Promotion of Access to Information Act
Promotion of Access to Information Act, 2000 (Act No. 2 of 2000)
Manual published in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 (as amended), describing who we are, the records we hold, how to request access to a record, and how personal information is processed.
Draft — required information outstanding
PAIA Manual is not ready for final publication until all [REQUIRED] fields have been completed and legally reviewed. Items marked [REQUIRED: …] in this manual have not yet been confirmed by the business, and are deliberately shown as placeholders rather than invented details.
This manual is published in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA), as amended, to assist any person who wishes to exercise a right under PAIA in relation to records held by Lifestyle Calculator.
It has been prepared using the structure recommended by the Information Regulator (South Africa) for a private body, and describes:
Access to records is not automatic. Every request is considered in terms of PAIA and may be granted, partially granted or refused on the grounds permitted or required by the Act and other applicable law.
Lifestyle Calculator is an online financial modelling and educational platform operating in South Africa through the website listed in this manual. Users capture their own figures and the platform models and explains aspects of their financial position.
The platform allows a user to model and understand:
Lifestyle Calculator is not a bank, financial institution, financial adviser, credit provider, insurer, investment provider or debt counsellor, and does not hold itself out as any of these. It is an educational financial modelling tool. Its calculations, scores, benchmarks, projections and recommendations are general and educational, and do not constitute personalised financial, investment, tax, legal or credit advice.
| Item | Detail |
|---|---|
| Legal entity name | [REQUIRED: INSERT LEGAL ENTITY NAME] |
| Trading name | Lifestyle Calculator |
| Registration number | [REQUIRED: INSERT COMPANY REGISTRATION NUMBER] |
| Registered address | [REQUIRED: INSERT REGISTERED / PHYSICAL ADDRESS] |
| Principal place of business | [REQUIRED: INSERT REGISTERED / PHYSICAL ADDRESS] |
| Website | https://mylifestylecalc.com |
| Telephone | [REQUIRED: INSERT TELEPHONE NUMBER] |
| General email | [REQUIRED: INSERT GENERAL CONTACT EMAIL] |
| Information Officer | [REQUIRED: INSERT INFORMATION OFFICER NAME] |
| Information Officer email | [REQUIRED: INSERT INFORMATION OFFICER EMAIL] |
| Email for PAIA requests | [REQUIRED: INSERT PAIA REQUEST EMAIL] |
| Deputy Information Officer | None appointed at the date of this manual |
Any item shown above as [REQUIRED: ...] has not yet been confirmed by the business. It must be completed before this manual is treated as final. No company particulars are invented for the purposes of this manual.
The Information Officer is responsible for dealing with requests for access to records under PAIA, and for the duties of an Information Officer in terms of POPIA, including responding to data subjects who wish to exercise their privacy rights.
| Item | Detail |
|---|---|
| Name | [REQUIRED: INSERT INFORMATION OFFICER NAME] |
| [REQUIRED: INSERT INFORMATION OFFICER EMAIL] | |
| Telephone | [REQUIRED: INSERT TELEPHONE NUMBER] |
| Postal address | [REQUIRED: INSERT POSTAL ADDRESS] |
| Physical address | [REQUIRED: INSERT REGISTERED / PHYSICAL ADDRESS] |
| Deputy Information Officer | None appointed at the date of this manual |
| Registration status with the Regulator | [REQUIRED: CONFIRM REGISTRATION STATUS] |
All PAIA requests must be directed to the Information Officer using the process described in section 9 of this manual. Requests relating to personal information under POPIA (access, correction, deletion, objection, withdrawal of consent or a complaint) may be submitted to the same Information Officer, or through the data-rights request form on the website.
The Information Regulator (South Africa) has published a Guide, in terms of section 10 of PAIA, explaining how to exercise a right under the Act. The Guide is available free of charge from the Regulator, and we do not republish or host our own copy of it.
A copy of the Guide may also be requested from the Regulator directly at enquiries@inforegulator.org.za or +27 10 023 5200.
