PAIA Manual (Section 51)

PAIA Manual (Section 51) — HomeForPaws

Prepared in terms of the Promotion of Access to Information Act, 2 of 2000 (PAIA) (as amended)

Private Body PAIA Manual (Section 51)

Trading name: HomeForPaws

Owner / Operator: Samuel Fourie (individual / sole proprietor)

1) List of acronyms and abbreviations

• PAIA — Promotion of Access to Information Act, 2 of 2000
• POPIA — Protection of Personal Information Act, 4 of 2013
• Information Officer (IO) — The designated person responsible for PAIA/POPIA compliance for the private body
• Regulator — The Information Regulator (South Africa)

2) Contact details of the Information Officer

Information Officer: Sam Fourie — Information Officer

Private body: HomeForPaws

Location: Pretoria, Gauteng, South Africa

Email (PAIA & POPIA requests): sam@homeforpaws.co.za

Website: homeforpaws.co.za

3) The PAIA Guide (how to use PAIA)

The Information Regulator has published a guide to assist persons who wish to exercise their rights under PAIA. The guide explains how to submit a request for access to records and what procedures apply.

You may contact the Information Regulator for assistance with the PAIA Guide and related guidance.

4) Records automatically available (Section 52)

No records are automatically available without a formal PAIA request.

5) Records available in terms of other legislation

Records are retained and made available in accordance with applicable South African law. Where applicable, HomeForPaws retains records for lawful business operations, contractual purposes, and compliance and recordkeeping requirements.

6) Description of records held by HomeForPaws

The following categories of records are held by HomeForPaws. The categories below are described at a high level and do not guarantee that every record is held in every case.

6.1 Corporate and operational records

• Business contact and correspondence records
• Service administration records
• Operational and security logs
• Internal policies and procedures (where applicable)
• Records relating to compliance with legal obligations

6.2 Platform user and account records

• User registration records (including shelters and applicants/adopters)
• Account and access management records (roles and permissions)
• Authentication and account security events (where applicable)

6.3 Billing and subscription records (shelters)

• Subscription status and billing administration records
• Payment references and payment status records (note: card details are not stored by HomeForPaws)

6.4 Shelter Records processed on behalf of shelters

HomeForPaws provides software used by shelters and animal welfare organisations. As part of providing the service, HomeForPaws processes certain records on behalf of shelters, which may include:

• Adoption applications and supporting information
• Adoption agreements / contract records
• Cruelty / inspectorate / welfare case records
• Statements, investigation notes, outcomes, and timelines
• Evidence and attachments (photos, videos, documents)

6.5 Technical and analytics records

• IP addresses (HomeForPaws stores IP addresses)
• Device and browser information (where applicable)
• Internal platform analytics and event records (e.g., views, contact reveals, likes, saves, page views)

7) Processing of personal information in terms of POPIA

7.1 Purpose of processing

Personal information may be processed for purposes including:

• Operating and providing the HomeForPaws platform and its features
• Enabling shelters to manage adoptions and welfare-related workflows
• Authenticating users and securing accounts
• Customer support (email support)
• Security, fraud prevention, auditing, and service integrity
• Billing administration for shelter subscriptions (payment references/status only)

7.2 Categories of data subjects

• Applicants/adopters
• Shelter staff and authorised shelter users
• Complainants, accused persons, witnesses, and other individuals referenced in welfare/inspectorate cases (where applicable)

7.3 Categories of personal information processed (high level)

• Names, contact details, addresses
• South African ID numbers or passport numbers
• Employment and other application-related information
• Home inspection notes, references, screening notes and outcomes
• Case statements, reports, investigation notes and outcomes
• Evidence files (photos, videos, documents)
• IP addresses and usage logs (for security and operational purposes)

7.4 Recipients / categories of recipients

Personal information may be shared with:

• The relevant shelter and its authorised users (for Shelter Records)
• Authorised HomeForPaws personnel, limited to what is necessary to operate/support the platform
• Service providers used to run the platform (see 7.5)

7.5 Cross-border processing and storage

HomeForPaws uses service providers to operate the platform. As a result, certain personal information may be processed or stored outside South Africa, including:

• Authentication processing via Firebase Authentication (United States)
• File storage (contracts/PDFs/images/videos/evidence) via Cloudflare R2 (Western Europe)

Other processing and hosting includes:

• Database hosting via MongoDB Atlas on AWS (Cape Town, South Africa)
• Application hosting and serverless execution configured for Cape Town, South Africa via Vercel
• Payments processed via Paystack (HomeForPaws stores payment references and status only; card details are not stored by HomeForPaws)

7.6 Security safeguards (high level)

HomeForPaws implements reasonable technical and organisational measures to protect personal information, which may include:

• Encryption in transit (TLS/HTTPS)
• Access controls and least privilege principles
• Monitoring and logging for security and operational integrity
• Backup and recovery practices

7.7 Retention (high level)

HomeForPaws retains records in accordance with its retention schedule and applicable recordkeeping requirements, including:

• Adoption agreements and related adoption records: five (5) years from the date the adoption agreement is signed
• Cruelty/inspectorate/welfare cases and related evidence/documents: five (5) years from the case closure date
• Backups: may be retained for up to 30 days
• Logs (which may include IP addresses): retained for limited periods for security and operations

8) Procedure to request access to records (PAIA request process)

A requester who wishes to request access to a record held by HomeForPaws must submit a written request as follows:

1. Submit your request by email to: sam@homeforpaws.co.za
   Subject line: “PAIA Request”
2. Include sufficient details to identify the record requested, including:
   • Full name and contact details of the requester
   • A clear description of the record(s) requested
   • The form of access required (electronic copy, etc.)
   • If requesting personal records, proof of identity and confirmation that the requester is entitled to request the record
3. HomeForPaws will acknowledge receipt and may request clarification if the request is unclear.
4. HomeForPaws will process the request in accordance with PAIA and may refuse access on grounds permitted by PAIA (for example, protection of third-party privacy, confidentiality, or legally privileged information).

9) Fees

HomeForPaws does not charge a request submission fee for PAIA requests. If reproduction, transcription, or other costs are required to provide access in a requested format, reasonable costs may apply. Where applicable, HomeForPaws will inform the requester of any costs before providing the records.

10) Remedies and complaints

If a requester is not satisfied with the outcome of a PAIA request, the requester may:

• Request further engagement with the Information Officer at sam@homeforpaws.co.za, and/or
• Lodge a complaint with the Information Regulator (South Africa), and/or
• Approach a court with jurisdiction, as provided for in PAIA.

11) Availability of this Manual

This PAIA Manual is made available on the HomeForPaws website and may also be requested via email at sam@homeforpaws.co.za.