Promotion of Access to Information Act Manual.

This manual is published by Smart Home Connect (Pty) Ltd (the "Company") in terms of Section 51 of the Promotion of Access to Information Act 2 of 2000 ("PAIA"), read with the Protection of Personal Information Act 4 of 2013 ("POPIA").

It sets out the categories of records held by the Company, the procedure for requesting access to those records, and the contact details of the Information Officer.

• Registered name: Smart Home Connect (Pty) Ltd
• Type of business: Licensed WISP, fibre and technology services provider
• Regulator: Independent Communications Authority of South Africa (ICASA)
• Postal / physical address: available on request
• Telephone: 067 002 5664
• Email: info@smarthomeconnect.co.za

The Head of the Company for purposes of PAIA and the appointed Information Officer for purposes of POPIA is David Vorster.

All PAIA requests, POPIA data-subject requests and information queries must be directed to the Information Officer at davidvor@gmail.com or info@smarthomeconnect.co.za.

The South African Human Rights Commission (SAHRC) has compiled a guide, in terms of Section 10 of PAIA, containing information to assist a person wishing to exercise a right of access to information.

The guide is available in each of the official languages from the SAHRC:

• Postal: Private Bag X2700, Houghton, 2041
• Telephone: +27 (11) 877 3600
• Website: sahrc.org.za

Records held in terms of other legislation

• Companies Act 71 of 2008 — statutory company records
• Income Tax Act 58 of 1962 — tax and VAT records
• Labour Relations Act 66 of 1995 — employee records
• Basic Conditions of Employment Act 75 of 1997
• Electronic Communications Act 36 of 2005 — ICASA licence and network records
• RICA 70 of 2002 — subscriber verification records
• POPIA 4 of 2013 — personal information processing records
• Consumer Protection Act 68 of 2008

Records held by the Company

• Customer records: contact details, addresses, RICA documents, service agreements
• Billing records: invoices, payments, statements
• Network records: IP allocations, connection logs, uptime and fault data
• Support records: tickets, correspondence, on-site visit reports
• CCTV records held on behalf of customers (customer-owned)
• Employee and contractor records
• Financial, tax and statutory records
• Marketing and website analytics records

The following records are available without needing to submit a formal PAIA request:

• Marketing material published on our website
• Service plans, pricing and coverage information
• Compliance and privacy notices at /compliance
• A customer's own account, billing and service records on request

1. Complete the prescribed PAIA Form 02 (Request for Access to Record of Private Body) issued under the PAIA Regulations.
2. Submit the completed form to the Information Officer by email to davidvor@gmail.com.
3. Provide sufficient particulars to enable the Company to identify the record and the requester, and specify the form of access required.
4. Where the request is made on behalf of another person, provide proof of the capacity in which the request is made.
5. Pay the applicable request and access fees as prescribed in the PAIA Regulations. A requester seeking their own personal information is not required to pay the request fee.

The Company will respond within 30 days of receipt of a valid request, subject to extension as permitted by Section 57 of PAIA.

Access to a record may be refused on the grounds set out in Chapter 4 of Part 3 of PAIA, including but not limited to:

• Mandatory protection of the privacy of a third-party natural person
• Mandatory protection of commercial information of a third party
• Mandatory protection of confidential information of a third party
• Mandatory protection of the safety of individuals and the protection of property
• Protection of records privileged from production in legal proceedings
• Commercial activities of the private body
• Research information of a third party or of the private body

A requester who is dissatisfied with the response to a PAIA request may lodge a complaint with the Information Regulator or apply to a court for appropriate relief in terms of Section 78 of PAIA.

• Information Regulator (South Africa)
• JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
• Email: PAIAComplaints@inforegulator.org.za
• Website: inforegulator.org.za

The Company processes personal information in accordance with the eight conditions of lawful processing under POPIA. Personal information is collected directly from data subjects where practicable and used only for the purposes disclosed at collection or as permitted by law.

Data subjects have the right to access, correct and request deletion of their personal information, and to object to processing, by contacting the Information Officer.