The following categories of records may be held. Listing a category does not mean that a record in that category will be released; access remains subject to PAIA.
A. Corporate and administrative records
B. Financial records
C. Human resources records
D. User and account records
E. User financial modelling information
F. Financial Help and lead records
G. Technical, analytics and security records
Website analytics on this platform are first-party and anonymous: visitor and session identifiers are hashed and no financial figures or account identifiers are recorded in the analytics records.
The following records are published on the website and are available without a PAIA request, free of charge, and without needing to register or sign in:
Records containing personal information, confidential business information, third-party information or internal operational information are not automatically available and must be requested in terms of PAIA.
Records that are not automatically available may be requested in terms of PAIA. Access is not automatic and is subject to:
To request access to a record, a requester should:
The current prescribed form is published by the Information Regulator and can be downloaded from https://inforegulator.org.za/wp-content/uploads/2020/07/InfoRegSA-PAIA-Form02-Reg7.pdf. A request may also be started using the PAIA request form on this website, which records the request in our PAIA register and routes it to the Information Officer; the prescribed form and supporting documents remain required.
PAIA and its regulations allow a private body to charge a prescribed request fee and prescribed access fees for the reproduction, preparation and, where applicable, postage of records.
Where a fee is payable, the requester will be informed in writing of the amount payable, calculated in accordance with the applicable prescribed tariff, before the record is made available, and may lodge an internal or other remedy in respect of that decision as the Act allows. Where a request relates to a person's own personal information, the fee position provided for in the Act and its regulations applies.
Lifestyle Calculator does not publish its own invented tariff. The prescribed fees published in terms of PAIA apply.
A decision on a request must ordinarily be made, and the requester notified, within 30 days of receipt of the request. That period may be extended in the circumstances permitted by PAIA, in which case the requester will be notified in writing of the extension and the reasons for it.
Where a request affects a third party, the Act's third-party notification and representation periods apply before a decision is made. Where the record requested is required for the protection of the life or physical safety of a person, PAIA provides for a shorter response period.
The periods and procedures set out in PAIA and its regulations, as amended from time to time, are the authoritative source. Nothing in this manual shortens, extends or replaces them.
Access to a record may be refused, in whole or in part, where PAIA permits or requires refusal. Grounds include:
This list is a summary and not an exhaustive legal opinion. The applicable provisions of PAIA determine whether access may or must be refused, and whether the public-interest override in the Act applies.
Where a requested record contains information relating to a third party, the notification, representation and decision procedures in PAIA apply. Lifestyle Calculator will take the steps required by law before releasing information that relates to, or was supplied by, a third party, including notifying that third party where the Act requires it and allowing the third party to make representations.
Another user's personal information and another user's financial modelling information are never released merely because a request has been submitted.
PAIA deals with access to records. POPIA deals with how personal information is processed and protected. The two Acts are related but separate, and a request under one is not automatically a request under the other. This manual includes the information about the processing of personal information that is relevant to a PAIA manual; the full detail is set out in the Privacy Policy and POPIA Notice on the website.
Categories of personal information actually processed by the platform include:
The platform does not require or invite special personal information as defined in POPIA (such as health, biometric, religious, political or trade-union information), and does not knowingly collect the personal information of children. Users are asked not to submit information of that nature through free-text fields.
Personal information is processed for the following purposes:
Personal information may be made available to the following categories of recipient, in each case only to the extent necessary:
The Financial Help partner network is still being built. No user information has been shared with a financial partner, and no partner has been matched to any request. Information will only be shared with a partner in accordance with the applicable privacy notice, the user's consent and the law.
[REQUIRED: VERIFY WHETHER PERSONAL INFORMATION IS TRANSFERRED OUTSIDE SOUTH AFRICA AND IDENTIFY THE RELEVANT PROVIDERS/COUNTRIES BEFORE FINAL PUBLICATION.]
