Manual under section 51 of the Promotion of Access to Information Act

This manual is published under section 51 of South Africa’s Promotion of Access to Information Act 2 of 2000 (PAIA). It tells a requester what records the SADC Development Finance Resource Centre holds in connection with Digital Learning Academy, how to ask for access to them, what it costs, how long it takes, and what to do if we refuse.

1. Status of this manual

The Centre is established in Gaborone, Botswana, as an institution of the Southern African Development Community. PAIA applies to South African public bodies and to private bodies carrying on a trade, business or profession in South Africa. The Centre serves South African member institutions and processes the personal information of members in South Africa, and publishes this manual so that a South African requester has a clear route to the records we hold, whether or not a court would ultimately classify the Centre as a private body for PAIA purposes.

[TO CONFIRM: a legal opinion on whether the Centre is a “private body” as defined in PAIA given its activities in South Africa, and whether it also has obligations as a public body under any South African instrument. If the Centre is not a private body, this manual stands as a voluntary access procedure and should say so.]

2. Details of the body

3. The Information Regulator’s PAIA guide

Section 10 of PAIA requires the Information Regulator to publish a guide, in each official language, explaining how to use the Act. It is available free of charge from the Regulator, at inforegulator.org.za, and at the Regulator’s offices. A requester who is not sure how to proceed should start there.

4. Records held

The Centre holds the following categories of record in connection with the Platform. Listing a category does not mean every record in it will be released; grounds for refusal are set out in section 9.

• Governance and constitutional records: the instruments establishing the Centre, board and committee papers, policies and delegations.
• Financial records: budgets, funding agreements, audited statements, procurement and supplier contracts.
• Human resources records: employment contracts, personnel files, payroll and training records.
• Agreements with member institutions: participation agreements, programme sponsorships and reporting arrangements.
• Programme and course records: curricula, course content, assessment design, facilitator materials and accreditation correspondence.
• Member records held on the Platform: profile data, enrolments, progress, assessment attempts, credentials, posts, messages, and the technical records described in the Privacy Policy.
• Technical and security records: system documentation, access logs, session and security records, incident reports and supplier contracts for hosting and services.
• Legal and compliance records: this manual, the published policies, consent records, data-subject requests and correspondence with regulators.

5. Records available without a formal request

You do not need to use this procedure for anything already published. Available freely at lms.sadc-dfrc.org and on the Centre’s website:

• the Terms of Service, Privacy Policy, Cookie Policy, Acceptable Use and Community Guidelines, and Data Retention Schedule;
• this manual;
• the public course catalogue and programme descriptions;
• credential verification pages, to anyone holding the verification link.

Members can also see and correct most of their own profile information directly in Settings, which is faster than a request.

6. Records available under other legislation

[TO CONFIRM: whether any records are accessible under other South African legislation, for example tax, companies or labour legislation, given the Centre’s status. If none, this section should state that no records are held that are accessible under other legislation.]

7. How to make a request

To request access to a record:

• complete the prescribed form, Form 2 of the PAIA regulations, being the form for a request for access to a record of a private body;
• give sufficient detail to identify the record and to identify yourself, and give an address, email address or fax number in South Africa to which a decision can be sent;
• state the form of access you want, for example a copy, an inspection, or a transcription;
• state the right you are seeking to exercise or protect, and explain why the record is required to exercise or protect it. This is a requirement of PAIA for records of a private body and a request that omits it will be refused;
• if you are requesting on behalf of someone else, attach proof of your authority;
• send the form to the Information Officer at the email address at the foot of this page. We will acknowledge receipt.

A person who cannot read or write, or who has a disability that prevents them completing the form, may make the request orally to the Information Officer, who will reduce it to writing and give the requester a copy.

8. Fees

PAIA prescribes two kinds of fee for a private body:

• a request fee, payable when the request is made, currently R140.00 for a request to a private body;
• an access fee, covering reproduction, search and preparation time, and postage, calculated at the rates in the regulations;
• where search and preparation will take more than six hours, a deposit of one third of the access fee is payable before we begin;
• a requester seeking access to a record containing their own personal information does not pay a request fee, and no fee is payable by a person whose annual income falls below the threshold in the regulations.

We will tell you the amount payable before doing any chargeable work, and the period for our decision does not start to run until the request fee is paid. [TO CONFIRM: verify the current prescribed request fee, access-fee rates and income thresholds against the PAIA regulations in force at the date of publication, and the bank account or payment method for fees.]

9. Decision, timelines and refusal

We decide within 30 days of receiving a compliant request, and we may extend that by a further 30 days where the request is for a large number of records or requires a search of records held elsewhere. We will tell you before the first 30 days expire if we extend, and why. If we refuse, we will tell you the reason, the provision of PAIA relied on, and how to challenge the refusal.

PAIA requires or permits refusal in defined circumstances, including:

• the record contains personal information about a third party, and disclosure would be unreasonable;
• the record contains commercial information of a third party or of the Centre, such as trade secrets, or financial, commercial, scientific or technical information whose disclosure would harm commercial or financial interests;
• disclosure would breach a duty of confidence owed to a third party;
• disclosure could endanger the life or physical safety of an individual, or prejudice the security of property or a system;
• the record is privileged in legal proceedings, or relates to research whose disclosure would expose the researcher or the subject matter to serious disadvantage;
• the request is manifestly frivolous or vexatious, or the work involved would substantially and unreasonably divert our resources.

Where a record can be released with third-party information removed, we will release it in that form rather than refuse it altogether. Where a record contains a third party’s information, that third party is given notice and an opportunity to make representations before we decide.

10. If you are unhappy with the decision

There is no internal appeal against a decision of a private body under PAIA. A requester who is dissatisfied may lodge a complaint with the Information Regulator, or apply to a court, within the periods set out in the Act. Complaints to the Regulator are made on the prescribed form, Form 5. We will not treat a complaint to the Regulator as a reason to stop dealing with you.

11. Requests about your own personal information

If what you want is your own personal information held on the Platform, the simplest route is the request procedure in section 12 of the Privacy Policy: email the Information Officer, and we respond within 30 days without a fee. POPIA also provides prescribed forms: Form 2 to request access to or correction of your personal information, and Form 1 to object to processing. We accept a request in any of these ways and will not turn one away for being on the wrong form.

12. Information Regulator contact details

The Information Regulator (South Africa):

• JD House, 27 Stiemens Street, Braamfontein, Johannesburg, South Africa
• Telephone: +27 10 023 5200
• General enquiries: enquiries@inforegulator.org.za
• PAIA complaints: PAIAComplaints@inforegulator.org.za
• POPIA complaints: POPIAComplaints@inforegulator.org.za
• Website: inforegulator.org.za

[TO CONFIRM: verify the Regulator’s postal address, telephone number and complaint email addresses against inforegulator.org.za at the date of publication.]

13. Availability of this manual and updates

This manual is available on this page at no charge, and on request from the Information Officer in electronic form. It is reviewed at least annually and whenever the categories of record held change materially. [TO CONFIRM: whether the manual must also be submitted to the Information Regulator, and whether the Centre relies on any exemption from submission currently in force.]

14. Contact

Requests and questions about this manual: SADC-DFRC@socoed.com

Version 1.0 · Effective 14 September 2026