PAIA Manual

CONTENTS

1. Background to the Promotion of Access to Information Act

2. SUBMITT

3. Purpose of the PAIA Manual

4. Contact Details of the Directors (section 51(1)(a))

5. The Information Officer (section 51(1)(b))

6. Guide on How to Use the Act

7. The Latest Notice in Terms of Section 52(2) (if any)

8. Records Available Only on Request to Access in Terms of the Act (section 51(1)(d))

9. Records Available Without a Request to Access in Terms of the Act

10. Records Available in Terms of Any Other Legislation

11. Processing of Personal Information (Protection of Personal Information Act 4 of 2013)

12. Request Procedure

13. Refusal of Access to Records

14. Remedies Available When SUBMITT Refuses a Request

15. Access to Records Held by SUBMITT

16. Fees

17. Reproduction Fees

18. Decision

19. Availability and Updating of the PAIA Manual

Annexure - Prescribed Request Form

1. BACKGROUND TO THE PROMOTION OF ACCESS TO INFORMATION ACT

1.1 The Promotion of Access to Information Act, No 2 of 2000 (“the Act”) was enacted on 3 February 2000, giving effect to the constitutional right in terms Section 32 of the Bill of Rights contained in the Constitution of the Republic of South Africa 108 of 1996 (“the Constitution”) of access to any information held by the State and any information that is held by another person and that is required for the exercise or protection of any rights.

1.2 In terms of section 51 of the Act, all private bodies are required to compile a manual (“PAIA Manual”). Section 52 deals separately with the voluntary disclosure of categories of records which are automatically available without a request.

1.3 Where a request is made in terms of the Act, the body to whom the request is made is obliged to release the information, subject to applicable legislative and / or regulatory requirements, except where the Act expressly provides that the information may or must not be released. The Act sets out the relevant procedure to be adopted when requesting information from a Public or a Private Body.

2. SUBMITT

Submitt Medical Accounts (Pty) Ltd (“Submitt”) is a South African company that operates Submitt.App, a software application designed to assist medical practitioners, medical practices and medical billing bureaux with the administrative preparation and management of medical claims.

Submitt.App provides functionality through which users may capture, process and manage patient and claims-related information, including medical aid information, billing information, ICD-10 codes and other information required in connection with medical claims. The Application may also facilitate the transmission of claims and claims-related information to a medical billing bureau selected by the relevant Customer.

The Application incorporates automated information-extraction functionality using Amazon Textract, an Amazon Web Services (“AWS”) service, to assist in extracting specified information from images uploaded through the Application. Such information may include a medical aid name, medical aid membership number and a patient’s identification number. Information extracted through the automated functionality remains subject to human verification by the Customer or its authorised users.

Submitt is a technology and administrative service provider and does not provide medical or clinical services. Submitt does not diagnose or treat patients, provide medical advice, determine appropriate medical treatment, or assume responsibility for the professional or clinical decisions of medical practitioners or the billing decisions of medical billing bureaux.

In providing Submitt.App, Submitt may process Personal Information on behalf of its Customers. Customers generally determine the purposes for which Patient Information is processed and remain responsible for their obligations under applicable data protection legislation. To the extent that Submitt processes such information on behalf of a Customer, Submitt acts as an operator in accordance with the Customer’s lawful instructions.

Submitt uses third-party technology and infrastructure providers in providing the Services, including AWS and Amazon Textract, and may facilitate integrations with third-party systems such as GoodX and medical billing bureaux.

Submitt’s business therefore principally comprises the provision and operation of a software-as-a-service platform for the administration and processing of medical claims and related information, together with the technical and support services necessary to operate that platform.