[REQUIRED: CONFIRM THE SECTION 72 BASIS FOR EACH CROSS-BORDER TRANSFER, AND THAT EACH OPERATOR AGREEMENT IS SIGNED, BEFORE FINAL PUBLICATION.]
Lifestyle Calculator implements reasonable technical and organisational measures designed to protect personal information against loss, damage, unauthorised access, interference, modification, disclosure or destruction.
Measures actually implemented on the platform include:
Lifestyle Calculator does not claim any security certification, accreditation or third-party audit standard. No system can be guaranteed to be completely secure.
Records and personal information are retained only for as long as is reasonably necessary for the purposes for which they were collected, unless a longer retention period is required or permitted by law. The retention periods currently configured by the business are:
A user may delete their information through the platform or by contacting the Information Officer, subject to any records we are legally required to keep.
Subject to POPIA and other applicable law, a data subject may:
These requests can be submitted through the data-rights request form on the website, or directly to the Information Officer. The Privacy Policy and POPIA Notice explain each right in more detail.
A requester who is aggrieved by a decision — including a refusal of access, a decision on fees, a decision to extend the response period, or a failure to respond — may apply to a court for appropriate relief in terms of PAIA, and may lodge a complaint with the Information Regulator on the prescribed form.
| Item | Detail |
|---|---|
| Regulator | Information Regulator (South Africa) |
| Website | https://inforegulator.org.za/ |
| Address | 27 Stiemens Street, Braamfontein, Johannesburg, 2001 (P.O. Box 31533, Braamfontein, Johannesburg, 2017) |
| Telephone | +27 10 023 5200 |
| PAIA complaints | PAIAComplaints@inforegulator.org.za |
| POPIA complaints | POPIAComplaints@inforegulator.org.za |
| General enquiries | enquiries@inforegulator.org.za |
These are the Regulator's published details. Please confirm them against the Regulator's website, which is the authoritative source, before submitting a complaint.
| Record category | Examples | Automatically available? | Request required? |
|---|---|---|---|
| Published policies and website content | PAIA Manual, Privacy Policy, Terms & Conditions, disclaimers, educational content | Yes | No |
| Corporate and administrative records | Registration documents, internal policies, contracts, supplier records | No | Yes |
| Financial records | Accounting records, invoices, financial statements, tax records | No | Yes |
| Human resources records | [REQUIRED: CONFIRM WHETHER ANY HUMAN RESOURCES RECORDS ARE HELD] | No | Yes |
| A user's own account records | Profile details, verification status, preferences, support history | Partly — visible in the user's own account | Yes, for anything not shown in the account |
| A user's own financial modelling records | Income, expenses, debts, assets, savings, goals, results and snapshots | Partly — visible in the user's own account | Yes, for anything not shown in the account |
| Financial Help / lead records | Request details, category, consent record, status history | Partly — the user's own requests are shown in the app | Yes |
| Technical, analytics and security records | Anonymous session and usage records, error logs, audit logs | No | Yes, subject to the grounds for refusal |
| Third-party records | Records containing another person's or business's information | No | Yes, subject to the third-party procedures in PAIA |
This manual is reviewed periodically and updated whenever there is a material change to the business, the records held, the Information Officer, the way personal information is processed, or the applicable law. Superseded versions are retained in our internal compliance records.
| Item | Detail |
|---|---|
| Version | 1.0 |
| Effective date | [REQUIRED: INSERT EFFECTIVE DATE] |
| Last reviewed / updated | [REQUIRED: INSERT LAST UPDATED DATE] |
| Next review | [REQUIRED: INSERT NEXT REVIEW DATE] |
This PAIA Manual is intended to provide information about access to records held by Lifestyle Calculator. It does not replace the Promotion of Access to Information Act, the Protection of Personal Information Act, applicable regulations, or other applicable law. It is not legal advice.
The publication of this manual does not mean that Lifestyle Calculator is certified, accredited or approved by any regulator, and it does not constitute a representation that every applicable legal requirement has been met.