PAIA Manual
This PAIA Manual was last updated on 1 July 2023
Table of contents
Introduction
AutonoSky (Pty) Limited (registration No: 2020/699918/07) is a company incorporated and carrying on business in accordance with the company laws of South Africa (“AutonoSky”);
AutonoSky is an aerial technology solutions company based in Cape Town, South Africa. AutonoSky provides unmanned aviation technology solutions and services to a broad spectrum of clients.
AutonoSky supports the constitutional right of access to information and we are committed to provide you access to our records in accordance with the provisions of the Promotion of Access to Information Act 2 of 2000 ("the Act") and the Protection of Personal Information Act 4 of 2013 (“POPIA”), the confidentiality we owe third parties and the principles of South African privacy law.
Company Contact Details
| Contact: | Amit Ramdath |
| Physical Address: | 11 Mt Pleasant, Rondebosch, 7700 |
| Postal Address: | Suite 148, Private Bag X22, Tygervalley, 7536 |
| Telephone: | +27 (0)82 820 2573 |
| Email: | amit@autonosky.com |
Information Officer Contact Details
| Contact: | Nadia Venter (Information Officer) |
| Street Address: | 2nd Fl, Sable Park, Bridgeways Precinct, Century City, 7446 |
| Postal Address: | Suite 148, Private Bag X22, Tygervalley, 7536 |
| Telephone: | +27 (0)21 492 5184 |
| Email: | compliance@autonosky.com |
The Manual
Introduction to the Manual
- This Manual has been compiled to meet the requirements of the Act, as applied in conjunction with POPIA. The goal is to give effect to the constitutional right of individuals to access information held by a private body (in this case, AutonoSky), if the information is required for the exercise or protection of that individual's rights.
- Such right of access to information is subject to justifiable limitations for the reasonable protection of privacy, commercial confidentiality, and effective, efficient good governance, balancing the right to information against other rights. If a public body lodges a request, the public body must be acting in the public interest.
- This Manual is available at autonosky.com, and at the physical address specified in paragraph 2 above.
- Requests for information in terms of the Act must be made in accordance with the procedures prescribed in this Manual and accompanied by the prescribed fees.
- The South African Human Rights Commission ("SAHRC") has compiled a guide in terms of Section 10 of the Act which gives advice on how to exercise your rights (“Guide”). This Guide is available from the SAHRC at:
Postal Address:Private Bag 2700, Houghton, 2041Telephone Number:+27-11-877 3600Fax Number:+27-11-403 0625Website:www.sarhc.org
Purpose for processing data
- AutonoSky takes the privacy and protection of personal information very seriously and will limit the personal information processed to only that to which you consent and which is necessary for our legitimate business interests and process it in strict accordance with current South African privacy legislation.
- AutonoSky processes personal information for a variety of purposes, including, but not limited to the following:
- to provide any information, products, services, or support requested by data subjects;
- to help identify data subjects when they contact AutonoSky;
- to maintain customer records;
- to securely transmit the data of data subjects for the purpose of providing services to AutonoSky customers;
- for recruitment, internship, and employment purposes;
- for travel purposes;
- for general administration, financial, and tax purposes;
- for legal or contractual purposes;
- for health and safety purposes;
- to monitor access, and ensure the security of AutonoSky’s premises and assets;
- to transact with suppliers and business partners;
- to help AutonoSky:
- improve the quality of its products and services;
- detect and prevent fraud and money laundering;
- debts;
- to carry out analysis and customer profiling; and
- to identify other products and services which might be of interest to data subjects and to inform them about our products and services.
Categories of Data Subjects
- AutonoSky processes the personal information of a number of types of subjects, for various reasons, including the following:
Data Subjects Type of personal information processed Employees and potential employees - demographic information
- health and disability information
- employment contracts
- performance and disciplinary matters
- payroll
- physical access and monitoring
- training
- employment history
- criminal history
- background checks
- time and attendance
- correspondence
Customers and Potential Customers - demographic information of (potential) customers and their representatives
- contracts
- contact details
- banking details
- credit record
- account history
- correspondence
- customer information (exclusively for contracted support, hosting or back-up purposes)
Suppliers - demographic information of suppliers and their representatives
- banking details
- account history
- product and service information
- contracts
- correspondence
Categories of Data recipients
- AutonoSky may share the personal information of our data subjects for the purposes outlined above with the following kinds of recipients:
- AutonoSky employees;
- service providers and agents who perform services on AutonoSky’s behalf;
- third parties as described below.
