PAIA Manual

Compiled 1 November 2026; next review by 1 November 2027

This manual is published in terms of section 51 of South Africa’s Promotion of Access to Information Act, 2 of 2000 (PAIA), as amended by the Protection of Personal Information Act, 4 of 2013 (POPIA). Argfab AI is the business of Grant Trimble, a sole proprietor in Roodepoort, South Africa, which makes the Mac app Golf Swing Diary. Under PAIA it is a private body, and its head, who is also its Information Officer under POPIA, is the person named in the particulars above, as registered with the Information Regulator.

The manual is written from the Regulator’s template for a private body and follows its order. It says what records the business holds, how to ask for one, what it costs, how long we take, and what you can do if you are not satisfied. The Privacy Policy says what the app collects and what happens to it; where the two overlap, they say the same thing.

1. Purpose of this manual

PAIA gives everyone the right to ask a private body for a record it holds, where the record is needed to exercise or protect a right (section 50). This manual is what section 51 requires a private body to publish so that you can:

• see which of our records are available without a formal request;
• understand how to make a request, from a description of the subjects on which we hold records and the categories of records on each;
• find the contact details of the Information Officer who will deal with your request;
• find the Regulator’s guide on how to use PAIA, and how to get it;
• know the purpose for which we process personal information, whose information it is, who may receive it, whether it leaves South Africa, and in general terms how it is secured.

2. The private body and its Information Officer

The particulars at the top of this page are the particulars registered with the Information Regulator on the date given there, and the Regulator publishes them. The business is a sole proprietorship: there is no company, and no employee. Under section 1 of PAIA the head of such a private body is the natural person who carries on the business, and under section 55 of POPIA that person is also its Information Officer. There is no Deputy Information Officer, because only an employee of a body can be designated as one.

Send a request, or any question about this manual, to the Information Officer at the email address above; a letter to the postal address reaches the same person.

3. The Regulator’s guide on how to use PAIA

The Information Regulator has published, under section 10 of PAIA, a guide in plain language on how to use PAIA and POPIA: the objects of the two Acts, how to make a request to a public or a private body, the help available from an Information Officer and from the Regulator, the remedies (a complaint to the Regulator, an application to a court), how to find a body’s manual, the fees, and the Regulations.

The guide is available in each of the official languages and in braille, free of charge:

• on the Regulator’s website, inforegulator.org.za;
• from the Regulator’s office at Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191, telephone 010 023 5200, toll free 0800 017 160, email enquiries@inforegulator.org.za;
• from the Information Officer: a copy in English and in Afrikaans is kept at the street address above for public inspection during normal business hours, and a copy in any official language is supplied, free of charge, on request on Form 1 of the Regulations (regulation 3).

4. Records available without a request

These records are available to anyone without a PAIA request, free of charge, on the website:

This table is the description of records made available voluntarily under section 52(1) of PAIA and regulation 5. It is kept up to date, is available to the Regulator, on the website and for inspection at the street address above, and a copy of a record on it costs no more than the reproduction fee in section 8. No notice under section 52(2) has been published in the Government Gazette.

5. Records available under other legislation

6. The subjects on which we hold records, and the categories of records on each

We hold no record of your use of the app beyond what the table says. Your videos, your diary, your notes, your students’ details and your settings stay on your Mac and in your own iCloud; we have no copy of them and cannot give access to them. Apple holds your billing details; we never see them. We have no employees and therefore no personnel records, and the website keeps no record of its visitors.

7. How to request a record

A request for access to a record of a private body is made on the prescribed form, Form 2 of the PAIA Regulations, which you can download from the Regulator’s website. Send the completed form to the Information Officer by email, to the address in the particulars above, or by post. The form asks you to:

• give enough detail for us to identify the record and to identify you, with proof of identity (and, if you ask on someone else’s behalf, proof that you may);
• say which form of access you want (a copy, an inspection, a transcript) and how you would like to be told of the decision;
• give a postal address or fax number in South Africa;
• name the right you want to exercise or protect, and explain why you need the record for it (section 50(1)(a) of PAIA);
• say if you think you are exempt from a fee, and why.

The Information Officer will help you, free of charge, with the form (regulation 7(2)); if you cannot complete it yourself because you cannot read or write or have a disability, you may make the request orally, and the Information Officer completes the form for you and gives you a copy. A request that does not meet every formal requirement is not refused for that reason without first being given the chance to correct it.

If you want your own personal information, you do not need this procedure. Section 23 of POPIA gives you the right to ask whether we hold personal information about you and to see it, and the Privacy Policy says how: write to support@argfab.ai, and we answer within 30 days, at no charge.

What happens next

1. We acknowledge the request and, if a request fee is payable, ask you to pay it before we go further (section 54(1)). If finding and preparing the record will take more than six hours, we may ask for a deposit of up to a third of the access fee (section 54(2)).
2. We decide and tell you within 30 days of receiving the request, or of receiving the particulars and the fee (section 56). We may extend that once, by up to 30 days, if the request is for a large number of records, needs a search that cannot reasonably be done in time, or you agree in writing; we tell you within the first 30 days why and for how long (section 57).
3. The decision comes on Form 3 of the Regulations (regulation 8). If access is granted, it says the access fee, if any, and the form of access. If it is refused, it gives the reasons and the sections of PAIA relied on (section 56(3)). A request that gets no decision within the time allowed counts as refused (section 58).
4. Where part of a record may or must be refused, the rest is still given to you (section 59).

