Prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 (as amended).
1. List of acronyms and abbreviations
- “CIPC” Companies and Intellectual Property Commission
- “IO” Information Officer
- “DIO” Deputy Information Officer
- “Minister” Minister of Justice and Correctional Services
- “PAIA” Promotion of Access to Information Act No. 2 of 2000 (as amended)
- “POPIA” Protection of Personal Information Act No. 4 of 2013
- “Regulator” Information Regulator
- “Republic” Republic of South Africa
- “SARS” South African Revenue Service
- “the Company” Knowsis
2. Purpose of PAIA Manual
This PAIA Manual is useful for the public to:
- check the categories of records held by Knowsis which are available without a person having to submit a formal PAIA request;
- have a sufficient understanding of how to make a request for access to a record of the Company, by providing a description of the subjects on which the Company holds records and the categories of records held on each subject;
- know the description of the records of the Company which are available in accordance with any other legislation;
- access all the relevant contact details of the Information Officer and Deputy Information Officer who will assist the public with the records 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 Company will process personal information, the purpose of processing of personal information and the description of the categories of data subjects and of the information or categories of information relating thereto;
- know 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 Company has planned to transfer or process personal information outside the Republic of South Africa and the recipients or categories of recipients to whom the personal information may be supplied; and
- know whether the Company has appropriate security measures to ensure the confidentiality, integrity and availability of the personal information which is to be processed.
3. Key contact details for access to information of Knowsis
3.1 Information Officer
| Field | Details |
|---|---|
| Name | Gregory Streatfield |
| Tel | 0837017033 |
| greg@knowsis.co.za | |
| Fax number | Not applicable |
3.2 Deputy Information Officer
No Deputy Information Officer has been designated in terms of section 17(1) of PAIA and section 56 of POPIA. The Information Officer, Gregory Streatfield, is the sole point of contact for all requests for access to records.
3.3 Access to information general contacts
| Field | Details |
|---|---|
| greg@knowsis.co.za |
3.4 Head Office / Registered Office
| Field | Details |
|---|---|
| Postal / Physical Address | 35B Raapenberg Road, Mowbray, Cape Town, Western Cape, 7700 |
| Telephone | 0837017033 |
| greg@knowsis.co.za | |
| Website | https://knowsis.net |
4. Guide on how to use PAIA and how to obtain access to the guide
4.1 The Information 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.
4.2 The Guide is available in each of the official languages and in braille.
4.3 The Guide contains the description of the objects of PAIA and POPIA; the contact details of Information Officers and Deputy Information Officers; the manner and form of requests for access to records; the assistance available from the Information Officer and the Regulator; and all remedies in law available regarding an act or failure to act in respect of a right or duty conferred by PAIA and POPIA, including the manner of lodging an internal appeal, a complaint to the Regulator, or an application to court.
4.4 Members of the public can inspect or make copies of the Guide from the registered office of the Company during normal working hours, by prior arrangement with the Information Officer.
4.5 The Guide can also be obtained upon request to the Information Officer, or from the website of the Regulator (https://www.justice.gov.za/inforeg/).
4.6 A copy of the Guide is available in English and Afrikaans for public inspection during normal office hours, by prior arrangement with the Information Officer.
