PAIA Section 51 Manual
ASDF Consulting (Pty) Ltd – registration number 2023/566704/07.
Published under Section 51, Promotion of Access to Information Act, 2000.
1. Contact details
Requests should be addressed to Frederick James (Ricky) Klopper, Managing Director and Information Officer:
| Contact | Details |
|---|---|
| Postal and street address | Block 2, Blaauwklip Office Park, Webersvallei Road, Stellenbosch, 7600 |
| ricky@bill.co.za | |
| Telephone | 069 041 1717 |
2. The PAIA guide
The Information Regulator’s guide explains how to exercise rights under the Promotion of Access to Information Act, 2000 and POPIA. It and its translations are available at inforegulator.org.za/paia-guidelines or from the Information Officer. A person who cannot read the guide may ask the Information Regulator for assistance (Section 10, Promotion of Access to Information Act, 2000).
3. Records available without a formal request
This manual, the Privacy Policy, terms of service, cookie policy and refund policy are available on bill.co.za.
4. Records available under other legislation
Access to the following records is available to persons entitled to it under the applicable legislation:
| Records | Legislation |
|---|---|
| Company constitutional documents, securities and director registers, shareholder-meeting records and financial statements | Sections 26 and 31, Companies Act 71 of 2008 |
| Records kept under the Basic Conditions of Employment Act 75 of 1997 or National Minimum Wage Act 9 of 2018 that relate to the employee’s employment | Section 78, Basic Conditions of Employment Act 75 of 1997 |
| Confirmation of, and a record or description of, personal information held about the requester | Section 23, Protection of Personal Information Act, 2013 |
The relevant law determines who may obtain each record and the applicable procedure.
5. Subjects and categories of records
| Subject | Records held |
|---|---|
| Bill customers | Contracts, correspondence, invoices and account records |
| Finance | Accounting records, bank records, tax records and annual financial statements |
| Personnel and contractors | Agreements, payroll and employment records |
| Suppliers | Agreements, correspondence and invoices |
| Company statutory | Registration documents, registers and resolutions |
| Operations and compliance | Business operations, systems and privacy compliance records |
Access to these records is assessed under the Promotion of Access to Information Act, 2000.
6. Processing of personal information
This section summarises the information required by Section 51(1)(c), Promotion of Access to Information Act, 2000. The Privacy Policy, including Annexure A, is the authoritative statement of how we process personal information.
6.1. Purposes
We process personal information to provide the Bill platform and its billing and communication services, and to measure how well its features perform and evaluate the quality of chat replies; manage client, employment, contractor and supplier relationships; administer payroll; maintain business and accounting records; comply with legal obligations; respond to enquiries; and market our services and measure website and advertisement performance, with consent where required.
6.2. Data subjects and information categories
| Data subjects | Information categories |
|---|---|
| Bill users | Identity and contact details, practice details, credentials, billing rates, subscription and payment records, and communications processed on their instructions |
| Users’ clients and contacts | Identity and contact details, matter and billing records, and communication content |
| Employees and contractors | Identity, contact, banking, tax and employment information |
| Suppliers | Identity, contact, banking and tax information |
| Website visitors and prospects | Contact and enquiry information, marketing preferences, campaign details, IP addresses, device and browser information, website usage and timing data, and cookie and advertisement-click identifiers where consent is given |
6.3. Recipients
Recipients include regulatory authorities; banks and payment or payroll services; professional advisers and insurers; cloud hosting, artificial-intelligence, messaging and email-delivery providers; web analytics providers; advertising platforms acting under their own terms; and identity and accounting services, and applications such as artificial-intelligence assistants, chosen by users and acting under their own terms. The Privacy Policy describes these disclosures and their purposes.
6.4. Planned transborder flows
Personal information is processed outside South Africa by some of the recipients described in the Privacy Policy. Transfers are subject to Section 72, Protection of Personal Information Act, 2013.
6.5. Security measures
For the Bill platform, measures include encryption in transit and at rest; authentication and access restrictions; backups and recovery; logging and monitoring; and confidentiality obligations for personnel with access to personal information or production systems, as described in the Privacy Policy.
7. How to request access to records
7.1. Requirements and submission
Access requires that the record be needed to exercise or protect a right, compliance with the request procedure and no applicable ground of refusal (Section 50, Promotion of Access to Information Act, 2000).
Submit Form 02, available at inforegulator.org.za/paia-forms or from the Information Officer, by email or post to the contact details in section 1 (Regulation 7, Regulations relating to the Promotion of Access to Information, 2021).
Identify yourself and the record, provide your contact details and the form of access requested, and explain the right you seek to exercise or protect and why the record is needed. If acting for someone else, provide proof of your authority. (Section 53, Promotion of Access to Information Act, 2000).
7.2. Fees
The request fee is R140.00. Reproduction, search and preparation fees may also apply. Contact the Information Officer for payment details (Section 54, Promotion of Access to Information Act, 2000; Annexure B, Regulations relating to the Promotion of Access to Information, 2021).
7.3. Decision and remedies
Except where third-party notification and intervention apply, the company will notify you of its decision as soon as reasonably possible and within 30 days of receiving the request or the required particulars, subject to an extension of no more than 30 additional days in the circumstances permitted by Sections 56 and 57, Promotion of Access to Information Act, 2000. A refusal notice will state the reasons and available remedies.
A complaint about a refusal, fee or extension may be lodged with the Information Regulator within 180 days, using Form 05 at inforegulator.org.za/paia-forms. Complaints may be sent to PAIAComplaints@inforegulator.org.za. There is no internal appeal for a private body (Section 77A, Promotion of Access to Information Act, 2000; Regulation 10, Regulations relating to the Promotion of Access to Information, 2021).
8. Availability
This manual is available at bill.co.za/paia-manual, at the company’s principal place of business (the street address in section 1) for free inspection during normal business hours, to any person on request and to the Information Regulator on request. A reasonable charge may apply for a copy (Section 51(3), Promotion of Access to Information Act, 2000).