(Hereinafter “SUBMITT”)

2.1 This PAIA Manual is relevant and is available to view in person at the premises of SUBMITT: Mooikloof Office Park, West Block, Block 7, Cnr Atterbury Road and Jollify Main Road, Mooikloof, Pretoria, 0081 as well as on its website: https://www.submitt.app

3. PURPOSE OF THE PAIA MANUAL

3.1 This PAIA Manual is intended to ensure that SUBMITT complies with the Act and to foster a culture of transparency and accountability with SUBMITT by giving effect to the right to information that is required for the exercise or protection of any right and to actively promote a society in which the people of South Africa have effective access to information to enable them to exercise and protect their rights.

3.2 In order to promote effective governance of private bodies, it is necessary to ensure that everyone is empowered and educated to understand their rights in terms of the Act in order for them to exercise their rights in relation to Public and Private Bodies.

3.3 Section 9 of the Act recognizes that the right to access information cannot be unlimited and should be subject to justifiable limitations, including, but not limited to:

3.3.1 Limitations aimed at the reasonable protection of privacy;

3.3.2 Commercial confidentiality; and

3.3.3 Effective, efficient and good governance; and

3.3.4 In a manner which balances that right with any other rights, including such rights contained in the Bill of Rights in the Constitution.

3.4 This PAIA Manual has been drafted in accordance with section 51 of the Act and the Regulations made under it, having regard to the guidance published by the Information Regulator for private bodies.

3.5 In addition, this PAIA Manual complies with the requirements of section 51 of the Act and recognises that under the Protection of Personal Information Act 4 of 2013, that the appointed Information Officer will be responsible to regulate compliance with the Act and its Regulations by Public and Private Bodies.

4. CONTACT DETAILS OF THE DIRECTORS (SECTION 51(1)(a))

5. THE INFORMATION OFFICER (SECTION 51(1)(b))

5.1 The Act prescribes the appointment of an Information Officer for Public Bodies where such Information Officer is responsible to, inter alia, assess requests for access to information. The Head of a Private Body fulfills such a function in terms of Section 51. SUBMITT has opted to appoint an Information Officer to assess requests for access to information as well as to oversee its required functions in terms of the Act.

5.2 The Information Officer appointed in terms of the Act also refers to the Information Officer as referred to in the Protection of Personal Information Act 4 of 2013. The Information Officer oversees the functions and responsibilities as required for in terms of both this Act as well as the duties and responsibilities in terms of Section 55 of the Protection of Personal Information Act 4 of 2013 after registering with the Information Regulator.

5.3 The Information Officer may appoint, where it is deemed necessary, Deputy Information Officers, as allowed in terms of Section 17 of the Act as well as Section 56 of the Protection of Personal Information Act 4 of 2013. This is in order to render SUBMITT as accessible as reasonably possible for requesters of its records and to ensure fulfillment of its obligations and responsibilities as prescribed in terms of Section 55 of the Protection of Personal Information Act 4 of 2013. All requests for information in terms of the Act must be addressed to the Information Officer.

Contact Details of the Information Officer

6. GUIDE ON HOW TO USE THE ACT

6.1 Section 10 of the Act provides for a guide to be compiled on how to use the Act. With effect from 30 June 2021 the functions of the South African Human Rights Commission under the Act were transferred to the Information Regulator, and the Guide is compiled and published by the Information Regulator.

6.2 The Guide contains such information as may reasonably be required by a person who wishes to exercise any right contemplated in the Act, and accordingly it:

6.2.1 contains information on understanding and how to use the Act;

6.2.2 includes the objectives of the Act, particulars of every public and private body, the manner and form for requests, and the contents of the Regulations made under the Act; and

6.2.3 is updated and published from time to time.

6.3 The Guide is available in each of the official languages of the Republic of South Africa.

6.4 The Guide may be obtained from the Information Regulator, and any enquiry regarding the Guide should be directed to the Information Regulator at the details below.

7. THE LATEST NOTICE IN TERMS OF SECTION 52(2) (IF ANY)

At this stage no notice(s) has/have been published on the categories of records that are automatically available without a person having to request access in terms of the Act.

