Privacy Policy

Purpose of the PAIA Manual

This PAIA Manual is useful for the public to:

• Check the categories of records held by a body which are available without a person having to submit a formal PAIA request
• Have sufficient understanding of how to make a request for access to a record of the body, by providing a description of the subjects on which the body holds records and the categories of records held on each subject
• Know the description of the records of the body which are available in accordance with any other legislation.
• Access all the relevant contact details of the IO and DIO who will assist the public with the records that they intend to access.
• Know the description of the guide on how to use PAIA, as updated by the Regulator, and how to obtain access to it.
• Know if the body will process personal information, the purpose of processing personal information, and the description of the categories of data subjects and of the information or categories of information relating thereto.
• Know the recipients or categories of recipients to whom the personal information may be supplied.
• Know if the body has planned to transfer or process personal information outside of the Republic of South Africa and the recipients or categories of recipients to whom the personal information may be supplied.
• Know whether the body has appropriate security measures to ensure the confidentiality, integrity and availability of the personal information which is to be processed.

Key Contact Details for Access to Information of the 247AI SOUTH AFRICA (PTY) LTD

Information Officer

Name	Johannes Christaan S
Email address	Informationofficer.SA@247.ai
Office address	11 IMAM HARON ROAD CLAREMONT CLAREMONT WESTERN CAPE 7708

Global Privacy Committee and DIO

Email address

Privacy@247.ai

Guide on how to use PAIA and how to Obtain Access to the Guide

• The Regulator has, in terms of section 10(1) of PAIA, as amended, updated and made available the revised guide on how to use PAIA (“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 aforesaid guide contains the description of:

1. The objects of PAIA and POPIA;
2. The postal and street address, phone and fax number and, if available, email address of:
   • The IO of every public body, and
   • Every DIO of every public and private body is designated in terms of section 17(1) of PAIA and section 56 of POPIA[1];
3. The manner and form of a request for:
   • Access to a record of a public body contemplated in section 11[2].
   • Access to a record of a private body contemplated in section 50[3].
   • An internal appeal.
   • A complaint to the Regulator
   • An application with a court against a decision by the IO of a public body, a decision on internal appeal or a decision by the Regulator or a decision of the head of a private body.

• The provisions of sections 14[4] and 51[5] requiring a public body and private body, respectively, to compile a manual, and how to obtain access to a manual;
• The provisions of sections 15[6] and 52[7] providing for the voluntary disclosure of categories of records by a public body and private body, respectively;
• The notices issued in terms of sections 22[8] and 54[9] regarding fees to be paid in relation to requests for access;
• The regulations made in terms of section 92[10];
• Assistance is available from the IO of a public body in terms of PAIA and POPIA;
• The assistance available from the Regulator in terms of PAIA and POPIA; and
• All remedies in law are available regarding an act or failure to act in respect of a right or duty conferred or imposed by PAIA and POPIA, including the manner of lodging.
• Members of the public can inspect or make copies of the guide from the offices of the public and private bodies, including the office of the Regulator, during normal working hours.
• The guide can also be obtained:
  • Upon request to the IO.
  • From the website of the Regulator (Empowered to monitor and enforce compliance by public and private bodies.)
• A copy of the guide is also available in the following three official languages, for public inspection during normal office hours:
  •  English.
  •  Afrikaans.
  •  Zulu.

Guide of Information Regulator

• A guide to PAIA and how to access information in terms of PAIA has been published pursuant to section 10 of PAIA.
• The guide contains information required by an individual who may wish to exercise their rights in terms of PAIA.
• Should you wish to access the guide, you may request a copy from the IO by contacting him/her using the details specified above.
• You may also inspect the guide at 247AI SOUTH AFRICA (PTY) LTD’s offices during ordinary working hours.
• You may also request a copy of the guide from the Information Regulator at the following details:

Postal address	P O Box 31533, Braamfontein, Johannesburg, 2017
Contact number	+27 (10) 023-5200
Website	www.inforegulator.org.za
Email	PAIAComplaints@inforegulator.org.za.

Latest Notices in terms of Section 52(2) of PAIA

At this stage, no notice(s) has/have been published on the categories of records that are available without having to request access to them in terms of PAIA.

