PAIA Manual
Last updated: July 12, 2026
PAIA Manual
Manual of CleverCam (Pty) Ltd prepared in terms of section 51 of the Promotion of Access to Information Act, 2000 (Act 2 of 2000) ("PAIA"), read with the Protection of Personal Information Act, 2013 ("POPIA").
This manual explains what records CleverCam (Pty) Ltd ("CleverCam", "we", "us", "our") holds, and how you can request access to them. It also describes how we process personal information under POPIA. It should be read together with our POPIA & Data Protection page and our Privacy Policy.
1. About CleverCam
| Full name | CleverCam (Pty) Ltd |
| Registration number | 2024/280446/07 |
| Nature of business | Software for the security industry — AI camera monitoring, alarm and panic-event handling, armed-response dispatch, and the operations, staff and billing tools behind them. |
| Registered address | Den Haag Street, Die Heuwel, eMalahleni (Witbank), Mpumalanga, 1035, South Africa |
| Postal address | Den Haag Street, Die Heuwel, eMalahleni (Witbank), Mpumalanga, 1035, South Africa |
| General contact | hello@clevercam.co.za |
Information Officer
In terms of PAIA and POPIA, requests are handled by our Information Officer:
- Information Officer: Louw Jacobus Pretorius (Chief Executive & Managing Director)
- Email: legal@clevercam.co.za
- General contact: hello@clevercam.co.za
2. The Information Regulator's Guide on how to use PAIA
The Information Regulator has compiled a guide, in an easily understandable form, on how to use PAIA to exercise your rights. If you need more assistance than this manual provides, you may obtain that guide from the Information Regulator:
The Information Regulator (South Africa) JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001 Tel: 010 023 5200 Email (general enquiries): enquiries@inforegulator.org.za Email (PAIA complaints): PAIAComplaints@inforegulator.org.za Website: https://inforegulator.org.za
3. Records available in terms of other legislation
Certain records are, or may be, accessible in terms of legislation other than PAIA — for example the Companies Act, 2008; the Income Tax Act, 1962; the Value-Added Tax Act, 1991; the Basic Conditions of Employment Act, 1997; the Labour Relations Act, 1995; and POPIA. Access to those records is governed by the applicable legislation, and this manual does not override those rights or procedures.
4. Records automatically available without a formal request
We do not currently publish records that are automatically available for inspection, purchase or copying without a PAIA request, other than the information already public on our website (such as this manual, our POPIA & Data Protection page, our Privacy Policy and Terms of Service). All other records must be requested using the procedure in section 7 below.
5. Records held, by category
The following are the broad categories and subjects of records we hold. Listing a category here does not mean the records are automatically available — a request must be made, and access is subject to the grounds for refusal in PAIA.
- Company records — registration and statutory records, contracts, insurance, and internal policies.
- Financial records — invoices, payments, banking, tax and accounting records.
- Employee and human-resources records — records relating to our own staff.
- Customer and account records — the businesses that subscribe to our platform, their account administrators, and our correspondence with them.
- Operational data processed on behalf of customers — as described in section 6, most of the personal information on the platform is held by us as an Operator on behalf of our customers (who are the Responsible Parties). This includes their end-customer and keyholder contacts, camera images and event footage, alarm and panic events, vehicle and responder tracking, and their officers' records.
- Marketing and website records — prospect and enquiry records, and website analytics.
- Technical and security records — system logs, audit trails and configuration.
6. Processing of personal information (POPIA — section 51(1)(e))
In line with POPIA, we describe below the personal information we process. Fuller detail — including where the data is hosted (South Africa and the European Union), our sub-processors, security measures and your rights — is set out on our POPIA & Data Protection page.
Our role. For our customers' operational data we act as an Operator (processor) on their behalf; the customer is the Responsible Party. For our own account holders, staff, suppliers and website visitors we are the Responsible Party.
Categories of data subjects and the personal information relating to them:
| Category of data subject | Personal information |
|---|---|
| Our customers' account administrators and users | Names, contact details, usernames, hashed passwords, role and activity |
| Our customers' end-customers, keyholders and residents | Names, contact details, site/address information, camera images and event footage, alarm/panic events, location |
| Security officers and responders | Profile details and, where recorded, PSIRA registration, competency and firearm-competency records, and firearms-register entries |
| Our own employees and contractors | Employment, payroll and HR records |
| Suppliers and service providers | Contact and account details |
| Website visitors and prospects | Contact details, enquiry content, IP address, device and analytics data |
Categories of recipients. Personal information may be shared with the sub-processors listed on our POPIA & Data Protection page (for hosting, messaging, payments, mapping and related services), with the relevant Responsible Party, and with authorities where required by law.
Trans-border flows. Some personal information is processed outside South Africa — principally in the European Union (Ireland) for our core database, and with certain international service providers — as described and justified under POPIA section 72 on our POPIA & Data Protection page.
7. How to request access to a record
- Complete the prescribed request form (Form 2 of the Regulations under PAIA — the form for requesting access to a record of a private body). We can supply the form on request.
- Send the completed form to the Information Officer at legal@clevercam.co.za, or to our registered address.
- Provide enough detail to identify the record and yourself, specify the form of access required, and give an address/contact for our reply. If you are requesting the record on behalf of someone else, include proof of your authority.
- If the request is for personal information about yourself, we may ask you to verify your identity.
- Pay the prescribed request fee (and, where access is granted, the prescribed access fees) — see section 9.
Decision time. We will process your request within 30 days of receiving it. This period may be extended in the circumstances allowed by PAIA, in which case we will notify you.
8. Grounds for refusal
Access to a record may be refused on the grounds set out in Chapter 4 of Part 3 of PAIA, including:
- protection of the privacy of a third party who is a natural person;
- protection of the commercial information of a third party or of CleverCam;
- protection of confidential information supplied by a third party;
- protection of records privileged from production in legal proceedings;
- protection of research information; and
- where a request is manifestly frivolous or vexatious, or would involve an unreasonable diversion of resources.
Where only part of a record may be refused, we will grant access to the remainder.
9. Fees
Two fees may apply under PAIA:
- a request fee, payable before the request is processed; and
- an access fee, payable if access is granted, calculated according to the time and materials involved (for example, per-page reproduction, search and preparation, and postage).
The amounts are those prescribed from time to time in the Regulations under PAIA. The current fee schedule is available from the Information Officer on request. No fee is payable for a request for your own personal information, other than the reproduction cost where applicable.
10. Remedies if a request is refused
There is no internal appeal against a decision of a private body. If we refuse your request, or you are dissatisfied with how it was handled, you may:
- lodge a complaint with the Information Regulator (using PAIA Form 5) at PAIAComplaints@inforegulator.org.za; or
- apply to a court with jurisdiction for appropriate relief.
Full contact details for the Information Regulator are in section 2.
11. Availability of this manual
This manual is available:
- on our website at /paia-manual;
- from the Information Officer, on request (legal@clevercam.co.za); and
- at our registered address for inspection during office hours.
Copies may be requested in the languages and formats reasonably available.
12. Updates
We review and update this manual as our business, our records or the law change. The "last updated" date at the top of the page reflects the most recent revision.