8. RECORDS AVAILABLE ONLY ON REQUEST TO ACCESS IN TERMS OF THE ACT (SECTION 51(1)(d))

8.1 This clause serves as a reference to the categories of information that SUBMITT holds. The information is classified and grouped according to records relating to the following subjects and categories:

8.2 Personnel Records

8.2.1 Personal records provided by personnel.

8.2.2 Records provided by a third party relating to personnel.

8.2.3 Conditions of employment and other personnel-related contractual and quasi-legal records.

8.2.4 Internal evaluation records and other internal records.

8.2.5 Correspondence relating to personnel.

8.2.6 Training scheduled and material.

“Personnel” refers to any person who works for, or provides services to or on behalf of SUBMITT, and receives or is entitled to receive remuneration and any other person who assists in carrying out or conducting the business of SUBMITT. This includes, without limitation, directors (executive and non-executive), all permanent, temporary and part-time staff, as well as contract workers.

8.3 Customer Related Records

8.3.1 Records provided by a customer to a third party acting for or on behalf of SUBMITT.

8.3.2 Records provided by a third party.

8.3.3 Records generated by or within SUBMITT relating to its customers, including transactional records.

“Customer” refers to any natural or juristic entity that receives services from SUBMITT.

8.4 Private Body Records

8.4.1 Financial records

8.4.2 Operational records

8.4.3 Databases

8.4.4 Information Technology

8.4.5 Marketing records

8.5 Internal Correspondence

8.5.1 Product records

8.5.2 Statutory records

8.5.3 Internal Policies and Procedures

8.5.4 Records held by officials of the institution

These records include, but are not limited to, the records which pertain to SUBMITT’s own affairs.

8.6 Other Party Records

8.6.1 Personnel, customer or private body records which are held by another party, as opposed to the records held by SUBMITT itself.

8.6.2 Records held by SUBMITT pertaining to other parties, including without limitation, financial records, correspondence, contractual records, records provided by the other party, and records third parties have provided about the contractors/suppliers.

8.6.3 SUBMITT may possess records pertaining to other parties, including without limitation contractors, suppliers, subsidiary/holding/sister companies, joint venture companies, and service providers. Alternatively, such other parties may possess records that can be said to belong to SUBMITT.

8.7 Note that the accessibility of the records may be subject to the grounds of refusal set out in this PAIA Manual. Amongst others, records deemed confidential on the part of a third party, will necessitate permission from the third party concerned, in addition to normal requirements, before SUBMITT will consider access.

9. RECORDS AVAILABLE WITHOUT A REQUEST TO ACCESS IN TERMS OF THE ACT

9.1 Records of a public nature, typically those disclosed on the SUBMITT’s website and in its various annual reports, may be accessed without the need to submit a formal application.

9.2 Other non-confidential records, such as statutory records maintained at CIPC, may also be accessed without the need to submit a formal application, however, please note that an appointment to view such records will still have to be made with the Information Officer.

10. RECORDS AVAILABLE IN TERMS OF ANY OTHER LEGISLATION

10.1 Where applicable to its operations, SUBMITT also retains records and documents in terms of the legislation listed below. Unless disclosure is prohibited in terms of legislation, regulations, contractual agreement or otherwise, records that are required to be made available in terms of these Acts shall be made available for inspection by interested parties in terms of the requirements and conditions of the Act and applicable internal policies and procedures, should such interested parties be entitled to such information. A request to access must be done in accordance with the prescriptions of such Act.

10.2 It is further recorded that the accessibility of documents and records may be subject to the grounds of refusal set out in this PAIA Manual.

11. PROCESSING OF PERSONAL INFORMATION (PROTECTION OF PERSONAL INFORMATION ACT 4 OF 2013)

11.1 In addition to the requirements of the Act, this PAIA Manual records the following particulars of the processing of personal information by SUBMITT, as contemplated in the Protection of Personal Information Act 4 of 2013 (“POPIA”).