Access may be refused only on the grounds in Chapter 4 of Part 3 of PAIA (sections 62 to 70): the protection of another person’s privacy (63), of a third party’s commercial information (64) or information given in confidence (65), of the safety of people and of property (66), of records privileged in legal proceedings (67), of our own commercial information (68) and of research information (69). Even then, a record must be disclosed where the public interest in its disclosure clearly outweighs the harm (70), and where a third party’s record is involved, that third party is told of the request and may make representations (sections 71 to 73).

8. Fees

The fees are prescribed for private bodies in Annexure B of the Regulations relating to the Promotion of Access to Information, 2021 (Government Notice R. 757, Gazette 45057 of 27 August 2021; regulations 7(3) and 8), and we charge no more than they allow. The amounts, which the Regulator also publishes:

A copy sent by email costs nothing beyond the fees above. A deposit is repaid if the request is refused (section 54(4)). If a fee is out of date on this page, the Regulations prevail, and the Regulator’s fee structure gives the current figures.

9. If you are not satisfied

A private body has no internal appeal: PAIA’s internal appeal (section 74) is for public bodies. Your remedies against a decision of the Information Officer are these.

• A complaint to the Information Regulator, within 180 days of the decision (section 77A(2)(d)): against a refusal, a fee or a deposit, an extension of time, or the form of access, or where no decision was given in time. The complaint is made on Form 5 of the Regulations, on the Regulator’s website, and sent to PAIAComplaints@inforegulator.org.za or to the Regulator’s address in section 3 above. The Regulator may investigate, conciliate, and issue an enforcement notice.
• An application to a court, within 180 days, once the complaint procedure has been exhausted (section 78(1)(b) and (2)(d)): a court may confirm, amend or set aside the decision, and order access to the record (section 82).

Before either, we would rather hear from you: write to the Information Officer, and we will try to put it right.

10. Personal information

Section 51(1)(c) of PAIA, inserted by POPIA, asks a private body to say the following about the personal information it processes. The Privacy Policy says it in full; this is the summary the Act asks for.

Purpose of the processing

• To find and fix defects in the app, from the crash and error reports you choose to send.
• To answer feedback and improve the app.
• To confirm that a subscription is active, so that the app can unlock what was paid for.
• To keep the service secure and running, from the request logs of our servers.
• To run the business: paying for the services we use, keeping accounts, and meeting our obligations to Apple, to the Revenue Service and to the Regulator.

Categories of data subjects and of the information

The app is not directed at children, and we do not knowingly process a child’s information. We process no special personal information (health, religion, biometrics and the like) and no account credentials: the app has no account.

Recipients, or categories of recipients

• Apple, which runs the App Store, takes payment and holds the subscription under its own terms and privacy policy.
• Amazon Web Services, which hosts our servers and stores the reports and feedback.
• GitHub, which holds the private issue tracker where a copy of each feedback message and its reply address is placed, and the private repository of the business’s own records (suppliers’ invoices and contact details among them; never a user’s).
• Hugging Face, which serves the speech and language model files the app downloads, and so sees the internet address of the request.
• A court, a regulator or a law-enforcement body, where the law requires us to disclose.

We do not sell, rent or trade personal information, and nothing is given to advertisers.

Planned transborder flows

The reports, feedback and subscription records are stored on Amazon Web Services in the United States, and the issue-tracker copy of feedback on GitHub in the United States. Apple and Hugging Face process the information they receive under their own policies, in the countries where they operate. The transfers rest on the data subject’s consent (reports), on the contract with the data subject (purchases and feedback), and on the providers’ contractual commitments to protect the information, as section 72 of POPIA allows.

Security measures, in general terms

• Everything the app sends travels over an encrypted connection (HTTPS), and reports are stored encrypted at rest.
• Names, folders and email addresses are removed from a report on the Mac, before it is sent.
• Only the owner has access to what is stored. The website’s deploy and the servers’ are made through short-lived roles, with no credential stored in the code or its pipelines.
• Reports, feedback and their attachments are deleted automatically 90 days after the moment they describe; request logs after 30 days; database backups within a further 35 days.
• No passwords, payment details or government identifiers are held at all.

11. Availability of this manual

This manual is available:

• on the website, at golfswingdiary.com/paia/, free of charge, where it can be read, downloaded or printed;
• at the principal place of business, the street address in the particulars above, for public inspection during normal business hours;
• from the Information Officer on request: by email at no charge, or as a paper copy at the prescribed fee for photocopies (R2.00 per A4 page);
• to the Information Regulator on request.

The manual is in English. PAIA and the Regulations prescribe no language for a private body’s manual (section 14 asks three official languages of a public body’s; section 51 asks none of ours), and the Regulator’s guide recommends English. The Regulator’s own guide is available in every official language, as section 3 says.

12. Updating this manual

The head of the private body reviews this manual at least once a year, together with the particulars registered with the Regulator, and whenever anything in it changes. The dates of this version and of the next review are at the top of the page. A change to the registered particulars is made with the Regulator first, so that the two never differ.

Issued by Grant Trimble, Owner, Argfab AI.