Access to Information Manual

We respect your right of access to information. This document will help you exercise that right as required by section 51 of the Promotion to Access of Information Act 2 of 2000 (PAIA).

Callouts like this are a summary of our manual and contain the most important and relevant points for you. They are here to help you understand it, but please read the full manual.


Who we are
We are RattleHub Digital Ltd, a technology company specializing in the management of personal information, and this is our ‘Access to Information Manual’. Its purpose is to help you access our information and any other information that we have. PAIA requires us to make it available to you so that you:

  • know what types of information we have; and
  • can request access to it.

This manual exists to tell you what information we have and help you get access to it.

What we do
The core purpose of our business is to empower all our customers to confidently organise and manage their personal information. We take the deliberate position to empower digital citizens to own their data through our digital data exchange. In line with our mission statement, we provide a secure and structure platform where people can manage their personal information, and potentially their life, better. The owner of the data consents to the integration of data points from multiple sources via secure open API’s and secondly the sharing of information which enables our platform to automate mundane and boring processes, while facilitating flow in the ever-growing continuous exchange of data. Only the owner of the personal data has the tools and technology to share their data with the chosen partners data points, whilst at the same time the owner of the personal data has a single view of the data specific partners has of them.

Our details
Our details are as follows:

  • Company name: RattleHub Digital Ltd
  • Corporation number: 1049610-3
  • Postal address: Communitech Hub, 151 Charles Str W, Kitchener ON, N2G 1H6, Canada
  • Physical address: Communitech Hub, 151 Charles Str W, Kitchener ON, N2G 1H6, Canada
  • Phone number: +1 (519) 888 9944
  • Information officer: Siobhain O’Mahony
  • Contact email: info@rattlehub.com
  • Website: https://rattlehub.com

These are all our details, but please rather contact us by email at info@rattlehub.com whenever possible.

Further guidance
If you would like further guidance on how you can get access to information under PAIA, you may contact the South African Human Rights Commission (SAHRC) to find out more information about PAIA. They have a guide in each official language of South Africa on how to exercise any right under PAIA. Their contact details are as follows:

For further guidance on how you can get access to information, please contact the SAHRC by visiting their website at http://www.sahrc.org.za/index.php/understanding-paia.

Records we hold
We hold the following subjects and categories of records:

  • Company records;
  • Business records;
  • Financial records;
  • Insurance records;
  • Personnel records;
  • Policies and directives;
  • Agreements or contracts;
  • Regulatory documents;
  • Published information; and
  • Customer information.

We hold various subjects and categories of records in electronic or physical form that are available automatically or in other ways.

Company records
Company records are all our records related to the incorporation and administration of our company. Some of them are available from the Companies and Intellectual Property Commission (CIPC).

Memorandum of incorporation Automatically available from CIPC
Directors’ names Automatically available from CIPC
Documents of incorporation Automatically available from CIPC
Minutes of board of directors’ meetings Not automatically available
Written resolutions Not automatically available
Records relating to appointment of directors, auditor, secretary, public officer, or other officers Not automatically available
Share register and other statutory registers Not automatically available
Other statutory records Not automatically available

Business records
Business records include any documents that have economic value to the business.

Operational records Not automatically available
Published works Not automatically available
Internal correspondence  
Not automatically available
Product records Not automatically available

Financial records
Financial records are all our records related to our finances.

Financial statements Not automatically available (NDA required)
Tax returns Not automatically available
Other documents relating to taxation of the company  
Not automatically available
Accounting records Not automatically available
Banking records Not automatically available
Banking details Automatically available on request
Bank statements Not automatically available
Electronic banking records Not automatically available
Paid cheques Not automatically available
Asset register Not automatically available
Rental agreements Not automatically available
Invoices Not automatically available
Financial agreements Not automatically available

Insurance records
Insurance records are all our records related to our insurable assets.

Insurance policies held by the company Not automatically available
Register of all immovable property owned by the company Not automatically available

Income tax records
Income tax records are all our records related to our income tax obligations.

PAYE records Not automatically available
Corporate tax records Not automatically available
Customs tax Not automatically available
Documents issued to employees for income tax purposes Not automatically available
Records of payments made to SARS on behalf of employees Not automatically available
VAT records Not automatically available
Regional services levies Not automatically available
Skills development levies Not automatically available
UIF Not automatically available
Workmen’s compensation Not automatically available

Personnel records
Personnel records are all our records about anyone who works for us, provides services to us, or provides services on our behalf and who receives or is entitled to receive remuneration, including our employees, contractors, and other personnel.

List of employees Not automatically available
Employee personal information Not automatically available
Employee employment contracts Not automatically available
Employment policies and procedures Not automatically available
Employment equity plan Not automatically available
Medical aid records Not automatically available
Pension and provident fund records Not automatically available
Salaries of employees Not automatically available
Leave records Not automatically available
Internal evaluations Not automatically available
Disciplinary records Not automatically available
Disciplinary codes Not automatically available
Training records Not automatically available
Operating manuals Not automatically available
Personal records provided by personnel Not automatically available
Other statutory records Not automatically available
Related correspondence Not automatically available

Personnel records include records about our employees and contractors.

Policies and directives
Policies and directives include both internal and external documents.

Internal relating to employees and the company Not automatically available
External relating to clients and other third parties Not automatically available
Information technology systems and documents Not automatically available

Agreements or contracts

Agreements or contracts include the documents themselves and all related documents.