Availability of Certain Records in terms of PAIA

Categories of records of the 247AI SOUTH AFRICA (PTY) LTD which are available without a person having to request access:

Category of Records	Types of the Record	Available on Website	Available on Request
PAIA Manual	Company’s current PAIA Manual	X	X
Company overview	Company profile, business activities (technology services, business support services, BPO/agent services), business activities, contact details) contact details	X	X
Policies (public-facing)	Privacy policy, website cookies policy	X	X
Legal disclosures	Disclaimers, terms & conditions, consumer protection notices related to logistics service agreements	X	X
News and announcements	Service updates, media releases, company news relevant to logistics/shipping/wagons/rail, changes in service offering	X	X
Public marketing materials	Brochures, descriptions of service offerings (road transport, rail, warehousing, cold chain, project cargo, etc.)	X	X
POPIA and PAIA awareness training certificates	Records of internal or external training / awareness sessions on data protection (POPIA) and access to information (PAIA)	–	X
Public tender or supplier information (if applicable)	Supplier onboarding requirements, procurement notices, B-BBEE certificate (if published), accreditation or certification documents	–	X
Contact information for IO	Name, designation, email address, telephone / fax / physical address	X	X

Description of the records/subjects of (247AI SOUTH AFRICA (PTY) LTD) which are available in accordance with any other legislation:

Category of Records	Applicable Legislation	Department/ Subject Area
Memorandum of Incorporation, company registration documents, minutes of board meetings, share register	Companies Act, 71 of 2008	Corporate Governance
Employment contracts, employee attendance records, payroll information, leave records	Basic Conditions of Employment Act, 75 of 1997	Human Resources (HR)
Disciplinary records, grievance procedures, union agreements, Commission for Conciliation, Mediation and Arbitration (CCMA) documentation	Labor Relations Act, 66 of 1995	HR
Employment Equity (EE) plans, EE reports, committee meeting minutes	Employment Equity Act, 55 of 1998	HR
Tax returns, IRP5 certificates, Pay-As-You-Earn (PAYE) records, employee tax submissions	Income Tax Act, 58 of 1962	Finance
Workplace Skills Plans (WSPs), annual training reports, learnership agreements	Skills Development Act, 97 of 1998	Training and Development
Unemployment Insurance Fund (UIF) contribution records, declarations, employee benefit claim records	Unemployment Insurance Act, 63 of 2001	HR
Health and safety audits, incident reports, risk assessments, safety committee records	Occupational Health and Safety Act, 85 of 1993	Occupational Health and Safety
Value-Added Tax (VAT) returns, input/output tax records, SARS correspondence	Value-Added Tax Act, 89 of 1991	Finance
Workers Compensation Assistance (WCA) claims, injury-on-duty reports, compensation records	Compensation for Occupational Injuries and Diseases Act, 130 of 1993	Occupational Health and Safety
B-BBEE certificates, ownership and supplier development records	Broad-Based Black Economic Empowerment Act, 53 of 2003	Supply Chain Management (SCM)
Client contracts, complaint records, marketing disclaimers, product/ service terms and conditions	Consumer Protection Act, 68 of 2008	Client Services/ Marketing
System access logs	Electronic Communication and Transactions Act, 25 of 2002	IT Security
Incident reports	Electronic Communication and Transaction Act, 25 of 2002	IT Security
Cybersecurity incident reports, phishing logs, malware reports, vulnerability assessments, system monitoring logs	Cybercrimes Act, 19 of 2020	IT / Information Security
Call recordings, customer interaction records, scripts, voice recordings	Provision of Communication-Related Information Act, 70 of 2002 (RICA)	Operations / Compliance
Data subject consent forms, privacy notices, PAIA Manual, operator agreements, processing activity records	Protection of Personal Information Act, 4 of 2013	Legal and Compliance
PAIA Manual, access request logs, training records	Promotion of Access to Information Act, 2 of 2000	Legal and Compliance
Know Your Customer (KYC) documents, client identification and verification records	Financial Intelligence Centre Act, 38 of 2001 (if applicable)	Client Services/ Finance
Electronic communications policies, e-signature consents, website terms and conditions	Electronic Communications and Transactions Act, 25 of 2002	Information Technology (IT)
Document retention and disposal schedules, archive logs	National Archives and Records Service Act, 43 of 1996	Records Management

*Although we have used our best endeavors to supply a list of applicable legislation, it is possible that this list may be incomplete. Whenever it comes to our attention that existing or new legislation allows a Requester access on a basis other than as set out in PAIA, we shall update the list accordingly. If a Requester believes that a right of access to a record exists in terms of other legislation listed above or any other legislation, the Requester is required to indicate what legislative right the request is based on, to allow the Information Officer the opportunity of considering the request in light thereof.

