1. Purpose of this manual
Section 32 of the Constitution gives everyone the right of access to information held by another person where it is required to exercise or protect a right. The Promotion of Access to Information Act 2 of 2000 (“PAIA”) gives effect to that right.
Section 51 of PAIA requires every private body to have a manual, available at its principal place of business and on its website. The exemption that once relieved smaller private bodies of that duty expired on 31 December 2021. From 1 January 2022 no private body is exempt.
This manual tells you what we hold, how to ask for it, what it costs, how long we take, when we may refuse, and what you can do about it.
2. The companies this manual covers
| Flexifusions (Pty) Ltd | Debi Bridge (Pty) Ltd | |
|---|---|---|
| Registration number | 2008/014266/07 | 2022/722151/07 |
| Product | Click2Pay | Click2Pay |
| Nature of business | Third-Party Payment Provider - DebiCheck, EFT credit and EFT debit collections, sponsored by Absa Bank Limited | Third-Party Payment Provider - credit and debit card, sponsored by Absa Bank Limited |
| Physical address | 51 Ingersol Road, Lynnwood Glen, Pretoria, Gauteng, 0081 | 51 Ingersol Road, Lynnwood Glen, Pretoria, Gauteng, 0081 |
| Postal address | 51 Ingersol Road, Lynnwood Glen, Pretoria, Gauteng, 0081 | 51 Ingersol Road, Lynnwood Glen, Pretoria, Gauteng, 0081 |
| Telephone | +27 12 330 2142 / +27 12 330 2144 | +27 83 209 0827 |
| Website | www.click2pay.co.za | www.click2pay.co.za |
| Information Officer | Marcin Jacek Bizior | Marcin Jacek Bizior, Director |
| Deputy Information Officer(s) | None designated | None designated |
| Email for PAIA requests | enquiries@click2pay.co.za | enquiries@click2pay.co.za |
Under PAIA the head of a private body that is a company is its chief executive officer or equivalent officer, or the person acting as such, and under POPIA that person is the Information Officer. The role may also be held by a person the body designates and authorises to carry out those duties. Both companies have appointed the same Information Officer, so one person answers for both: for Debi Bridge he holds the role as its director, and for Flexifusions he holds it by designation. Address a request to the company that holds the record; if you are not sure which does, send it to the email address above and we will tell you.
3. The Guide published by the Information Regulator
Section 10 of PAIA requires the Information Regulator to publish a guide, in each official language, on how to use the Act. It explains the objects of the Act, how to lodge a complaint, and the remedies available. It is available from:
The Information Regulator (South Africa)
54 Maxwell Drive, Woodmead, Johannesburg, 2191
Telephone 010 023 5200 · Toll-free 0800 017 160
enquiries@inforegulator.org.za · inforegulator.org.za (opens in a new tab)
4. Records available without a request
4.1 Notice under section 52(2)
Neither company has submitted a notice to the Minister under section 52(2) of PAIA describing categories of records automatically available without a request.
4.2 Records we publish anyway
These are on our website free of charge and need no request:
- Our website terms of use
- Our privacy policy
- This manual
- Product, service and contact information
5. Records we hold, by category
This describes the subjects on which we hold records and the categories within each, as section 51(1)(e) requires. Being listed here does not mean a record will be released - section 9 below sets out the grounds on which we must or may refuse.