11.2 SUBMITT processes personal information for the following purposes:

11.2.1 the provision, operation, administration, security and support of Submitt.App;

11.2.2 the capture, extraction and processing of information required for the preparation, management and submission of medical claims;

11.2.3 the administration of Customer accounts, subscriptions and billing;

11.2.4 communication with Customers and their authorised users;

11.2.5 the detection, prevention and investigation of fraud, misuse and security incidents; and

11.2.6 compliance with legal and regulatory obligations.

11.3 The categories of data subjects, and of the personal information relating to them, are:

11.3.1 Customers and their authorised users: name, contact details, practice number, login credentials and account and subscription information;

11.3.2 patients of Customers: name, identity number, medical aid name and membership number, billing and ICD-10 codes and other information appearing on the documentation uploaded through the Application;

11.3.3 personnel of SUBMITT: the records described in clause 8.2; and

11.3.4 suppliers and service providers: contact and contractual details.

11.4 Personal information may be supplied to the following categories of recipients:

11.4.1 Amazon Web Services, including Amazon Textract, in respect of hosting and the automated extraction of information from uploaded images;

11.4.2 Teamgeek, in respect of the development, operation and support of the Application and the administration of the hosting environment;

11.4.3 GoodX, in respect of the integration through which claims are created;

11.4.4 the medical billing bureau nominated by the relevant Customer;

11.4.5 Stripe, in respect of subscription payments; Sentry, in respect of error and diagnostic reporting; AWS Amplify, in respect of usage analytics; and Expo, in respect of the distribution of application updates;

11.4.6 SUBMITT’s professional advisors, auditors and insurers; and

11.4.7 a court, regulator or other authority, where disclosure is required by law.

11.5 Personal information is processed and stored outside the Republic of South Africa. In particular, SUBMITT uses Amazon Web Services infrastructure in the European Union (eu-west-1). Where personal information is transferred outside the Republic, SUBMITT takes reasonable steps to ensure that the transfer and subsequent processing are undertaken in accordance with section 72 of POPIA.

11.6 SUBMITT employs appropriate technical and organisational measures to secure the integrity and confidentiality of personal information in its possession or under its control, including access controls, authentication measures, system monitoring, cloud infrastructure security, and backup and recovery measures. Every person who has access to uploaded documents or patient information is bound by a written undertaking of confidentiality, and operators are engaged under written agreements as contemplated in section 21 of POPIA.

11.7 In respect of patient information processed through the Application, SUBMITT acts as an operator on behalf of the Customer, which remains the responsible party. SUBMITT is the responsible party in respect of the personal information it processes for its own purposes, including Customer account, subscription and personnel information.

11.8 In addition to the recipients referred to in clause 11.4, SUBMITT uses Google Cloud Platform, specifically Google Cloud Run, hosted in the africa-south1 region, in respect of certain application-hosting and data-processing infrastructure used to provide the Services.

11.9 The Application processes data received from authorised requests and does not intentionally persist or permanently store such data within the application container or the Google Cloud Run environment referred to in clause 11.8. That environment is used primarily for processing and transmitting data between authorised systems. Any data temporarily held in application memory during processing is not intended to constitute permanent data storage.

12. REQUEST PROCEDURE

12.1 Procedural Requirements

12.1.1 The requester must comply with all the procedural requirements contained in the Act relating to the request for access to a record.

12.1.2 The requester must complete the prescribed form enclosed herewith, and submit same as well as payment of a request fee and a deposit (if applicable) to the Information Officer or the Deputy Information Officer at the postal or physical address, fax number or electronic mail address as noted in clause 5 above.

12.1.3 The prescribed form must be filled in with sufficient information to enable the Information Officer to identify:

12.1.3.1 the record or records requested; and

12.1.3.2 the identity of the requester.

12.1.4 The requester should indicate which form of access is required and specify a postal address or fax number of the requester in the Republic;

12.1.5 The requester must state that he/she requires the information in order to exercise or protect a right, and clearly state what the nature of the right is so to be exercised or protected. The requester must clearly specify why the record is necessary to exercise or protect such a right (Section 53(2)(d)).