• 247AI SOUTH AFRICA (PTY) LTD holds and/or processes the following records for the purposes of PAIA and POPIA:
  • PAIA: PAIA Manual; PAIA guides; PAIA records; PAIA submission records; awareness training.
  • POPIA: Including, but not limited to, the following: IO Registration Certificate; data breach records; retention records; awareness training.
  • Further information may be made available upon request.

• The above-mentioned records may be requested; however, it should be noted that there is no guarantee that the request will be honored. Each request will be evaluated in terms of PAIA and any other applicable legislation.

Request Process

• An individual who wishes to place a request must comply with all the procedures laid down in PAIA.

• The requester must complete Form 02 of PAIA Forms (Request for Access to Record) herein, is attached hereto and submit it to the IO at the details specified herein.

• The prescribed form as well as payment of a request fee and a deposit (if applicable) must be submitted to the IO at/via the postal or physical address, fax number or email address as is stated herein.

• The prescribed form must be completed with enough particularity to enable the IO to determine:
  • The record(s) requested;
  • The identity of the requestor;
  • What form of access is required; and
  • The postal address or fax number of the requestor.

• The requestor must state that the records are required for the requestor to exercise or protect a right, and clearly state what the nature of the right is so to be exercised or protected. An explanation of why the records are requested is required to exercise or protect the right.

• The request for access will be dealt with within 30 (thirty) days from date of receipt, unless the requestor has set out special grounds that satisfies the IO that the request be dealt with sooner.

• The period of 30 (thirty) days may be extended by not more than 30 (thirty) additional days, if the request is for a large quantity of information, or if the request requires a search for information held at another office of 247AI SOUTH AFRICA (PTY) LTD and the information cannot be reasonably obtained within 30 (thirty) days. The IO will notify the requestor in writing should an extension be necessary.

• The IO must communicate a response to the request for access using Form 03 of PAIA Forms (Outcome of Request and of Fees Payable) herein. This communication shall inform the requestor of:
  • The decision; and
  • Fees payable.

• If the IO is of the opinion that the searching and preparation of the record for disclosure would amount to more than six (6) hours, he/she shall inform the requestor to pay a deposit not exceeding one third of the amount payable.

• Should the requestor have any difficulty with the form or the process laid out herein, the requestor should contact the IO for assistance.

• An oral request can be made to the IO should the requestor be unable to complete the form due to illiteracy or a disability. The IO will then complete the form on behalf of the requestor and provide a copy of the form to the requestor.

• Form 2 of POPIA Forms (Request for Correction or Deletion) herein, is used by a data subject to request the correction of inaccurate, outdated, incomplete, irrelevant, or misleading personal information, and/or the deletion or destruction of personal information that is no longer necessary or unlawfully obtained, in accordance with Section 24(1) of POPIA. It ensures that responsible parties maintain accurate and lawful records of personal data.

• Form 3 of POPIA Forms (Application for the Issue of a Code of Conduct) herein is used by an industry body, profession, or class of entities to apply for the issuance of a Code of Conduct under Section 61(1)(b) of POPIA. It allows industries to self-regulate how personal information is processed within their sector, in line with the conditions for lawful processing.

• Form 4 of POPIA Forms (Request for Consent – Direct Marketing) herein enables a responsible party to formally request a data subject’s consent to receive direct marketing communications via unsolicited electronic means (e.g., SMS, email), as required under Section 69(2) of POPIA. It ensures that individuals have control over whether and how they are marketed to.

• Form 5 of POPIA Forms (Complaint Regarding Interference with Personal Information) herein allows a data subject or complainant to submit a complaint to the IR concerning unlawful interference with personal information; or a determination made by an adjudicator under POPIA. It provides an avenue for recourse and investigation in cases of non-compliance with data protection obligations.

