CLK Protection Services (Pty) Ltd — PAIA Manual

1. Acronyms

2. Purpose

This Manual assists the public to understand record categories, automatically available information, how to make PAIA requests, key contact details, personal-information processing categories and purposes, recipients, transborder processing, security measures, and applicable rights.

3. Key contacts

A suitable public-facing service address is pending and no residential address is published. Formal correspondence should presently be initiated through the email above. Information Officer registration with the Information Regulator is pending.

4. PAIA Guide

The Information Regulator maintains the PAIA Guide and prescribed forms to help people exercise access-to-information rights. See the official Form 2 and PAIA guidance. A private-body access request should ordinarily use prescribed Form 2. The requester must identify the right to be exercised or protected and explain why the requested record is required to exercise or protect that right.

5. Automatically available records

• Privacy & POPIA Notice;
• Participation Terms;
• this PAIA Manual;
• the public registration Portal and general registration information; and
• published Joint Operations contact information.

6. Other legislation

The presently confirmed legislation under which records may be held is:

• Companies Act 71 of 2008;
• Promotion of Access to Information Act 2 of 2000; and
• Protection of Personal Information Act 4 of 2013.

This section will be expanded after the company-wide statutory records review. No broader list is represented as complete at this interim stage.

7. Subjects and categories of records

Joint Operations registrations

• submissions and contact/affiliation information;
• status, confirmation, and update records; and
• rejected and archive records.

Joint Operations administration

• status history, review information, and verification notes;
• administrative notes and decision information; and
• secure confirmation-link audit information.

Privacy and access administration

• POPIA enquiries and access, correction, deletion, or objection requests;
• request identity verification; and
• PAIA requests, responses, and decisions.

Corporate/statutory records

CLK may hold company and statutory records. The wider company records audit remains pending, so those categories will be refined in an update.

8. Processing personal information

Purposes

Purposes include registration administration, applicant identification and verification, eligibility decisions, participant administration, communication and operational coordination, annual confirmation and updates, security and integrity, handling privacy/access requests, legal compliance, and establishment or protection of lawful rights.

Categories of data subjects

Applicants, approved or former participants, administrators, verification contacts, representatives of participating organisations, correspondents, requesters, and relevant third parties.

Recipients

Authorised administrators; stated employers, organisations, or appropriate verification contacts where reasonably necessary; technology providers; advisers; and lawful authorities where required or permitted by law.

Transborder flows

Cloudflare Pages, Workers and D1, and WhatsApp, may involve processing outside South Africa. Such flows are intended to be handled under section 72 of POPIA and applicable safeguards.

Security measures

Measures include restricted administrator access, authentication, role-based permissions, secure confirmation/update links, and reasonable technical and organisational safeguards. No system is guaranteed completely secure.

9. PAIA request procedure

1. Use prescribed Form 2 for a private-body request.
2. Identify the record requested with enough detail to locate it.
3. Identify the right to be exercised or protected and explain why the record is required.
4. Provide contact details and the preferred form of access.
5. Submit the request to clkgrp.identify@gmail.com.

Prescribed request and access fees may apply; this Manual does not hard-code an amount. A request may be refused only on lawful PAIA grounds. Depending on the decision and circumstances, a complaint to the Information Regulator and/or a court remedy may be available.

10. Information Regulator

11. Availability

This Manual is available on the website, as an electronic copy on request, and to the Regulator where required. A physical inspection location will be added once a suitable public-facing business/service address is confirmed. Until then, arrangements and formal correspondence should be initiated by email.

12. Updates and issue

The Manual will be updated for material record or processing changes, confirmation of the public address, Information Officer registration status, completion of the statutory audit, and changes in law.