PAIA Manual
Last Updated: August 15, 2026
1. Introduction and Purpose
The Constitution of the Republic of South Africa gives every person the right of access to any information held by the State, and any information held by another person that is required for the exercise or protection of any right. PAIA gives effect to this constitutional right and sets out the procedure for requesting access to records held by public and private bodies.
This manual is compiled in terms of section 51 of PAIA, as amended, and describes: how to request access to a record held by Jittercat (Pty) Ltd; the categories of records we hold; and, in line with the amendments introduced by POPIA, how and why we process personal information. It applies to Jittercat (Pty) Ltd, trading as Always Keep Me.
2. Contact Details of the Information officer
Legal Entity: Jittercat (Pty) Ltd
Enterprise Number: 2026/570232/07
Information Officer: Charlie Tester
Address: Eagle Canyon Office Park, Cnr Christiaan De Wet Road & Dolfyn Str, Randparkridge (meeting office only, available by appointment; we otherwise operate remotely)
Email: privacy@alwayskeep.me
Requests for access to records, and any queries about this manual, should be directed to the Information Officer using the contact details above.
3. The Guide on How to Use PAIA
Section 10 of PAIA requires the South African Human Rights Commission, and now the Information Regulator, to publish a guide containing information to assist a person wishing to exercise a right under PAIA, including the objects of PAIA and the manner in which to lodge a request.
This guide is available from the Information Regulator at inforegulator.org.za, or by contacting them directly at inforeg@justice.gov.za. We do not charge for referring you to the guide.
4. Records Automatically Available (Section 52 Notice)
Section 52 of PAIA allows a private body to voluntarily publish a notice describing categories of records that are available without a formal request. We have not published such a notice. All requests for access to our records should therefore follow the formal request procedure set out in Section 8 of this manual.
This does not affect information we make publicly available in the ordinary course of operating the Service, such as our Terms of Use, Privacy Policy, and this manual, which do not require a request.
5. Records Available Under Other Legislation
Some records we hold may also be available to you under legislation other than PAIA, including:
- The Consumer Protection Act 68 of 2008
- The Electronic Communications and Transactions Act 25 of 2002
- The Companies Act 71 of 2008
- Tax legislation administered by the South African Revenue Service
Where another law provides its own procedure for obtaining a record, that procedure may apply instead of, or alongside, a PAIA request.
6. Subjects and Categories of Records Held
To help you frame a request with sufficient detail, this section describes the general subjects on which we hold records, and the categories of records held on each. It does not mean that access will necessarily be granted to any particular record; refusal may still apply on the grounds set out in Section 9.
Customers and keepsake creators
- Account and contact information (email address)
- Uploaded content (audio or video files, custom text, titles, design preferences)
- Order and transaction records, including payment references processed by our payment provider
- Support and correspondence records
- Technical and usage information (browser type, device information, IP address, usage logs)
Third parties whose voice or likeness appears in a recording
- The audio or video recording itself, to the extent it was uploaded by another person
- Consent representations made to us by the uploader regarding that recording
Suppliers and business contacts
- Contact details and correspondence
- Contracts and commercial records
Employees, contractors, and job applicants (where applicable)
- Recruitment, employment, and payroll records
- Records required under employment, tax, or labour legislation
7. Processing of Personal Information (POPIA)
Section 51 of PAIA, as amended, requires this manual to also describe how we process personal information. This section summarises that information; our Privacy Policy sets it out in full and takes precedence if there is any inconsistency.
Purpose of Processing
We process personal information to generate personalised keepsake products, store audio for QR code access, process payment, provide customer support, communicate about orders, maintain the security of the Service, and comply with our legal obligations.
Categories of Data Subjects and Information
See Section 6 above for the categories of data subjects and the information we hold about each.
Recipients or Categories of Recipients
Personal information may be supplied to: our payment processor; cloud hosting, storage, and content delivery network providers; the third-party artificial intelligence provider powering Raiden; security and fraud-prevention service providers; our professional advisors, where reasonably necessary; and courts, regulators, or law enforcement, where required by law.
Planned Transborder Flows
Some of our service providers, including our cloud, CDN, and hosting infrastructure and the artificial intelligence provider behind Raiden, may process or store personal information outside South Africa. Where this occurs, we take reasonable steps to ensure the receiving party offers a level of protection substantially similar to the conditions for lawful processing under POPIA.
General Description of Security Measures
We implement reasonable technical and organisational safeguards designed to protect personal information against unauthorised access, alteration, disclosure, or destruction. These include access controls restricting who within our organisation and among our service providers can view stored content, encryption of data in transit, and agreements with service providers requiring them to keep personal information confidential and secure. No method of electronic storage or transmission is completely secure, and we cannot guarantee absolute security.
8. How to Request Access to a Record
A request for access to a record must be made on the prescribed form (Form 2 under the PAIA Regulations) and submitted to the Information Officer at the contact details in Section 2. Your request should provide sufficient detail to enable us to identify the record and yourself as the requester, and should specify the form of access you require.
The prescribed request fee and any further access fees applicable to your request will be communicated to you once we have assessed the request, in accordance with the fees prescribed under the PAIA Regulations. We will notify you of our decision as soon as reasonably possible, and within the timeframes prescribed by PAIA.
If a request is made on your behalf by another person, that person must submit proof of authority to act on your behalf.
9. Grounds for Refusal of Access
Access to a record may be refused on grounds set out in Chapter 4 of Part 3 of PAIA. These include, among others, where disclosure would involve the unreasonable disclosure of personal information about a third party, would breach legal professional privilege, would prejudice commercial or financial interests, or falls within another specific ground for refusal recognised under PAIA. Where a request is refused, we will provide the reasons for refusal as required by PAIA.
10. Availability of This Manual
This manual is available on our website at alwayskeep.me/paia-manual, at our principal place of business for inspection during normal business hours by appointment (see Section 2), on request from any person on payment of a reasonable reproduction fee where applicable, and to the Information Regulator on request. We review and update this manual on a regular basis.
11. Contact Information
Information Officer / Privacy and Legal: legal@alwayskeep.me
Legal Entity: Jittercat (Pty) Ltd
Enterprise Number: 2026/570232/07
Jurisdiction: Republic of South Africa
Information Regulator of South Africa
Email: POPIAComplaints@inforegulator.org.za
Website: inforegulator.org.za