- AutonoSky does not share the personal information of data subjects with third parties unless:
- a data subject has consented thereto;
- obliged to do so for legal or regulatory purposes, or in connection with legal proceedings; or
- it necessary to provide or improve a product or service for which a data subject has contracted with AutonoSky;
- If required to share a data subject's private information with a third party as specified above, AutonoSky shall notify the data subject of such disclosure.
- AutonoSky’s employees are required to adhere to AutonoSky’s data privacy and confidentiality policies, and are trained in this regard.
Transfer of Your Personal Information out of South Africa
- AutonoSky subcontracts the hosting of data (including personal information) to third parties located in countries other than South Africa with the prior consent of data subjects. AutonoSky will, in these cases, ensure that standard contractual clauses are agreed upon with these parties so as to ensure protection of your Personal Information.
Information security measures
- AutonoSky implements appropriate information technology security measures to protect all data, including personal information, processed by AutonoSky. Such protection includes but is not limited to encryption, back-ups, anti-virus and anti-malware protection, redundancy, and disaster recovery plans.
- AutonoSky implements its technical and organisational security measures to protect the integrity, security, and accessibility of data processed by it. Any third parties with whom AutonoSky interacts for the provision of such services are required to be bound by legislation similar to that in South Africa regarding the protection of personal information, or alternatively be bound by agreements which bind them to an equivalent level of competency and care.
Applicable Legislation
| No. | Act |
|---|---|
| 1. | Basic Conditions of Employment Act 75 of 1997 |
| 2. | Broad-based Black Economic Empowerment Act 53 of 2003 |
| 3. | Companies Act 71 of 2008 |
| 4. | Electronic Communications and Transactions Act 25 of 2002 |
| 5. | Employment Equity Act 55 of 1998 |
| 6. | Income Tax Act 58 of 1962 |
| 7. | Labour Relations Act 66 of 1995 |
| 8. | Occupational Health Act 61 of 2003 |
| 9. | Promotion of Access to Information Act 2 of 2000 |
| 10. | Skills Development Act 97 of 1998 |
| 11. | Skills Development Levies Act 9 of 1999 |
| 12. | Unemployment Insurance Contributions Act 4 of 2002 |
| 13. | Value Added Tax Act 89 of 1991 |
Schedule of Records
AutonoSky has under its control or in its possession the following categories of records under the subjects described below. The categories of records are not exhaustive and are subject to amendment.
| Record Type | Subject | Access Level |
|---|---|---|
| Business | CIPC records (including company registration, officers, intellectual property) | 1,2 |
| audited financial statements | 4 | |
| tax records | 2 | |
| asset register | 4 | |
| statutory records | 2 | |
| internal policies and procedures | 2 | |
| financial records | 4 | |
| product development information | 4 | |
| management planning information, budgets | 4 | |
| information technology system records | 4 | |
| information technology disaster recovery and implementation plans | 4 | |
| Marketing | product information | 1 |
| manuals | 2 | |
| media releases | 1 | |
| company website | 1 | |
| marketing plans | 4 | |
| Personnel | personal information provided by personnel | 3 |
| personal information provided by third parties | 4 | |
| employment contracts | 4 | |
| internal evaluation, performance management and disciplinary records | 3 | |
| statutory records regarding UIF, PAYE, B-BBEE, EE, Health and Safety | 2,3 | |
| correspondence with and about personnel | 3,4 | |
| training schedules and material | 2,3 | |
| remuneration records | 3,4 | |
| facilities management documentation | 2 | |
| Legal | agreements and memoranda of understanding | 4 |
| litigation records | 4 | |
| legal opinions | 4 | |
| legal correspondence | 4 | |
| Customer | personal information provided by customers about their businesses and representatives | 3 |
| customer contracts | 4 | |
| customer databases (including personal information of customers' customers) | 3,4 | |
| credit records | 3 | |
| account records | 3 | |
| correspondence with and about customers | 3,4 | |
| Suppliers & Contractors | personal information provided by suppliers and contractors | 3 |
| contracts | 4 | |
| accounting records | 3 |
Key to record access levels
| Access Level | Classification | Description |
|---|---|---|
| 1 | Sharable | Unrestricted availability |
| 2 | Confidential | Administrative records relating to the running of the business with little interest or value to outside parties, to which outside parties may be granted limited access, depending on the circumstances. |
| 3 | Controlled | Personal information of an individual or juristic person requested by the data subject of that information. |
| 4 | Restricted | Legally privileged document, or document likely to harm an individual, compromise the safety of individuals or property, or harm the commercial or financial interests of the company or a third party. |
Request for Access to Information
To be granted access to a record referred to in paragraph 5 above, please complete the request form included as Schedule 1 hereto and address your request to the Information Officer at the details given in paragraph 2 above and submit it to compliance@bytorbit.com.