| Subject | Categories of record |
|---|---|
| Company secretarial | Memorandum of incorporation, CIPC registrations and filings, share register, director and officer registers, minutes and resolutions |
| Financial | Annual financial statements, management accounts, audit files, banking records, tax returns and assessments, VAT records, asset register |
| Merchant and client | Applications, identity verification files including copies of merchants' and their directors' identity documents, merchant agreements and annexures, suretyships, correspondence, support tickets, credit and risk assessments |
| Payment and transaction | Collection instructions and their results, mandates and mandate authentication records, settlement files and reports, unpaid and dispute records, chargeback files, reserve and holdback records |
| Regulatory and compliance | Payment-system registrations, sponsoring bank correspondence, card scheme registrations, sanctions screening records, POPIA records including this manual |
| Employee | Employment contracts, personnel files, payroll and PAYE, leave, disciplinary and grievance records, training, health and safety, employment equity, skills development |
| Supplier and procurement | Supplier contracts, service level agreements, operator agreements, purchase orders, invoices |
| Information technology | System architecture and configuration, access control and user records, security policies, incident records, business continuity and disaster recovery plans, software licences, penetration test and vulnerability reports |
| Insurance | Policies, schedules, claims |
| Legal | Litigation files, legal opinions, correspondence with attorneys, intellectual property registrations |
| Marketing | Marketing material, website content, campaign records, consent and opt-out records |
6. Records available under other legislation
Some records are available, or must be given, under other statutes. Those routes stand alongside PAIA and are often faster.
Basic Conditions of Employment Act 75 of 1997 · Companies Act 71 of 2008 · Compensation for Occupational Injuries and Diseases Act 130 of 1993 · Consumer Protection Act 68 of 2008 · Electronic Communications and Transactions Act 25 of 2002 · Employment Equity Act 55 of 1998 · Financial Intelligence Centre Act 38 of 2001 · Income Tax Act 58 of 1962 · Labour Relations Act 66 of 1995 · National Payment System Act 78 of 1998 · Occupational Health and Safety Act 85 of 1993 · Pension Funds Act 24 of 1956 · Protection of Personal Information Act 4 of 2013 · Skills Development Act 97 of 1998 · Tax Administration Act 28 of 2011 · Unemployment Insurance Act 63 of 2001 · Value-Added Tax Act 89 of 1991
7. How to request a record
7.1 The form
Use Form 2 - Request for Access to Record of Private Body, prescribed by regulation 7 of the PAIA Regulations. It is available from the Information Regulator at inforegulator.org.za (opens in a new tab), and from our Information Officer on request.
A request that is not on Form 2 is not a valid PAIA request and we cannot process it as one.
7.2 What the form must contain
- Enough particulars to let us identify the record, and to identify you
- The form of access you want - inspection, a copy, or a transcription
- Your postal or email address in the Republic
- The right you are seeking to exercise or protect, and why the record is required to exercise or protect it. This is a substantive requirement of section 50(1)(a), not a formality - a request that does not identify a right will be refused.
- Whether you want to be told of the decision in a manner other than in writing, and if so how
- If you are asking on someone else's behalf, proof of the capacity in which you do so
7.3 Where to send it
By email to enquiries@click2pay.co.za, or by post or delivery to the physical address of the company concerned in section 2.
7.4 What it costs
Two fees can arise. Both are prescribed by Annexure B to the PAIA Regulations, 2021 (GN R.757, Government Gazette 45057 of 27 August 2021) - we may not charge more, current as at publication.
A request fee, payable before we process the request: R140.00. A personal requester - someone asking for a record about themselves - pays no request fee.
An access fee, payable before the record is released:
| Item | Amount |
|---|---|
| Photocopy or printed copy of an A4 page, or part of a page | R2.00 |
| Copy in computer-readable form, on a flash drive you supply | R40.00 |
| Copy in computer-readable form, on a CD we supply | R60.00 |
| Transcription of an audio record, per A4 page | R24.00 |
| Transcription of visual images | Outsourced - charged at the quoted amount |
| Search and preparation, per hour or part of an hour, excluding the first hour | R145.00 |
| Maximum search and preparation charge | R435.00 |
| Postage, email or other electronic transfer | Actual cost |
Where we estimate that search and preparation will exceed six hours, we require a deposit of one third of the access fee before we begin. If access is then refused, the deposit is repaid.
We send you a written estimate before you incur an access fee, and you may withdraw the request rather than pay it.
