PAIA & POPIA Manual

1. Details of the body

2. Information Officer

The Information Officer is responsible for encouraging compliance with PAIA and POPIA within the organisation, and for dealing with requests for access to records and complaints related to the processing of personal information.

3. Guide on how to use PAIA

The South African Human Rights Commission ("SAHRC") has compiled a guide in terms of Section 10 of PAIA. This guide contains information to assist any person who wishes to exercise their right of access to information. The guide is available from the SAHRC at:

4. Records available without a request

The following categories of information are publicly available on our website without submitting a formal PAIA request: information about our products and services (available at looom.co.za/modules); our Privacy Policy (available at looom.co.za/privacy-policy); our Terms of Use (available at looom.co.za/terms); and general contact information (available at looom.co.za/contact).

5. Records held by the body

The following categories of records are held by Bespoke Solutech (Pty) Ltd. Note that the inclusion of a category does not imply that access will automatically be granted — each request is assessed on its merits in accordance with the grounds for refusal set out in PAIA.

5.1 Company records

Memorandum of Incorporation and related statutory documents. Minutes of board meetings and resolutions. Share register and shareholder agreements.

5.2 Financial records

Annual financial statements. Tax returns and SARS correspondence. Banking records and transactional data. Invoices, purchase orders, and supplier agreements.

5.3 Human resources records

Employment contracts. Payroll records and IRP5 certificates. Leave records. Disciplinary records. Skills development and training records.

5.4 Client records

Service agreements and licensing contracts. Client correspondence. Invoicing and billing records. Support and incident logs.

5.5 Operational and IT records

Software development documentation. Information security policies and procedures. System access and audit logs. Business continuity and disaster recovery plans.

5.6 Intellectual property records

Trademark registrations and applications. Copyright records. Trade secrets and proprietary methodology documentation.

6. Processing of personal information (POPIA)

6.1 Purpose of processing

We process personal information for the purposes described in our Privacy Policy, including: responding to enquiries; delivering the Looom platform under contract; managing employment relationships; fulfilling legal and regulatory obligations; and improving our products and services.

6.2 Categories of data subjects

We process personal information relating to the following categories of data subjects: website visitors and prospective clients; employees and contractors; current clients and their authorised users; suppliers and service providers.

6.3 Categories of personal information

Depending on the category of data subject, we may process: names and contact details; identity and tax reference numbers (employees only); employment information; financial and billing information; technical and usage data; and correspondence records.

6.4 Categories of recipients

Personal information may be shared with: employees and contractors of Bespoke Solutech who require access for business purposes; professional advisors (legal, audit, insurance); regulatory authorities and law enforcement where required by law; and service providers under data processing agreements.

6.5 Cross-border transfers

Where personal information is transferred outside South Africa, appropriate safeguards are in place in accordance with Section 72 of POPIA.

6.6 Security measures

We implement appropriate technical and organisational security measures as described in our Privacy & Security page, including encryption, access controls, and incident response procedures.

7. How to request access to records

A request for access to records must be made on the prescribed form (Form C, available from the Information Regulator's website at inforegulator.org.za) and submitted to our Information Officer.

7.1 Submission

Completed forms should be submitted by email to info@looom.co.za with the subject line "PAIA Request".

7.2 Required information

Your request must include: your full name and contact details; sufficient detail to identify the record(s) requested; the form of access required (e.g. inspection, copy); and if requesting on behalf of another person, proof of authorisation.

7.3 Fees

A request fee and, where applicable, an access fee may be payable in accordance with the prescribed fees published by the Information Regulator. You will be notified of any applicable fees before access is provided.

7.4 Response time

We will respond to your request within 30 days of receipt. This period may be extended by a further 30 days if the request requires a search through a large volume of records or consultation with a third party.

7.5 Grounds for refusal

Access to records may be refused on the grounds set out in Chapter 4 of PAIA, including but not limited to: protection of personal information of a third party (Section 63); protection of commercial information (Section 64); protection of confidential information of a third party (Section 65); protection of safety of individuals (Section 66); protection of records privileged from production in legal proceedings (Section 67); and protection of research information of a third party (Section 69).

8. Remedies available if request is refused

If your request for access to a record is refused, you may apply to a court for relief in terms of Section 78 of PAIA. You may also lodge a complaint with the Information Regulator.

9. Data subject requests under POPIA

In addition to the right of access under PAIA, data subjects have the following rights under POPIA: the right to request correction or deletion of personal information; the right to object to the processing of personal information; the right to withdraw consent; and the right to lodge a complaint with the Information Regulator. To exercise any of these rights, please contact our Information Officer at info@looom.co.za.

10. Information Regulator contact details

11. Updates to this manual

This manual will be updated from time to time as required by changes in legislation or our business operations. The date at the top of this page reflects the most recent revision.