Grounds for Refusal

• The following are grounds upon which 247AI SOUTH AFRICA (PTY) LTD may, subject to the exceptions in chapter 4 of PAIA, refuse a request for access in accordance with chapter 4 of PAIA:

• Mandatory protection of the privacy of a third party who is a natural person, including a deceased person, where such disclosure of personal information would be unreasonable.

• Mandatory protection of the commercial information of a third party, if the records contain:
  • Trade secrets of that third party;
  • Financial, commercial, scientific or technical information of the third party, the disclosure of which could likely cause harm to the financial or commercial interests of that third party; and/or
• Information disclosed in confidence by a third party to 247AI SOUTH AFRICA (PTY) LTD, the disclosure of which could put that third party at a disadvantage in contractual or other negotiations or prejudice the third party in commercial competition.

• Mandatory protection of confidential information of third parties if it is protected in terms of any agreement.

• Mandatory protection of the safety of individuals and the protection of property.

• Mandatory protection of records that would be regarded as privileged in legal proceedings.

• Protection of the commercial information of 247AI SOUTH AFRICA (PTY) LTD, which may include:
  • Trade secrets;
  • Financial/commercial, scientific or technical information, the disclosure of which could likely cause harm to the financial or commercial interests of 247AI SOUTH AFRICA (PTY) LTD;
  • Information which, if disclosed, could put 247AI SOUTH AFRICA (PTY) LTD at a disadvantage in contractual or other negotiations or prejudice 247AI SOUTH AFRICA (PTY) LTD in commercial competition; and/or
  • Computer programs which are owned by 247AI SOUTH AFRICA (PTY) LTD, and which are protected by copyright and intellectual property laws.

• Research information of 247AI SOUTH AFRICA (PTY) LTD or a third party, if such disclosure would place the research or the researcher at a serious disadvantage
• Requests for records that are clearly frivolous or vexatious, or which involve an unreasonable diversion of resources.

Remedies Should a Request be Refused

If 247AI SOUTH AFRICA (PTY) LTD does not have an internal appeal procedure in light of a denial of a request, decisions made by the IO is final. The requestor may in accordance with sections 56(3) (c) and 78 of PAIA, apply to a court for relief within 180 (one-hundred-and-eighty) days of notification of the decision for appropriate relief.

Fees

The following fees shall be payable upon request by a requestor:

Details	Fee
Request fee (payable on every request)	R140.00 once-off
Photocopy of an A4 page or part thereof	R2.00 per page
Printed copy of an A4 page or part thereof	R2.00 per page
Hard copy on flash drive (flash drive to be provided by requestor)	R40.00 once-off
Hard copy on a compact disc (compact disc to be provided by requestor)	R40.00 once-off
Hard copy on a compact disc (compact disc to be provided by 247AI SOUTH AFRICA (PTY) LTD)	R60.00 once-off
Transcription of visual images per A4 page	As per quotation of service provider
Copy of visual images	As per quotation of service provider
Transcription of an audio record	R24.00 per A4 page
Copy of an audio record on flash drive (flash drive to be provided by requestor)	R40.00 once-off
Copy of an audio on a compact disc (compact disc to be provided by requestor)	R40.00 once-off
Copy of an audio on a compact disc (compact disc to be provided by 247AI SOUTH AFRICA (PTY) LTD)	R60.00 once-off
Base/starting rate to search for and prepare the record for disclosure	R145.00 per hour for each hour or part thereof, excluding the first hour, reasonably required for such search and preparation (cannot exceed R435.00 per request)
Rate to search for and prepare the record for disclosure	R435.00 per hour for each hour or part thereof, excluding the first hour, reasonably required for such search and preparation (cannot exceed total cost)
Postage, email or any other electronic transfer	Actual expense, if any

Processing of Personal Information

The purposes for processing personal information include:

• To provide technology and business support services, including call handling, customer support services, sales support, and related client service functions.
• To respond to enquiries, complaints, claims, or service-related requests.
• To process payments for services rendered, including invoicing, billing, and reconciliations.
• To perform contractual obligations in terms of service agreements with clients, suppliers, and business partners, including compliance with service level agreements (SLAs).
• To conduct quality assurance monitoring, including call evaluations, performance reviews, service improvement reporting, and customer satisfaction feedback.
• For recruitment, onboarding, training, workforce management, and HR administration purposes, including verification of qualifications and work history.
• For security, access control, and identity verification purposes, including the accuracy of personal information provided.
• To maintain IT systems, network infrastructure, cybersecurity monitoring, and business continuity processes.
• To comply with applicable legal and regulatory requirements, including record retention obligations and lawful disclosure obligations.
• To conduct direct marketing activities where consent is obtained or where permitted by law, including the management of opt-outs and objection requests.
• To support dispute resolution, claims investigations, or regulatory reporting.