12.1.6 SUBMITT will process the request within 30 (thirty) days, unless the requester has stated special reasons to the satisfaction of the Information Officer that circumstances dictate that the above time periods not be complied with.

12.1.7 The requester shall be advised whether access is granted or denied in writing. If, in addition, the requester requires the reasons for the decision in any other manner, the requester will be obliged to state which manner and the particulars required.

12.1.8 If a request is made on behalf of another person, then the requester must submit proof of the capacity in which the requester is making the request to the reasonable satisfaction of the Information Officer (Section 53(2)(f)).

12.1.9 If an individual is unable to complete the prescribed form because of illiteracy or disability, such a person may make a request orally.

12.1.10 The requester must pay the prescribed fee, before any further processing can take place.

12.1.11 All information as listed in clause 12.1 should be provided, failing which the process will be delayed until the required information is provided. The prescribed time periods will not commence until the requester has furnished all the necessary and required information. The Information officer shall sever a record, if possible, and grant only access to the portion requested and which is not prohibited from being disclosed.

13. REFUSAL OF ACCESS TO RECORDS

A Private Body such as SUBMITT is entitled to refuse a request for information.

13.1 The main grounds for SUBMITT to refuse a request for information relates to the:

13.1.1 mandatory protection of the privacy of a third party who is a natural person or a deceased person (Section 63) or a juristic person, as included in the Protection of Personal Information Act 4 of 2013, which would involve the unreasonable disclosure of personal information of that natural or juristic person;

13.1.2 mandatory protection of personal information and for disclosure of any personal information to, in addition to any other legislative, regulatory or contractual agreements, comply with the provisions of the Protection of Personal Information Act 4 of 2013;

13.1.3 mandatory protection of the commercial information of a third party (Section 64), if the record contains:

13.1.3.1 trade secrets of the third party;

13.1.3.2 financial, commercial, scientific or technical information which disclosure could likely cause harm to the financial or commercial interests of the third party;

13.1.3.3 information disclosed in confidence by a third party to SUBMITT, if the disclosure could put that third party at a disadvantage in negotiations or commercial competition;

13.1.4 mandatory protection of confidential information of third parties (Section 65) if it is protected in terms of any agreement;

13.1.5 mandatory protection of the safety of individuals and the protection of property (Section 66);

13.1.6 mandatory protection of records which would be regarded as privileged in legal proceedings (Section 67).

13.2 The commercial activities (Section 68) of a Private Body, such as SUBMITT, which may include:

13.2.1 trade secrets of SUBMITT;

13.2.2 financial, commercial, scientific or technical information which disclosure could likely cause harm to the financial or commercial interests of SUBMITT;

13.2.3 information which, if disclosed could put SUBMITT at a disadvantage in negotiations or commercial competition;

13.2.4 a computer program which is owned by SUBMITT, and which is protected by copyright;

13.2.5 the research information (Section 69) of SUBMITT or a third party, if its disclosure would disclose the identity of SUBMITT, the researcher or the subject matter of the research and would place the research at a serious disadvantage.

13.3 Requests for information that are clearly frivolous or vexatious, or which involve an unreasonable diversion of resources shall be refused.

13.4 All requests for information will be assessed on their own merits and in accordance with the applicable legal principles and legislation.

13.5 If a requested record cannot be found or if the record does not exist, the Information Officer shall, by way of an affidavit or affirmation, notify the requester that it is not possible to give access to the requested record. Such a notice will be regarded as a decision to refuse a request for access to the record concerned for the purpose of the Act. If the record should later be found, the requester shall be given access to the record in the manner stipulated by the requester in the prescribed form, unless the Information Officer refuses access to such record.