Details of the fees payable and the payment procedure will be provided by the Information Officer once the request has been received.
Please complete all fields in the request form, ensuring that you provide us with the following information:
- Details of the record that you are requesting;
- A copy of your valid South African ID document or card;
- A copy of the power of attorney (if applicable);
- A description of the right you seek to exercise or protect, with an explanation of the reason the record is required to exercise or protect the right;
- Details of how the information requested must be provided to you if the request is granted; and
- Your contact details.
Fees
When the Information Officer of AutonoSky receives a request on the official form for information in terms of the Act, the Information Officer will send the requester (other than a personal requester) a notice requiring the requester to pay the prescribed request fee of R50.00 before further processing the request.
A further access/reproduction fee will be payable before the requested record is released. The fee is calculated in accordance with the prescribed rates set out in schedule 2, taking access/reproduction costs, search and preparation time, and postal costs (if relevant).
If preparation of the record requested will take more than six hours, a deposit of one third of the access fee will be payable in advance of provision of the record, with the balance payable on delivery.
The Information Officer will provide the details of the account into which the payment must be made on the invoice for the access/reproduction fee.
Timelines for Consideration
Once received, AutonoSky will assess your request and your request will be processed within 30 (thirty) days, unless the request contains considerations that are of such a nature that an extension of the 30-day time limit is needed. If an extension is necessary, you will be notified with reasons for the extension.
If the Information Officer fails to communicate a decision on a request, such a request is then deemed to have been refused.
Grounds for Refusal of Access to Records
The main grounds on which AutonoSky may refuse access to records relate to:
- the privacy of a third party who is a natural person;
- the commercial information of a third party;
- confidential information of a third party;
- the safety of individuals and property;
- legally privileged records; and
- commercial information of AutonoSky, which may include without limitation:
- trade secrets;
- financial, commercial, scientific or technical information, the disclosure of which would likely harm the financial or commercial interests of AutonoSky;
- information that, if disclosed, could put AutonoSky at a disadvantage in negotiations or commercial competition;
- computer programs and related information technology software that are owned by AutonoSky and that are protected by copyright; and
- research information compiled by AutonoSky or a third party, if disclosure would expose the third party, researcher or subject matter of the research and therefore seriously disadvantage AutonoSky.
Requests submitted in terms of the Protection of Personal Information Act, 4 of 2013, may be refused on the same grounds set out above.
Remedies Available
AutonoSky does not have any internal appeal procedures that may be followed once a request to access information has been refused. The decision of the Information Officer is final. If you are not satisfied with the outcome of your request, you can apply to the Information Regulator for relief.
Schedule 1: Access Request Form
Download the form here.
Schedule 2: Fees
The following schedule lays out the fees associated with a request for information.
| Request | Fee (Ex VAT) |
|---|---|
| For every photocopy of an A4-sized page or part thereof | R1.50 |
| For every printed copy of an A4-sized page or part thereof held electronically | R2.00 |
| For a copy in a computer-readable form on a flash drive | R100.00 |
| For a transcription of visual images for an A4-sized page or part thereof | R40.00 |
| For a copy of a visual image | R60.00 |
| For a transcription of an audio record per A4-sized page or part thereof | R20.00 |
| For a copy of an audio record | R30.00 |
| To search for and prepare the record for disclosure | R50.00 per hour or part thereof |
