PAIA Manual

• Registered name: Kuumba (Pty) Ltd
• Trading as: Cavitech AI
• Registered address: 2 Farrar Street, Comet, Boksburg, Gauteng, South Africa
• Website: cavitech-ai.com
• Information Officer: Ruan Baker — privacy@kuumba.dev
• Deputy Information Officer: Dr Stefan Pretorius — privacy@kuumba.dev

The Information Regulator has published a guide under section 10 of PAIA in all official languages, explaining how a member of the public may exercise their right of access to information. The guide is available in English and the other official languages on the Information Regulator’s website at inforegulator.org.za, or may be requested from the Information Regulator at the address below.

Information Regulator (South Africa)
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
PO Box 31533, Braamfontein, Johannesburg, 2017
Tel: +27 (0) 10 023 5207 · Email: inforeg@justice.gov.za
PAIA-related enquiries: PAIAComplaints.IR@justice.gov.za

No records are currently automatically available under section 15 of PAIA. A requester may submit a request under section 11 (public body records) or section 53 (private body records) as applicable to obtain any record held by Kuumba.

Kuumba holds records that fall within the following categories. The list below is illustrative; it is not necessarily exhaustive.

Company records

• Records kept under the Companies Act 71 of 2008 and regulations thereunder (Memorandum of Incorporation, directors’ resolutions, annual returns, share register, minute book).
• Records of contracts with suppliers, sub-processors, service providers, and customers.
• Insurance policies (where applicable) and claims history.

Financial records

• Records kept under the Income Tax Act 58 of 1962 and the Value-Added Tax Act 89 of 1991 (general ledger, tax returns, bank statements, invoices, expense records).
• Audited or reviewed financial statements where applicable.

Employment and HR records

• Records kept under the Basic Conditions of Employment Act 75 of 1997, the Employment Equity Act 55 of 1998, the Labour Relations Act 66 of 1995, the Unemployment Insurance Contributions Act 4 of 2002, and the Skills Development Levies Act 9 of 1999 (employment contracts, payslips, leave records, performance records).

Customer and patient-health records (via customers)

• Kuumba processes special personal information (patient health data) on behalf of dental-practice customers, under the terms of our Data Processing Addendum. Access to these records is controlled by the responsible dental practice, not by Kuumba. Requests for access to patient records should be directed to the treating dental practice; Kuumba will support the practice in responding in a timely manner.

Technical and compliance records

• Signed legal acknowledgements and consent records retained for investigational-device evidence under SAHPRA / FDA / MHRA / MDR frameworks (typically six-year retention).
• Adverse-event and complaint records maintained under the post-market surveillance obligations of SAHPRA regulations.
• Security and audit logs, backup metadata, and sub-processor agreements.

A request for access to a record held by Kuumba must be submitted on the prescribed form (Form 2 of the Regulations under PAIA) and sent to our Information Officer. The prescribed form can be downloaded from the Information Regulator’s website. Requests may be lodged by email to privacy@kuumba.dev or by post to the registered address above.

Your request must:

• Provide sufficient particulars to enable Kuumba to identify the record and the requester.
• Indicate the form of access required (e.g. copy, inspection).
• Specify a postal address or email address in the Republic.
• Identify the right that the requester seeks to exercise or protect, and explain why the requested record is required for that purpose (for private-body records under section 53).
• If the request is made on behalf of another person, provide proof of capacity to act.

Kuumba will reply to the request within 30 days of receipt of a valid request, in accordance with section 56 of PAIA, unless an extension of up to a further 30 days applies. If the request affects a third party, that party may be notified to make representations before a decision is made.

Fees payable by a requester are those prescribed from time to time under section 54 of PAIA in the Regulations. At the time this manual is published these are:

• Request fee: R50 (exempt where the request is a personal requester seeking records about themselves).
• Access fee: as prescribed, based on the format of the record and the time required to prepare it.
• Deposit: where the access fee is expected to exceed R200, a deposit of one-third of the expected access fee may be required before processing proceeds.

The current prescribed fees are published in the Government Gazette. Kuumba will provide a written fee estimate before processing a request that attracts an access fee.

Kuumba may refuse a request for access to a record in accordance with the grounds for refusal in Part 3 of PAIA, including but not limited to:

• Mandatory protection of privacy of a third party who is a natural person (section 63).
• Mandatory protection of commercial information of a third party (section 64).
• Mandatory protection of confidential information (section 65).
• Mandatory protection of safety of individuals and property (section 66).
• Mandatory protection of records privileged from production in legal proceedings (section 67).
• Commercial information of Kuumba (section 68).
• Mandatory protection of research information (section 69).

A refusal will be accompanied by reasons and a description of any relevant internal appeal or external remedy.

Kuumba does not currently have an internal appeal procedure. A requester who is dissatisfied with a decision made by Kuumba’s Information Officer may:

• Lodge a complaint with the Information Regulator under section 77A of PAIA.
• Apply to the relevant court for appropriate relief under section 78 of PAIA.

PAIA regulates access to records in general. Where a data subject seeks access to their own personal information processed by Kuumba, the Protection of Personal Information Act 4 of 2013 (POPIA) also applies. Full details are in our POPIA notice. A data subject may exercise their POPIA rights of access, correction, and deletion by contacting our Information Officer at the address below.

You may submit a PAIA request or a POPIA data-subject request online using the form at /legal/paia-manual/request. This is provided as a convenience; the prescribed PAIA Form 2 remains the authoritative submission method for formal PAIA requests. Online submissions are received by the Information Officer and acknowledged within 2 business days.