14. REMEDIES AVAILABLE WHEN SUBMITT REFUSES A REQUEST

14.1 Internal Remedies

SUBMITT does not have an internal appeal procedure. The decision made by the Information Officer is final. Requesters will have to exercise such external remedies at their disposal if the request for information is refused, and the requestor is not satisfied with the answer supplied by the Information Officer.

14.2 External Remedies

14.2.1 A requester or third party who is dissatisfied with a decision of the Information Officer may lodge a complaint with the Information Regulator in terms of Part 4 of Chapter 1 of the Act. A complaint must be lodged in the form, and within the period, prescribed by the Act and the Regulations made under it. The contact details of the Information Regulator are set out in clause 6.

14.2.2 A requester or third party may also apply to a court for appropriate relief, as provided in the Act.

14.2.3 A requestor that is dissatisfied with the Information Officer’s decision to grant a request for Information, may within 30 (thirty) days of the notification of the decision, apply to a Court for relief.

14.2.4 A third party dissatisfied with the Information Officer’s decision to grant a request for information, may within 30 (thirty) days of notification of the decision, apply to a Court for relief.

For purposes of the Act, the Courts that have jurisdiction over these applications are the Constitutional Court, the High Court or another Court of similar status and a Magistrate’s Court designated by the Minister of Justice and Constitutional Development and which is presided over by a designated Magistrate.

15. ACCESS TO RECORDS HELD BY SUBMITT

15.1 Prerequisites for Access by Personal/Other Requester

15.1.1 Records held by SUBMITT may be accessed by requests only once the prerequisite requirements for access have been met.

15.1.2 A requester is any person making a request for access to a record of SUBMITT. There are two types of requesters:

15.1.3 Personal Requester

15.1.3.1 A personal requester is a requester who is seeking access to a record containing personal information about the requester.

15.1.3.2 SUBMITT will voluntarily provide the requested information, or give access to any record with regard to the requester’s personal information. The prescribed fee for reproduction of the information requested will be charged.

15.1.4 Other Requester

15.1.4.1 This requester (other than a personal requester) is entitled to request access to information on third parties.

15.1.4.2 In considering such a request, SUBMITT will adhere to the provisions of the Act. Section 71 requires that the Information Officer take all reasonable steps to inform a third party to whom the request record relates of the request, informing him/her that he/she may make a written or oral representation to the Information Officer why the request should be refused or, where required, give written consent for the disclosure of the information.

SUBMITT is not obliged to voluntarily grant access to such records. The requester must fulfil the prerequisite requirements, in accordance with the requirements of the Act and as stipulated in Chapter 5; Part 3, including the payment of a request and access fee.

16. FEES

16.1 Fees Provided by the Act

16.1.1 The Act provides for two types of fees, namely:

16.1.1.1 A request fee, which is a form of administration fee to be paid by all requesters except personal requesters, before the request is considered. The request fee is not refundable; and

16.1.1.2 An access fee, which is paid by all requesters in the event that a request for access is granted. This fee is inclusive of costs involved by the Private Body in obtaining and preparing a record for delivery to the requester.

16.1.2 When the request is received by the Information Officer, such officer shall by notice require the requester, other than a personal requester, to pay the prescribed request fee, before further processing of the request (Section 54(1)).

16.1.3 If the search for the record has been made and the preparation of the record for disclosure, including arrangement to make it available in the requested form, requires more than the hours prescribed in the regulations for this purpose, the Information Officer shall notify the requester to pay, as a deposit, the prescribed portion of the access fee which would be payable if the request is granted.

16.1.4 The Information Officer shall withhold a record until the requester has paid fees as indicated below.

16.1.5 A requester whose request for access to a record has been granted, must pay an access fee that is calculated to include, where applicable, the request fee, the process fee for reproduction and for search and preparation, and for any time reasonably required in excess of the prescribed hours to search for and prepare the record for disclosure including making arrangements to make it available in the request form.

16.1.6 If a deposit has been paid in respect of a request for access, which is refused, then the Information officer concerned must repay the deposit to the requester.