7.5 How long we take
We must decide within 30 days of receiving the request. We may extend that once, by a further 30 days, where the request covers a large number of records or searching them would unreasonably interfere with running the business - we will tell you in writing before the first 30 days expire, and give reasons.
If we do not respond within the period, the request is regarded as refused.
7.6 What we will tell you
We tell you in writing whether access is granted, what fee is payable, and in what form access will be given. If we refuse, we give adequate reasons, identify the provisions of PAIA we rely on, and tell you that you may complain to the Information Regulator or apply to a court, and how.
8. Third parties
Where a record contains information about someone else, PAIA requires us to take reasonable steps to tell them and give them an opportunity to make representations before we decide. We will tell you if that is happening, because it affects the timetable.
9. When we may refuse
Chapter 4 of Part 3 of PAIA sets out the grounds. Some are mandatory and some discretionary. In summary, access must or may be refused where the record contains:
- Personal information about a third party who is a natural person, where disclosure would be unreasonable
- Trade secrets, or financial, commercial, scientific or technical information of a third party, where disclosure would be likely to harm their commercial or financial interests
- Information supplied in confidence by a third party, where disclosure would put us in breach of a duty of confidence
- Information whose disclosure could reasonably be expected to endanger the life or physical safety of an individual, or prejudice the security of property or a system
- Records privileged from production in legal proceedings
- Our own trade secrets or commercial information, where disclosure would be likely to harm us
- Research information of a third party or of ours, where disclosure would be likely to expose the researcher or the subject matter to serious disadvantage
The public-interest override. PAIA requires disclosure despite most of those grounds where the record would reveal a substantial contravention of the law, or an imminent and serious public-safety or environmental risk, and the public interest in disclosure clearly outweighs the harm the ground protects. We apply that override on its own terms; it is not ours to waive.
Where only part of a record may be withheld, we release the rest.
10. If you are not satisfied
There is no internal appeal against the decision of a private body. Your remedies are:
Complain to the Information Regulator. Use Form 5 - Lodging of a Complaint, prescribed by regulation 10, available from the Regulator.
The Information Regulator (South Africa)
54 Maxwell Drive, Woodmead, Johannesburg, 2191
Telephone 010 023 5200 · Toll-free 0800 017 160
PAIAComplaints@inforegulator.org.za
Apply to court. You may apply to a court for appropriate relief. A court may grant any order that is just and equitable, including ordering release of the record, and may make a costs order.
11. How we process personal information
PAIA requires this summary. For information collected through this website, see our privacy policy; merchants' collection data is governed by the merchant agreement.
| Categories of data subject | Website visitors and enquirers; merchants and their directors, members, trustees, beneficial owners and authorised signatories; payers whose accounts our merchants collect from; employees and job applicants; suppliers and their staff |
|---|---|
| Categories of personal information | Identifying and contact information; identification numbers and documents; bank account and tokenised card references; mandate and authentication records; transaction, unpaid and dispute records; employment and payroll records; online identifiers and usage information |
| Purpose of processing | Providing collection, settlement and reporting services; identification and verification; sanctions screening; fraud, dispute and collection-conduct monitoring; regulatory and payment-system reporting; billing; support; employment administration |
| Recipients | The sponsoring bank; the payment clearing house and clearing infrastructure; card schemes; paying and receiving banks; the card processor; verification and screening providers; hosting and support operators; professional advisers; regulators, law enforcement and the courts |
| Cross-border transfers (information collected through this website) | The website is hosted in South Africa, with xneelo. The one transfer of website information outside the Republic is to Calendly, LLC (United States), which processes demonstration bookings on our behalf where you choose to book through it - see section 6 of our privacy policy. |
| Security measures | Appropriate, reasonable technical and organisational measures, as POPIA s19 requires |
12. Availability and updating of this manual
This manual is available:
- On this website, free of charge
- At the principal place of business of each company, for inspection during business hours
- From the Information Officer on request, at the prescribed copying fee
- To the Information Regulator
We review it at least annually, and whenever our particulars, our record categories or the prescribed fees change.