Description of the categories of data subjects and of the information or categories of information relating thereto:

Categories of Data Subjects	Personal Information that may be Processed
Customers/clients	Name, address, registration numbers or identity numbers, employment status and bank details, Physical Address
Service providers	Name, registration number, VAT number, address, trade secrets and bank details
Employees	Name, surname, ID number, tax number, contact details, residential address, bank details, employment contracts, payroll and benefits information, leave records, performance records, disciplinary records, qualifications, race and gender (for EE compliance), training and development records, health and safety information.
Job Applicants	Name, surname, contact details, CV, qualifications, previous employment history, references, criminal or credit checks (if applicable).
Contractors / Freelancers	Full name, identity number, contact info, banking details, tax information, contracts, work experience, qualifications
Visitors / Guests	Name, contact details, vehicle registration (if recorded), visitor registers, CCTV footage (if applicable for office/site security).
Regulatory Bodies / Authorities	Contact person details, company registration info, compliance documentation, correspondence records
Shareholders / Investors	Full name, contact info, identity numbers, banking info, shareholding details, investment history, correspondence records
IT / System Users	Full name, identity info, login credentials, access logs, device info, IP addresses, security authentication data
Marketing / Newsletter Subscribers	Full name, contact info (email, phone), preferences, consent records, interaction history with communications

The Recipients or Categories of Recipients to whom the Personal Information may be Supplied

Category of Personal Information	Recipients or Categories of Recipients to whom the Personal Information may be Supplied
Identity number and names, for criminal checks	South African Police Services (SAPS), accredited background check agencies
Qualifications, for qualification verifications	South African Qualifications Authority
Credit and payment history, for credit information	Credit bureaus, debt collection service providers
Employment history and references (for background checks)	Previous employers, recruitment agencies, background screening companies
Banking details	Financial institutions, payment processors
Health information (for occupational health assessments)	Occupational health service providers, medical professionals
Customs and import/export documentation (for cross-border logistics)	South African Revenue Service (SARS) Customs Division, international customs authorities
Security clearance information (for restricted access areas)	Security service providers, regulatory bodies
Skills development and training records	Sector Education and Training Authorities (SETAs)
CCTV footage and security incident records	Authorized security service providers; law enforcement authorities (if required)

Planned Transborder Flows of Personal Information

247AI SOUTH AFRICA (PTY) LTD may transfer or store certain categories of personal information outside the Republic of South Africa, primarily using cloud-based service providers, payment gateways, marketing platforms, and IT hosting providers. These service providers may be located in jurisdictions such as the United States of America, the European Union, and other regions where global service providers host their systems.

The country in which personal information will be stored

India

Sout Africa

247AI SOUTH AFRICA (PTY) LTD may share personal information with third parties and in certain instances this may result in transborder flow of the personal information. The personal information will always be subject to protection, not less than the protection it is afforded under the Protection of Personal Information Act No.4 of 2013. General description of information security measures to ensure the confidentiality, integrity and availability of the information:

• Keeping our systems secure through access controls, system monitoring, and usage tracking;
• Storing physical and digital records in secure, access-controlled environments;
• Restricting access to buildings, systems, and records to authorized personnel only;
• Securely destroying or deleting personal information once it is no longer required;
• Ensuring compliance with relevant data protection standards, legal requirements, and industry codes of conduct.

