1. The company
| Name | Asset Disposal Consultancy (Pty) Ltd, trading as Ledger Data |
|---|---|
| Registration number | 2018/621824/07 |
| Registered address | Cape Town, Western Cape, South Africa Full registered address on request, by email, and on the company's public record at CIPC |
| For requests | By email, below. A request under this Act must be in writing in any event, so email is the proper route. |
| jt@asset-disposal.co.za | |
| Website | ledgerdata.co.za |
| Information Officer | John Bruce Taylor |
| Deputy Information Officer | None appointed. The company has one director. |
2. The Regulator's guide
The Information Regulator has published a guide on how to use PAIA, as section 10 requires. It is available from the Regulator at JD House, 27 Stiemens Street, Braamfontein, Johannesburg 2001, at inforegulator.org.za, or by email to inforeg@justice.gov.za.
3. Records available without a request
These are on the website and need no PAIA request:
- Terms of Use
- Privacy Policy
- Operator Agreement
- This manual
4. Records held
| Company records | Memorandum of incorporation, statutory registers, minutes and resolutions |
|---|---|
| Financial | Annual financial statements, accounting records, tax records, bank records, invoices |
| Customer records | Agreements with firms, correspondence, account and billing records |
| Personnel | Employment records, where any exist |
| Operational | Application source code, system configuration, backup records, audit logs |
| Held for customers | Documents uploaded by firms into their own data rooms. These belong to the firm concerned. A request for them will ordinarily be refused under section 65 as records of a third party, and the requester referred to that firm. |
5. Records held under other legislation
Records are kept under, among others, the Companies Act 71 of 2008, the Income Tax Act 58 of 1962, the Value Added Tax Act 89 of 1991, the Basic Conditions of Employment Act 75 of 1997, and the Protection of Personal Information Act 4 of 2013.
6. How to make a request
- Use the prescribed form (Form 2 of the PAIA Regulations, obtainable from the Regulator's website) and send it to the Information Officer at the email or postal address in section 1.
- Give enough detail to identify the record and to reach you, and say in what form you want it.
- If you are asking for a record in order to exercise or protect a right, say which right and how the record would help — the Act requires this.
- If you are asking on someone else's behalf, provide proof of your authority.
We will decide within 30 days and tell you in writing. That period may be extended where the Act allows, and we will tell you if it is.
7. Fees
Fees are those prescribed by the Regulations under PAIA and are payable as they require. No fee is charged for a request by a person for their own personal information. We will tell you what is payable before doing the work, and may require a deposit where the Act permits.
8. Grounds for refusing
A request may be refused on the grounds set out in Chapter 4 of Part 3 of the Act. In this company's case the ones most likely to apply are:
- Section 63 — unreasonable disclosure of someone else's personal information.
- Section 64 — commercial information of a third party, including a firm's own records held in its data room.
- Section 65 — information held in confidence for a third party.
- Section 66 — information that would endanger the security of a person, property or a system. This covers our security configuration and anything that would make the service easier to attack.
- Section 68 — commercial information of the company itself, including source code.
Where we refuse we will say so in writing, give the grounds, and tell you how to take it further.
9. If you are unhappy with the outcome
You may complain to the Information Regulator, or apply to a court, as sections 77A to 82 of the Act provide. The Regulator's details are in section 2 above.
10. Updating this manual
This manual is reviewed when the company's details or the records it holds change, and at least annually. The current version is always at ledgerdata.co.za/static/legal/paia.html.