17. REPRODUCTION FEES

17.1 The fees payable under the Act are those prescribed in the Regulations made under the Act, as amended from time to time. The amounts set out below are those prescribed in Annexure B to the Regulations Relating to the Promotion of Access to Information, 2021, published under Government Notice R.757 in Government Gazette 45057 of 27 August 2021. Where the prescribed fees are amended, the amended fees apply and this PAIA Manual will be updated accordingly.

17.2 Where SUBMITT has voluntarily provided the Minister with a list of categories of records that will automatically be made available to any person requesting access thereto, the only charge that may be levied for obtaining such records is a fee for reproduction of the record in question.

17.3 Request Fees

A requester who is not a personal requester must pay a request fee of R140.00 before the request is further processed. The request fee is not refundable.

17.4 Access Fees

17.4.1 An access fee is payable in all instances where a request for access to information is granted, except in those instances where payment of an access fee is specifically excluded in terms of the Act or an exclusion is determined by the Minister in terms of section 54(8).

17.4.2 The access fee comprises the reproduction fees set out above, together with the following:

17.5 Deposits

17.5.1 Where the Information Officer, on receipt of a request for access to information held on a person other than the requester, is of the opinion that the search for and preparation of the record for disclosure will take more than 6 (six) hours, a deposit is payable by the requester.

17.5.2 The amount of the deposit is equal to 1/3 (one third) of the amount of the applicable access fees.

17.5.3 If a deposit has been paid in respect of a request which is refused, the Information Officer must repay the deposit to the requester.

17.6 Payment

17.6.1 All fees must be paid into a bank account nominated in writing by SUBMITT, and proof of payment must be sent to the Information Officer at the details set out in clause 5, together with the request form and any supporting documents.

17.7 All fees are subject to amendment as provided for in the Act, and such amendments may not always be immediately reflected in this PAIA Manual. A requester will be informed of the fees payable before any payment is made.

18. DECISION

18.1 Time Allowed to Institution

18.1.1 SUBMITT will within 30 (thirty) days of receipt of the request, decide whether to grant or decline the request and give notice with reasons (if required) to that effect.

18.1.2 The 30 (thirty) day period within which SUBMITT has to decide whether to grant or refuse the request, may be extended for a further period of not more than 30 (thirty) days if the request is for a large number of information, or the request requires a search for information held at another office and the information cannot reasonably be obtained within the original 30 (thirty) day period.

18.1.3 SUBMITT will notify the requester in writing should an extension be sought.

19. AVAILABILITY AND UPDATING OF THE PAIA MANUAL

19.1 Availability

19.1.1 This PAIA Manual is made available in terms of section 51 of the Act and the Regulations Relating to the Promotion of Access to Information, 2021, published under Government Notice R.757 in Government Gazette 45057 of 27 August 2021, which replaced the Regulations of 2002. SUBMITT will update this PAIA Manual at such intervals as may be necessary.

19.1.2 This PAIA Manual of SUBMITT is available to view at its premises as aforesaid as well as on its website https://www.submitt.app

ANNEXURE - PRESCRIBED REQUEST FORM

A request for access to a record of SUBMITT must be made on the form prescribed by the Regulations made under the Act.

The prescribed form is Form 2, Request for Access to Record, prescribed by regulation 7 of the Regulations Relating to the Promotion of Access to Information, 2021, published under Government Notice R.757 in Government Gazette 45057 of 27 August 2021. Those Regulations replaced the Regulations of 2002, and the earlier Form C is no longer the prescribed form.

A request must be made in a form that corresponds substantially with Form 2, and must be delivered to the Information Officer at the address, or sent to the e-mail address, set out in clause 5.

Download Form 2 - Request for Access to Record (PDF)

Form 2, and the Guide compiled by the Information Regulator, may also be obtained from the Information Regulator at www.inforegulator.org.za, or from SUBMITT on request to the Information Officer.