This manual is published under section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA). It explains what records The Growth Box (Pty) Ltd, trading as CommunityDesk, holds, how to ask for them, and how we process personal information under the Protection of Personal Information Act 4 of 2013 (POPIA).

A printed copy is available free of charge from our Information Officer, and the manual is available at https://communitydesk.co.za/en/paia-manual.

• Private body: The Growth Box (Pty) Ltd (registration number 2014/113470/07), trading as CommunityDesk
• Head of the private body and Information Officer: our director
• Street and postal address: 25 Ormonde View, Corwen Street, Ormonde Extension 26, Johannesburg, 2091
• Telephone: 067 861 3549
• Email: enquiry@communitydesk.co.za
• Website: https://communitydesk.co.za

The Information Regulator has published a guide, in each official language, on how to use PAIA and POPIA to request information and exercise your rights. You can get it from the Regulator:

• Website: inforegulator.org.za
• Address: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191
• Email: enquiries@inforegulator.org.za

We have not published a notice under section 52 of PAIA. The following are freely available on our website without a formal request: our product information, pricing, Help Centre articles, blog, Terms of Service, Privacy Policy, Cookie Policy, Disclaimer and Legal Notices.

Where they apply to us, we keep records under laws including:

• the Companies Act 71 of 2008;
• the Income Tax Act 58 of 1962 and the Tax Administration Act 28 of 2011;
• the Basic Conditions of Employment Act 75 of 1997, the Labour Relations Act 66 of 1995, the Unemployment Insurance Act 63 of 2001 and the Compensation for Occupational Injuries and Diseases Act 130 of 1993;
• the Electronic Communications and Transactions Act 25 of 2002;
• the Consumer Protection Act 68 of 2008;
• the Protection of Personal Information Act 4 of 2013.

Records held because a law requires it are available where that law, or PAIA, allows.

• Company records: incorporation documents, registers, minutes and resolutions.
• Financial and tax records: accounting records, invoices, bank records, tax returns and correspondence with SARS.
• Employees and contractors (if any): contracts, payroll and statutory records.
• Customers: customer agreements, account and billing records, support requests and correspondence.
• Customers’ scheme records: the information schemes load into CommunityDesk (units, owners, residents, levies, payments, maintenance, meetings and documents). We hold these as an operator on the scheme’s behalf; requests for them should go to the scheme, and we will help it respond.
• Prospective customers and website visitors: enquiries, demo requests, chat conversations and, with consent, newsletter subscriptions and visit statistics.
• Suppliers and service providers: agreements, invoices and contact details.
• Technology and security: system, security and audit logs, and backups.
• Marketing: website content, brochures and campaign records.

1. Complete Form 2 (Request for Access to Record) from the PAIA Regulations, available from the Information Regulator’s website or from us.
2. Send it to our Information Officer at enquiry@communitydesk.co.za or to the address above.
3. Include enough detail to identify the record, the form of access you want (for example a copy or an inspection), how you want to be told of our decision and, if you ask on behalf of someone else, proof of your authority.
4. Show the right you want to exercise or protect and why the record is needed for it (section 53 of PAIA).

We may ask you to confirm your identity. We will decide within 30 days, and may extend this once by up to 30 days where the law allows, telling you why. If we don’t decide in time, the request is regarded as refused.

We may refuse a request only on the grounds in Chapter 4 of Part 3 of PAIA, for example to protect someone else’s personal information, commercial information of a third party, confidential information, or legal privilege. If we refuse, we will give reasons.

The fees for private bodies are those prescribed in the PAIA Regulations. A request fee is payable before a request is processed, except when you ask for your own personal information. An access fee may be payable for searching for and copying records. If the search and preparation will take more than six hours, we may ask for a deposit of up to one third of the access fee. We will tell you the fee before it is payable, and refund the deposit if access is refused.

We do not have an internal appeal procedure. If you are unhappy with our decision, you may complain to the Information Regulator, or apply to a court, within 180 days of being told of the decision (sections 77A and 78 of PAIA).

• Purposes: to provide and support CommunityDesk, answer enquiries, bill customers, keep the service secure, meet legal obligations, improve our website (with consent) and, with consent or as POPIA section 69 allows, send news.
• Data subjects and categories of information: website visitors and enquirers (contact details, messages); customers and their users (account, sign-in and billing details); people whose information schemes load (as the scheme’s operator: contact details, unit, levy and payment records, debit order mandates, meter readings, maintenance and meeting records); suppliers (contact and payment details); employees and contractors (employment records).
• Recipients: the service providers listed in our Privacy Policy, professional advisers, and authorities where the law requires.
• Cross-border transfers: some providers process information in the European Union and the United States, under the safeguards POPIA section 72 requires.
• Security measures: role-based access separated by customer, encryption in transit, one-time sign-in links and codes with two-step login, audit logs, encrypted storage of sensitive settings, and daily backups kept for seven days.

Our Privacy Policy has the full detail and explains how to use your rights under POPIA.

We review this manual when our records or processing change, and show the date of the latest version at the top.