In addition, the following technical security safeguards have been implemented to support these objectives:

• Data encryption (at rest and in transit) to protect sensitive information from unauthorized access;
• Anti-virus and anti-malware software to detect, prevent, and mitigate cyber threats;
• Firewalls and intrusion detection/prevention systems (IDS/IPS) to monitor and safeguard network traffic;
• Multi-factor authentication (MFA) and role-based access controls to limit access based on job function and business need;
• Secure backup and disaster recovery solutions to ensure business continuity and data integrity;
• Ongoing system monitoring and access logging to detect and respond to suspicious activity;
• Physical security controls such as keycard access, secure storage, and visitor management procedures;
• Employee training and awareness program to promote secure data handling and prevent human error;
• Secure disposal of physical and electronic records when no longer needed or when required by law.
• These safeguards are continuously reviewed and enhanced to address new risks, changing business processes, and advancements in technology.

Availability of the Manual

• A copy of the manual is available:
• On or at any head office 247.ai 247AI SOUTH AFRICA (PTY) LTD for public inspection during normal business hours;
• To any person upon request and upon the payment of a reasonable prescribed fee; and
• To the Information Regulator upon request
• A fee for a copy of the manual, as contemplated in Annexure B of the Regulations, shall be payable per each A4-size photocopy made.

Objection to the Processing of Personal Information by a Data Subject

• A data subject who wishes to object to the processing of personal information in terms of section 11(3)(a) or section 11(3)(b) of the Act, must submit the objection to a responsible party at any time during office hours of a responsible party and free of charge.
• A data subject who wishes to object to the processing of personal information must do so on a form substantially similar to Form 3 herein, free of charge and reasonably accessible to a data subject by hand, fax, post, email, SMS, or WhatsApp and or in any manner expedient to a data subject in terms of section 11(3)(a) of the Act.
• A responsible party must, when collecting personal information of a data subject, notify the data subject, in terms of section 18(1)(h)(iv) of the Act, of their right to object, as referred to in section 11(3) of the Act.
• If an objection to the processing of personal information of a data subject is made telephonically, such an objection shall be electronically recorded by a responsible party and upon request, be made available to the data subject in any manner, including the transcription thereof.

Request for Correction/Deletion of Personal Information or Destruction/Deletion of Record of Personal Information

• A data subject has the right, in terms of section 24 of the Act, to request, where necessary, the correction, destruction, or deletion of his, her or its personal information.
• A data subject, who wishes to request a correction or deletion of his, her, or its personal information, as provided for in section 24(1)(a) of the Act, has the right to request correction or deletion of personal information at any time and free of charge, if the personal information is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully.
• A data subject who wishes to request the destruction or deletion of a record of his, her, or its personal information in terms of section 24(1)(b) of the Act, has the right to request the destruction or deletion of a record of his, her or its personal information at any time and free of charge, if a responsible party is no longer authorised to retain such information in terms of section 14 of the Act.
• A request for correction to or deletion of personal information, as referred to in sub-regulation 12.11.2 or a request for the destruction or deletion of a record of personal information, as referred to in sub-regulation 12.11.3 must be submitted to a responsible party on a form which is substantially similar to Form 2 of POPIA Forms herein free of charge and reasonably accessible to a data subject by hand, fax, post, email, SMS, WhatsApp message or in any manner expedient to a data subject.
• A request for a correction or deletion of personal information by telephonic means shall be recorded by a responsible party and such recording must, upon request, be made available to a data subject in any manner, including the transcription thereof which shall be free of charge.
• A responsible party must, within 30 (thirty) days of receipt of the outcome of the request referred to in sub-regulation 12.11.2 or 12.11.3, notify a data subject, in writing, of the action taken as a result of the request

APPLICABLE FORMS

PAIA Forms
Form 01: Request for a Copy of the Guide from an Information Officer [Regulation 3]
Form 02: Request for Access to Record [Regulation 7]
Form 03: Outcome of Request and of Fees Payable [Regulation 8]
Form 05:Complaint Form [Regulation 10]
Form 13: PAIA Request for Compliance Assessment Form [Regulation 14(1)]

POPIA Forms
Form 1: Objection to the Processing of Personal Information
Form 2: Request for Correction of Deletion of Personal Information or Deletion of Record of Personal Information
Form 3: Application for the Issue of a Code of Conduct
Form 4: Application for the Consent of a Data Subject for the Processing of Personal Information for the Purpose of Direct Marketing
Form 5: Complaint Regarding Interference with the Protection of Personal Information for the Purpose of Direct Marketing