Standard agreements Not automatically available
Contracts concluded with customers Not automatically available
NDAs Not automatically available
Letters of Intent, MOUs Not automatically available
Third party contracts (such as JV agreements, VAR agreements, etc.) Not automatically available
Office management contracts Not automatically available
Supplier contracts Not automatically available

Regulatory documents
Regulatory documents include any documents required to comply with any laws.

Permits Not automatically available
Licences Not automatically available
Authorities Not automatically available

Published information
Published information includes any document that we prepare and produce.

External newsletters and circulars Automatically available
Marketing brochures Automatically available
Internal newsletters and circulars Not automatically available
Information on the company published by third parties Not automatically available
Information on our website Automatically available

Customer information
Customer information includes any information about anyone that we provide goods or services to, including our customers, leads, or prospects. The table below describes the customer information we hold in specific categories:

Category Description Automatically available?
Customer basic information This can include identifying information such as your name, date of birth, or any identification document. Not automatically available
Information of related parties This can include identifying information of related parties, such as names, dates of birth, or any identification document Not automatically available
Customer estate information This includes information related to your estate. Not automatically available
Customer profession information This includes information related to your employment, your business, professional qualifications etc. Not automatically available
Investment information This includes information related to any investments you may have. Not automatically available
Accounts information This includes any information related to accounts you may have. Not automatically available
Social information This includes information related to your social interests. Not automatically available
Health information This includes any health-related information. Not automatically available
Communications with customers This includes any communications between us and you. Not automatically available
Transactional information This includes information related to transactions between us and you. Not automatically available

Information we hold to comply with the law
We hold records for the purposes of PAIA in terms of the following main laws, among others:

  • Basic Conditions of Employment Act 75 of 1997;
  • Companies Act 61 of 1973;
  • Companies Act 71 of 2008;
  • Compensation for Occupational Injuries and Disease Act 130 of 1993;
  • Consumer Protection Act 68 of 2008;
  • Electronic Communications and Transactions Act 25 of 2002;
  • Employment Equity Act 55 of 1998;
  • Income Tax Act 58 of 1962;
  • Labour Relations Act 66 of 1995;
  • Occupational Health and Safety Act 85 of 1993;
  • Protection of Personal Information Act 4 of 2013;
  • Skills Development Levies Act 9 of 1999;
  • Unemployment Contributions Act No. 4 of 2002;
  • Unemployment Insurance Act 63 of 2001; and
  • Value Added Tax Act 89 of 1991.

How to request access
We have authorised and designated our information officer to deal with all matters relating to PAIA in order to comply with our obligations in terms of PAIA. To request access to a record, please complete Form C which is available from:

Please submit the completed form to our information officer together with the relevant request fee (details here: http://www.sahrc.org.za/home/21/files/PAIA%20Notice%20on%20fees.pdf) at our information officer’s email address, our physical address, or by fax in terms of our details provided above. Please ensure that the completed form:

  • has enough information for the information officer to identify you, the requested records, and which form of access you require;
  • specifies your email address, postal address, or fax number;
  • describes the right that you seek to exercise or protect;
  • explains why you need the requested record to exercise or protect that right;
  • provides any other way you would like to be informed of our decision other than in writing; and
  • provides proof of the capacity in which you are making the request if you are making it on behalf of someone else (we will decide whether this proof is satisfactory).

If you do not use the standard form, we may:

  • reject the request due to lack of procedural compliance;
  • refuse it if you do not provide sufficient information; or
  • delay it.

You may request information by completing a request for access form and submitting it to our information officer together with a request fee.

Grounds for refusal
We may have to refuse you access to certain records in terms of PAIA to protect:

  • someone else’s privacy;
  • another company’s commercial information;
  • someone else’s confidential information;
  • the safety of individuals and property;
  • records privileged from production in legal proceedings; or
  • research information.

We will notify you in writing whether your request has been approved or denied within 30 calendar days after we have received a completed request for access form. If we cannot find any requested record or it does not exist, then we will notify you by way of affidavit that it is not possible to give access to that particular record.

We may have to refuse you access to a record to protect others.

How we will give you access
We will evaluate and consider all requests to us in terms of PAIA. If we approve your request for access to our records, then we will decide how to provide access to you – unless you have asked for access in a specific form. Publication of this manual does not give rise to any rights to access information records, except in terms of PAIA.

How much it will cost you
You must pay us a request fee as required by law when submitting a request for access to information. The prescribed fees are as set out in the Fee Schedule which is available from http://www.sahrc.org.za/index.php/understanding-paia at this link: http://www.sahrc.org.za/home/21/files/PAIA%20Notice%20on%20fees.pdf. You must pay us the fees before we will hand over any information. You may have to pay a further access fee if we grant the request for any time that has exceeded the prescribed hours to search and prepare the record for disclosure.

How we process and protect personal information
We process the personal information of various categories of people for various purposes as set out in the terms of our Privacy Policy at https://rattlehub.com/privacy-policy.

Other prescribed information
The Minister of Justice and Constitutional Development has not made any regulations prescribing any other information that needs to appear in this manual.

Availability of this Manual
This manual is available in English and will be available on our website, and at our company offices. The manual is also electronically available on our website.

Updates to this Manual
This manual will be updated whenever we make material changes to the current information.