PAIA manual

Idealweb (Pty) Ltd, trading as Recruit 360

Date of compilation: 25 September 2026 · Date of revision: 25 September 2026

1. Abbreviations

2. Purpose of this manual

This manual helps you to:

• see which of our records are available without a formal request;
• understand how to request access to a record we hold, and what it costs;
• know which of our records are kept under other laws;
• know the subjects on which we hold records, and the categories of records on each;
• know how and why we process personal information, to whom we may supply it, whether it leaves South Africa, and how we protect it;
• find the Regulator’s guide on how to use PAIA; and
• know the remedies available if a request is refused.

3. Contact details

3.1 Information Officer
Name: Louis Coetzee, Director (head of the private body)
Telephone: 087 265 2153 / 072 617 4893
Email: [email protected] (mark it “PAIA request”)

3.2 Deputy Information Officer
None designated. The Information Officer is the head of the private body.

3.3 General access-to-information contact
Email: [email protected]

3.4 Head office
Physical address: 87 Marjoram Avenue, Sinoville, Pretoria, 0129
Postal address: 87 Marjoram Avenue, Sinoville, Pretoria, 0129
Telephone: 087 265 2153 / 072 617 4893
Email: [email protected]
Website: https://recruit360.co.za

4. The Regulator’s guide on how to use PAIA

4.1 Under section 10(1) of PAIA the Regulator has updated and made available a guide on how to use PAIA and POPIA (the Guide).

4.2 The Guide describes:

• the objects of PAIA and POPIA;
• the contact details of every information officer and deputy information officer of every public body;
• how to request a record of a public body (section 11) and of a private body (section 50);
• the help available from information officers and from the Regulator;
• all legal remedies for an act or failure to act under PAIA and POPIA, including an internal appeal (public bodies), a complaint to the Regulator, and an application to court;
• the duty of public and private bodies to make a manual available (sections 14 and 51), and how to get a copy;
• the voluntary disclosure of categories of records (sections 15 and 52);
• the notices on fees (sections 22 and 54); and
• the regulations made under section 92.

4.3 The Guide is available from the Regulator, in all the official languages, on the Regulator’s website at https://inforegulator.org.za.

5. Records available without a request

These are available to anyone without a PAIA request:

6. Records kept in terms of other legislation

We keep records under the following laws, to the extent each applies to us:

7. Subjects on which we hold records

A note on customer workspaces. A request for a record in a customer’s workspace (for example, a candidate’s record at a recruitment agency) is usually best made to that customer, which decides what happens to the record. If you make it to us, we will tell the customer. We will consider it under PAIA, including the grounds for protecting third parties’ personal and confidential information in sections 63 and 65.

8. Processing of personal information (POPIA)

8.1 Purposes of processing

• Providing, securing and supporting the Recruit 360 service to our customers and their users.
• Processing personal information in customers’ workspaces on their instructions, as their operator.
• Hosting pages and adverts for our customers on our jobs host, keeping the sign-ins of people who registered or applied through a customer’s door on our jobs host (jobs.recruit360.co.za) or on our own site before 23 September 2026, and passing their applications and registrations to the agencies and employers they choose.
• Billing, collecting payment and keeping financial and tax records.
• Answering enquiries, arranging demonstrations and preparing quotes.
• Measuring and improving our websites and advertising.
• Employing and contracting staff.
• Meeting legal and regulatory obligations, and establishing or defending legal claims.

8.2 Categories of data subjects and their information

8.3 Recipients or categories of recipients

We do not sell personal information.

8.4 Planned transborder flows

Most personal information is processed in South Africa. The following functions are performed by providers outside South Africa, on written terms that protect the information, and on data-processing terms of the standard POPIA s72(1)(a) describes where the provider offers them:

Hosting, the database, file storage, system email, off-site backups and payments are in South Africa.

8.5 Security measures

We take reasonable technical and organisational measures to protect personal information, including:

• hosting on a dedicated server in a South African data centre with physical and network access controls;
• encryption of traffic in transit;
• separation of each customer’s workspace enforced in the database itself (row-level security), not by application code alone;
• multi-factor authentication available on every account, and role-based access within each workspace;
• access by our staff to production and to a customer’s workspace that is limited, time-bound and logged;
• an audit trail of significant actions in each workspace, including exports and changes to consent and retention;
• encryption of the credentials for a connected mailbox or calendar with a separate key held only by the server;
• regular backups, encrypted and held off-site in South Africa, and overwritten on a cycle not exceeding 35 days; and
• a process for identifying and reporting security compromises under POPIA sections 21 and 22.

9. How to request access to a record

9.1 Form. Use Form 2 prescribed by the Regulations (regulation 7), available on the Regulator’s website (https://inforegulator.org.za, PAIA forms). Send it to the Information Officer by email or by hand to the address in section 3. If you cannot read or write, or have a disability, you may make the request orally and the Information Officer will help you complete the form.

9.2 What to include. Enough detail to identify the record and you, the form of access you want, how you want to be told of the decision, and, because we are a private body, the right you want to exercise or protect and why you need the record for it (PAIA s50 and s53). If you ask on someone else’s behalf, include proof of your authority.

9.3 Your own personal information. You can ask us whether we hold personal information about you, and ask for it to be corrected or deleted, by writing to [email protected] as our privacy notice explains. You do not need Form 2 to find out whether we hold information about you.

9.4 Decision. We will decide within 30 days of receiving a complete request. We may extend this once, by up to 30 days, in the cases PAIA s57 allows, and we will tell you if we do. If we do not decide in time, the request is regarded as refused (s58).

9.5 Grounds for refusal. We may or must refuse access on the grounds in Chapter 4 of Part 3 of PAIA, including to protect: another person’s personal information (s63); a third party’s commercial information (s64); information we hold in confidence for a third party (s65); the safety of individuals and property (s66); privileged legal records (s67); our own commercial information, trade secrets and research (s68 and s69). Where part of a record may be released, we will release that part (s59).

9.6 Third parties. Where a request concerns a third party’s information, we will notify them and consider their representations before deciding (s71 to s73).

10. Fees

The Regulations prescribe the fees for private bodies in Annexure B. We will tell you in writing of any fee before we process the request further.

A fee may be waived at our discretion. If a request is refused, any deposit paid is repaid (PAIA s54(4)).

11. Remedies

11.1 PAIA provides no internal appeal against a decision of a private body.

11.2 If you are unhappy with a decision (including a refusal, a fee or an extension), you may within 180 days:

• lodge a complaint with the Regulator on the Regulator’s complaint form (Form 5, regulation 10); or
• apply to a court with jurisdiction.

11.3 Information Regulator (South Africa)
Physical address: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191
Telephone: 010 023 5200 · toll-free 0800 017 160
PAIA complaints: [email protected]
General enquiries: [email protected]
Website: https://inforegulator.org.za

12. Availability of this manual

12.1 This manual is available:

• on our website at https://recruit360.co.za/legal/paia-manual;
• at our head office (section 3.4), for public inspection during normal business hours;
• to any person on request, on payment of the prescribed fee for copies in section 10; and
• to the Information Regulator on request.

12.2 We update this manual when the information in it changes.