How to request our records.
This manual is published under section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA). It explains what categories of records De Vlamingh & Associates Consulting CC (trading as PositionMeAI) holds, and how to request access to them. This is a separate, statutory document from our Privacy Policy. The Privacy Policy explains what we do with your personal information day-to-day; this manual explains your formal right, as anyone (not only PositionMeAI users), to request access to records we hold.
docs/legal/POPIA-COMPLIANCE-REGISTER.md for the full context.
01About this body
De Vlamingh & Associates Consulting CC, trading as PositionMeAI, is a close corporation registered in South Africa. It is a private body for the purposes of PAIA.
General contact: hello@positionmeai.co.za
02Information Officer
Not yet published. Under PAIA and POPIA section 55, a private body's Information Officer must be a named individual, registered with the Information Regulator before commencing their duties. That registration has not yet been completed. Until it is, direct any PAIA or POPIA request to the general contact address above, and it will be handled manually.
03Categories of records held
In the ordinary course of operating PositionMeAI, we hold records in the following categories. This list describes categories, not individual records; see our Privacy Policy for the detail on personal information specifically.
| Category | Examples |
|---|---|
| Customer & purchase records | Email addresses, product access grants, PayFast transaction references and confirmations |
| Assessment & report data | Career Report, Scan, Legacy Scan, CareerShift, and FuturePath responses and results, where you've chosen to have them stored (see Privacy Policy Sections 2–3) |
| Course & certificate records | Academy/Foundations completion records, issued certificates |
| Correspondence | Emails and application forms (Consultations, Foundations/Sprint applications) |
| Financial & accounting records | Invoices, transaction records kept for SARS purposes |
| Operational/technical records | Aggregate, anonymised platform-usage statistics; security and access logs |
04Records automatically available (no request needed)
Some records are already published and don't require a formal PAIA request:
- This PAIA Manual
- Our Privacy Policy
- Public product/pricing information across the site
05How to request access to a record
To request access to a record, email hello@positionmeai.co.za with:
- Your name and contact details
- A description of the record you're requesting, specific enough for us to locate it
- The form in which you'd like to receive it (e.g. email, printed copy)
- If you're requesting on someone else's behalf, proof of that authority
We will acknowledge your request and respond within the timeframes PAIA sets out. If a request is refused in whole or in part, we will explain why, and tell you about your right to lodge a complaint with the Information Regulator or apply to court.
If you're specifically requesting your own personal information rather than a general record, POPIA's data-subject-access process (see Privacy Policy Section 9) may be the faster route. Use whichever applies to what you're actually asking for.
06Fees
We follow the fee structure prescribed under PAIA regulations for private bodies (a request fee, plus a per-page reproduction fee where applicable). We will tell you the applicable fee before proceeding with a request that isn't free.
07Grounds for refusal
PAIA permits refusal of a request in specific, limited circumstances, for example where disclosure would unreasonably reveal another person's personal information, breach legal privilege, or harm commercially sensitive information. Any refusal will state which specific ground applies.
08The Information Regulator
If you're unhappy with how a request was handled, you can complain to:
Information Regulator (South Africa)
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
Telephone: +27 (0) 10 023 5200
Email: PAIAComplaints@inforegulator.org.za
Website: inforegulator.org.za