5. Categories of records of Knowsis which are available without a person having to request access
| Category of records | Types of the record | Available on website | Available upon request |
|---|---|---|---|
| Company constitutional documents | Memorandum of Incorporation, SARS Notice of Registration | — | X |
| PAIA compliance | PAIA Manual | X | X |
| Marketing information | Company profile, service brochures | X | — |
6. Description of the records of Knowsis which are available in accordance with any other legislation
| Category of records | Applicable legislation |
|---|---|
| Memorandum of Incorporation and CIPC filings | Companies Act 71 of 2008 |
| PAIA Manual | Promotion of Access to Information Act 2 of 2000 |
| Employee personal information and payroll records | Protection of Personal Information Act 4 of 2013; Basic Conditions of Employment Act 75 of 1997 |
| Financial statements and tax records | Income Tax Act 58 of 1962; Tax Administration Act 28 of 2011 |
7. Description of the subjects on which Knowsis holds records and categories of records held on each subject
| Subjects on which the Company holds records | Categories of records |
|---|---|
| Corporate / Company Secretarial | Memorandum of Incorporation, SARS Notice of Registration, director resolutions, register of directors |
| Finance | Financial statements, invoices, bank statements, tax records |
| Human Resources | Employment contracts, employee personal records, payroll records, leave records |
| Clients / Customers | Client contracts, correspondence, service records |
| Suppliers / Service Providers | Supplier agreements, invoices, banking details |
8. Processing of personal information
8.1 Purpose of Processing Personal Information
Knowsis processes personal information for purposes that include, but are not limited to: managing relationships with clients and customers; managing employees and contractors; complying with legal, tax and regulatory obligations; and managing relationships with service providers and suppliers.
8.2 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 |
| Service Providers | Name, registration number, VAT number, address, trade secrets and bank details |
| Employees | Address, qualifications, gender and race |
8.3 The recipients or categories of recipients to whom the personal information may be supplied
| Category of personal information | Recipients or categories of recipients |
|---|---|
| Identity number and names, for criminal checks | South African Police Service |
| Qualifications, for qualification verifications | South African Qualifications Authority |
| Credit and payment history, for credit information | Credit Bureaus |
8.4 Planned transborder flows of personal information
Knowsis uses third-party service providers to operate its business and its products, and some of those providers process or store personal information outside the Republic of South Africa. The providers, and the regions in which they process data, are:
| Provider | Purpose | Region |
|---|---|---|
| Anthropic PBC (Claude API) | Text analysis within specific Knowsis products | United States / global |
| Twilio SendGrid | Delivery of report emails | United States |
| Formspree | Contact form on knowsis.net | United States |
| Netlify | Hosting of the knowsis.net website | United States |
| PostHog | Product analytics | United States |
| Google LLC (Google Drive) | Encrypted off-site backups | United States |
| Paystack Payments South Africa (Pty) Ltd | Card payment processing | South Africa / regional |
Each provider is engaged under its commercial terms of service, which limit its use of the data to providing that service to Knowsis.
The Data Alchemy Platform and the Persona Engine run on Knowsis-operated hardware in Cape Town using a locally hosted open-source model. No personal information leaves the Republic in the course of operating those two products.
A fuller account, product by product, is set out in the Knowsis Privacy Policy.
8.5 General description of Information Security Measures
Knowsis applies the following safeguards to protect the confidentiality, integrity and availability of the personal information it holds:
- Encryption in transit. Data moving between users and Knowsis systems is protected by TLS.
- Access controls. Administrative and production systems are access-controlled. Knowsis is a small consultancy, and only a small number of people have access to production systems.
- Password protection. Platform accounts are password-protected, and passwords are stored as a one-way hash and never in readable form.
- Transient processing of research data. Datasets uploaded for analysis are processed within a session and are not retained as persistent datasets on the platform.
- Encrypted backups. Off-site backups are held as encrypted archives.
- Contractual safeguards. Third-party service providers are engaged under terms that limit their use of the data to providing the relevant service to Knowsis.
No method of transmission or storage is completely secure, and Knowsis cannot guarantee absolute security. Further detail is set out in the Knowsis Privacy Policy.
9. Availability of the manual
9.1 A copy of this Manual is available:
- on the Knowsis website at https://knowsis.net/paia;
- at the registered office of Knowsis for public inspection during normal business hours, by prior arrangement with the Information Officer;
- to any person upon request and upon payment of a reasonable prescribed fee; and
- to the Information Regulator upon request.
9.2 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.
10. Updating of the manual
The Information Officer of Knowsis will, on a regular basis, review and update this Manual.
Issued by
Gregory Streatfield
Information Officer, Knowsis