PAIA Manual

This manual is published in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA). It explains what records Padler holds, how to ask for access to them, and what happens if we say no. See also our Privacy Policy, which covers how we handle personal information generally.

The Information Regulator has published a Guide, in terms of section 10 of PAIA, on how to use the Act. It is available free of charge from the Regulator at inforegulator.org.za, or on request from the Regulator at PAIAComplaints@inforegulator.org.za or 010 023 5200. We'll also point you to it if you ask us.

Body: Bosman Data (Pty) Ltd, trading as Padler.

Registration: 2020/584135/07 (CIPC)

Physical and postal address: 7 Langenhoven Street, Dan Pienaar, Bloemfontein, 9301. This is also the address for service of legal documents.

Information Officer: Malan Bosman, who is the head of the body and therefore its Information Officer in terms of section 56(1) of POPIA.

Email: hello@padler.co.za

Website: padler.co.za

Some records are published and need no PAIA request at all. On a region whose ladder is public, anyone can see team names, both players' first names, ladder positions and win/loss records simply by visiting the site. Our Privacy Policy, Terms and Refund Policy are published for the same reason.

We have not published a notice under section 52(2) of PAIA listing further categories of records as automatically available. If that changes, it will be noted here.

Grouped by subject, with the people each group is about. This list is kept in step with the actual database rather than written once and left.

• Accounts and profiles — name, email address, and a phone number where one has been supplied. Subjects: team captains and region administrators.
• Region membership — which region an account belongs to, its role (player or administrator) and status. Subjects: account holders.
• Teams and ladder standing — team name, composition, the captain's name and self-reported Playtomic rating, the partner's first name and self-reported Playtomic rating, ladder position, win/loss record, strikes, and any immunity, cooldown or leave periods. Subjects: captains and their partners.
• Contact details for match arrangement — a team's WhatsApp number. Subjects: captains.
• Challenges and matches — challenges issued and accepted, proposed and agreed time slots, deadline extensions, submitted scores, confirmations, disputes and their resolutions, and snapshots of the ladder taken so a disputed result can be reversed. Subjects: both teams in a match.
• Opponent ratings — after a match, a captain may rate the other team on communication, punctuality and sportsmanship. We record who left each rating. See "When we may refuse" below, which is directly relevant to this record.
• Notifications — messages sent to an account within the app, and whether they were read.
• Subscriptions and payments — a team's subscription status, the end of the paid period, and the payment gateway's reference. We never hold card numbers.
• Administrative action logs — a record of actions taken by region administrators, such as removing or reinstating a team, reordering a ladder or resolving a dispute.
• Regions — region name, slug, location, contact number, settings and branding. Subjects: the region rather than an individual, though a contact number may be a person's.
• Correspondence — email sent to us at hello@padler.co.za, including support questions and requests made under this manual.

We keep records because other statutes require it, not only because we want them. These are held in terms of, among others:

• Companies Act 71 of 2008 — company and accounting records.
• Tax Administration Act 28 of 2011 and the Income Tax Act 58 of 1962 — tax records.
• Protection of Personal Information Act 4 of 2013 — documentation of our processing operations.
• Electronic Communications and Transactions Act 25 of 2002 — the supplier information published on this site.

Padler currently has no employees. If that changes, records kept under the Basic Conditions of Employment Act, the Labour Relations Act, the Employment Equity Act, the Unemployment Insurance Act and the Compensation for Occupational Injuries and Diseases Act will be added here.

Email hello@padler.co.za. Please use the request form prescribed by the PAIA Regulations — the current form and fee schedule are published by the Information Regulator at inforegulator.org.za, and we'll send you a copy if you ask. In practice, if you're asking for your own information, a plain email is enough and we won't turn you away for not using the form.

Whichever route you use, tell us:

• enough detail to identify the record you want;
• enough detail to identify you — your account email address, and your region, is usually plenty;
• the form you'd like it in (a PDF or spreadsheet by email, unless you'd rather have something else), and how to reach you;
• if you're asking on someone else's behalf, proof that you're entitled to.

We must decide within 30 days of receiving the request, and we'll tell you the outcome in writing. That period can be extended by up to a further 30 days where the request covers a large number of records or requires a search through records held elsewhere; if we need to extend, we'll tell you why and you can challenge it.

You don't need to use PAIA to get a copy of your own personal information — POPIA gives you that right directly, and the "Your rights" section of our Privacy Policy is the quicker route. This manual exists for the cases POPIA doesn't cover.

PAIA allows a private body to charge two kinds of fee: a request fee, payable by a requester who is asking for someone else's records, and access fees for searching for, preparing and reproducing a record. A personal requester — someone asking for a record about themselves — pays no request fee.

The amounts are the ones prescribed in the PAIA Regulations and published by the Information Regulator. We don't reproduce them here because they are revised from time to time and a stale figure would be worse than none.

In practice we don't charge. Padler is a small operation and almost every request we expect is a player asking for their own information, which carries no request fee anyway. If a request were large enough that access fees would genuinely apply, we'd tell you what they would be, and give you the chance to narrow the request or withdraw it, before doing the work.

PAIA sets out limited grounds on which a private body must or may refuse a request. Those most likely to matter here:

• Someone else's privacy (section 63). This is the live one for Padler. Match records, challenges and disputes involve two teams, so a record about you often contains information about someone else — and opponent ratings are deliberately anonymous, because we promise raters that the team they rated will never see who said what. We will not disclose who left a rating. Where a record is mixed, we'll give you your part and hold back theirs rather than refuse the whole thing.
• Legally privileged records (section 67).
• Third-party commercial or confidential information given to us in confidence.
• A request that is manifestly frivolous or vexatious, or that would involve a substantial and unreasonable diversion of resources.

If we refuse, we'll tell you in writing which ground we're relying on, enough about our reasoning for you to make sense of it, and how to take it further. Section 70 of PAIA can require disclosure despite a refusal ground where the public interest clearly outweighs the harm — we'll apply that where it applies.

PAIA gives no internal appeal against a private body's decision — that route exists only for public bodies. If you're dissatisfied with our decision, with a deemed refusal (where we don't answer in time), or with a fee we've asked for, you may:

• Complain to the Information Regulator, at PAIAComplaints@inforegulator.org.za or through inforegulator.org.za; or
• Apply to court in terms of section 78 of PAIA.

You're welcome to raise it with us first — most things are quicker to fix that way — but nothing above requires you to, and doing so doesn't affect either right.

Included here because the PAIA Regulations ask a manual to cover it. The full detail is in our Privacy Policy.

• Purpose: running a challenge ladder — registering teams, placing them by rating, recording challenges and results, moving teams up and down, and billing a team subscription.
• Categories of data subjects: team captains, their partners, region administrators, and people who write to us.
• Categories of information: identity and contact details, self-reported skill ratings, ladder and match history, conduct records such as strikes and disputes, and subscription status.
• Recipients: other members of the same region (and, on a public region, anyone visiting, for the limited set named above); and our operators — Supabase, Cloudflare, Resend and Payfast.
• Cross-border transfers: some operators are outside South Africa. We rely on them being subject to law giving equivalent protection, or on a written agreement requiring it.
• Security: each region's data is isolated from every other region's at the database level, access is scoped to what a signed-in user is entitled to see, credentials that could bypass those protections are kept out of anything reaching a browser, and all traffic is encrypted.

This manual is available free of charge on this page, and on request from the address above. We'll provide it in another official language on request, and we'll make it available to the Information Regulator on request.