium on 5th, 5th St, Sandhurst, Sandton, 2196

Grounds Required for a Request

In terms of Section 50 of PAIA, a requester must demonstrate that:

• The record is required for the exercise or protection of any right; and
• The request complies with the procedural requirements of PAIA.

Response Timeframe

• SOMS Digital will respond to a request within 30 days of receiving the request and the request fee.
• SOMS Digital may, in certain circumstances, extend this period by a further 30 days and will notify the requester accordingly.

Outcome of a Request

Upon review, the Information Officer will:

• Grant access to the record (in whole or in part); or
• Deny access and provide written reasons for the refusal, which may be challenged.

Appeals and Complaints

If a requester is dissatisfied with the decision of the Information Officer, the requester may:

• Lodge a complaint with the Information Regulator using the prescribed form within the timeframes allowed; or
• Apply to a court of competent jurisdiction to compel access to the record.

Complaints to the Information Regulator can be submitted at:

• Website: https://inforegulator.org.za
• Email: [email protected]

FEES

Request Fee

A request fee is payable before processing of the request commences, as prescribed by the PAIA Regulations. The current prescribed fees are set by the Minister of Justice and are available on the Information Regulator’s website.

Access Fee

If access is granted, an access fee may be charged for the reproduction of the record (e.g., per page for photocopies, or costs for electronic reproduction), as prescribed in Annexure B of the PAIA Regulations.

Fee Exemption

No fee is payable if the request relates to personal information about the requester themselves.

Copy of this Manual

A fee as contemplated in Annexure B of the PAIA Regulations shall be payable per A4-size photocopy made of this manual, if requested in physical form.

GROUNDS FOR REFUSAL

SOMS Digital may refuse a request for access to a record on grounds permitted by PAIA, including but not limited to:

• Protection of the privacy of a third party (including personal information protected under POPIA)
• Protection of commercial information of third parties (e.g., trade secrets)
• Protection of confidential information supplied to SOMS Digital
• Protection of the safety of individuals
• Records that would be privileged in legal proceedings
• Records whose disclosure would be manifestly frivolous or vexatious
• Records whose disclosure would constitute an unreasonable diversion of resources

In all cases of refusal, the Information Officer will provide written reasons for the decision.

AVAILABILITY AND UPDATING OF THIS MANUAL

A copy of this Manual is available:

• To any person upon request, on payment of a reasonable prescribed fee
• To the Information Regulator upon request

This Manual will be reviewed and updated on a regular basis as required by Section 51(2) of PAIA and any changes in applicable law or company operations.

Issued by:

Glynn Rieckhoff
Chief Executive Officer & Founder
SOMS Digital (Pty) Ltd
Date: June 2026