1. Introduction
The Promotion of Access to Information Act 2 of 2000 (PAIA) gives effect to the constitutional right of access to information held by the state and by private bodies, where that access is required for the exercise or protection of any rights. Section 51 of PAIA requires every private body to compile and make available a manual describing the records it holds and the procedure to request access to those records.
This manual is published by Seventh Son Consulting Services (Pty) Ltd (SSCS), the entity that develops and operates the ActiviTrack platform.
2. Company Details
- Legal name
- Seventh Son Consulting Services (Pty) Ltd
- Registration number
- 2023/888982/07
- Business address
- Johannesburg, Gauteng, South Africa
- Postal address
- Johannesburg, Gauteng, South Africa
- info@sscservices.co.za
- Website
- https://app.sscservices.co.za
3. Information Officer
In terms of section 1 of PAIA and section 55 of POPIA, SSCS has appointed an Information Officer (IO) responsible for:
- Ensuring compliance with PAIA and POPIA within SSCS.
- Processing requests for access to records.
- Cooperating with the Information Regulator.
Seventh Son Consulting Services (Pty) Ltd
Email: info@sscservices.co.za
The IO is registered with the Information Regulator in terms of section 55 of POPIA.
4. Records Held by SSCS
SSCS holds the following categories of records. Not all records are accessible on request — access depends on whether a ground of refusal applies under PAIA.
Service agreements, statements of work, purchase orders, correspondence relating to client engagements, and invoices.
ActiviTrack user accounts, workforce profiles, clock-in/out records, geospatial progress data, and facial recognition enrollment records (where applicable). These are held on behalf of the client responsible party.
Employment contracts, CVs, payroll records, leave records, and performance-related documentation for SSCS employees and contractors.
Bank statements, tax records, and accounting documentation. Retained for the periods required by SARS and the Companies Act.
MOI, shareholder register, director resolutions, and CIPC filings.
System logs, incident records, security audit trails, and data processing documentation maintained for POPIA compliance.
Records relating to third parties may be withheld in whole or in part where disclosure would constitute an unreasonable infringement of that party's privacy (section 63 of PAIA).
5. How to Request Access to Records
To request access to a record held by SSCS, a requester must submit a completed PAIA Form C to the Information Officer. The form is available for download below and from the Information Regulator's website.
Information Officer, Seventh Son Consulting Services (Pty) Ltd
Email: info@sscservices.co.za
Subject line: PAIA Access Request — [Your Name]
What to include
- Your full name, contact details, and identity number.
- A description of the record(s) you are requesting.
- The right you are seeking to exercise or protect, and why access is required.
- Your preferred form of access (copy, inspection, etc.).
- Proof of identity (copy of ID document).
Timeframes
SSCS will respond within 30 days of receiving a valid request. This period may be extended by a further 30 days where the records are voluminous or the request requires searching multiple repositories. You will be notified of any extension.
Fees
A request fee may apply in accordance with the PAIA Regulations. Access fees depend on the form of access (pages printed, time taken to search, etc.). Indigent requesters may apply for a fee waiver. Fees are waived where the requester seeks access to their own personal information.
6. Grounds for Refusal
SSCS may refuse a request on grounds set out in sections 62–70 of PAIA. Common grounds include:
- Third-party personal information (s63) — disclosure would unreasonably infringe another person's privacy.
- Commercial information (s64) — disclosure would harm SSCS's commercial or financial interests, or reveal trade secrets.
- Research information (s65) — premature disclosure would be likely to expose to disadvantage the person carrying out the research.
- Legally privileged information (s67) — records subject to legal professional privilege.
Where a request is refused in whole or in part, SSCS will provide written reasons for the refusal and advise you of your right to appeal.
7. Appeals & Complaints
If you are dissatisfied with a decision to refuse access, you may:
- Lodge an internal appeal with the Information Officer within 60 days of receiving the refusal decision.
- Lodge a complaint with the Information Regulator in terms of section 74 of PAIA.
- Apply to the High Court for relief in terms of section 78 of PAIA.
Website: www.inforegulator.org.za
Email: enquiries@inforegulator.org.za
Tel: 010 023 5200
8. PAIA Forms
The following forms are prescribed under PAIA. They are available for download from the Information Regulator's website at www.inforegulator.org.za.
| Form | Purpose | When to use |
|---|---|---|
| Form C | Request for access to records of a private body | Submit this to SSCS when requesting access to any record |
| Form D | Notice of decision regarding access to records | SSCS will use this form to communicate its decision to you |
| Form E | Internal appeal against a decision | If you wish to appeal a refusal decision by the Information Officer |
9. Other Applicable Legislation
SSCS also processes personal information and maintains records in compliance with, among others: the Protection of Personal Information Act 4 of 2013 (POPIA), the Companies Act 71 of 2008, the Income Tax Act 58 of 1962, the Basic Conditions of Employment Act 75 of 1997, the Labour Relations Act 66 of 1995, and the Electronic Communications and Transactions Act 25 of 2002 (ECTA). See also our POPIA Compliance and Legal Disclosure pages.