PAIA Manual

1. Particulars of the private body

2. Information Officer

The Information Officer is responsible for PAIA requests and decisions about access to records held by Privately.

3. The Information Regulator

The Information Regulator oversees both PAIA and POPIA. The PAIA Guide contemplated in section 10 of PAIA is available from the Regulator. You may contact the Regulator or lodge a complaint at:

4. The section 10 PAIA Guide

The Information Regulator has compiled a guide, in each official language, on how to use PAIA to exercise your rights. The guide explains the objectives of PAIA, the particulars of bodies, how to request access, and the assistance available from the Regulator. It is available free of charge from the Regulator at the contact details in section 3 above and on the Regulator’s website.

5. Records held by Privately

The categories of records we hold include, where applicable:

• Company records — registration, statutory and tax records.
• User account records — registration, profile, contact and KYC / identity-verification records.
• Property listing records — listings, photos, videos and related media.
• Transaction records — offers, accepted deals, conveyancing referrals and payment records held by our payment processor.
• Operational records — analytics, logs, support correspondence and consent records.
• Contractual records — agreements with operators, attorneys, bond originators and service providers.

Certain records are also available automatically without a formal PAIA request — for example, our published Privacy Policy and Terms, and your own personal data via the in-platform Privacy & data export.

6. How to request access to a record

1. Complete the prescribed Form 2 (Request for Access to Record of Private Body) issued under PAIA. The form is available from the Information Regulator’s website.
2. Provide enough detail to identify the record(s) requested, your identity, the form of access required, and a contact address (a postal address or email is sufficient).
3. If you are requesting access in order to exercise or protect a right, identify that right and explain why the record is required.
4. Submit the completed form to the Information Officer at the contact details in section 2 above.
5. Pay the applicable request and access fees prescribed under PAIA. We will notify you of any deposit or access fee before processing.
6. We will respond within 30 days of receipt of a compliant request. This period may be extended in the circumstances permitted by PAIA, in which case we will notify you.

7. Fees

A requester (other than a personal requester seeking their own personal information) may be required to pay a request fee, and an access fee covering the cost of reproduction, search and preparation, as prescribed in the PAIA regulations. We will provide a written fee estimate where the preparation cost is likely to exceed the prescribed threshold, and may require a deposit before processing.

8. Grounds on which access may be refused

We may refuse access to a record on any of the grounds set out in Chapter 4 of Part 3 of PAIA, including where disclosure would involve:

• the unreasonable disclosure of personal information about a third party (section 63);
• the disclosure of commercial information of a third party or of Privately, including trade secrets (sections 64 & 68);
• a breach of a duty of confidence owed to a third party (section 65);
• endangerment of the life or physical safety of an individual, or prejudice to the protection of property or a person (sections 66 & 67);
• the disclosure of privileged records or research information (sections 67 & 69);
• requests that are manifestly frivolous or vexatious.

9. Remedies if access is refused

PAIA does not provide for an internal appeal against a decision of a private body. If your request is refused, or you are dissatisfied with a decision, you may either lodge a complaint with the Information Regulator (section 3 above) or apply to a court for appropriate relief in terms of section 78 of PAIA, within the time periods prescribed by PAIA.