Legal
PAIA Manual
Prepared under section 51 of the Promotion of Access to Information Act 2 of 2000 · Pylos Systems · date of compilation 15 October 2026 · date of revision 15 October 2026
1. Abbreviations
- IO — Information Officer
- PAIA — Promotion of Access to Information Act 2 of 2000
- POPIA — Protection of Personal Information Act 4 of 2013
- Regulator — the Information Regulator (South Africa)
- Pylos — Jason Holshausen, an individual (sole proprietor) trading as Pylos Systems
2. Purpose of this manual
This manual helps anyone who wants information from Pylos. It explains what records Pylos holds, which are available without a formal request, how to ask for the others, what it costs, and how Pylos processes personal information. Pylos is a private body under PAIA because it is a natural person carrying on a business.
3. Contact details
| Head of the private body and Information Officer | Jason Holshausen |
| Deputy Information Officer | None appointed |
| Physical address | Durbanville, Western Cape (full street address to be published here before the effective date) |
| Telephone | 084 887 9952 |
| pylossystems@gmail.com (please put "PAIA request" in the subject line) | |
| Website | https://pylossystems.com |
4. The Regulator's Guide on how to use PAIA
4.1 The Regulator has published a Guide, in all the official languages, that explains how to use PAIA and POPIA. It describes the objects of both Acts, the contact details of information officers, how to make a request to a public or private body, the help available from the Regulator, and the remedies available if a request is refused.
4.2 The Guide is available on the Regulator's website, inforegulator.org.za, and a copy may be inspected at Pylos's physical address during normal business hours. Pylos will email a copy to anyone who asks.
5. Records available without a request (section 52)
Anyone can access these records free of charge at pylossystems.com:
- the Subscription Terms, Operator Agreement, Privacy Notice and End-User Terms;
- the security summary;
- pricing and service status;
- this manual.
6. Records kept under other laws
Pylos keeps records as required by the following laws, where they apply to it:
- Tax Administration Act 28 of 2011 and Income Tax Act 58 of 1962;
- Value-Added Tax Act 89 of 1991 (if Pylos registers for VAT);
- Consumer Protection Act 68 of 2008;
- Electronic Communications and Transactions Act 25 of 2002;
- Protection of Personal Information Act 4 of 2013;
- Promotion of Access to Information Act 2 of 2000.
7. Subjects and categories of records held
| Subject | Categories of records |
|---|---|
| Business and finance | Invoices, payment records, bank statements, accounting records, tax returns and correspondence with SARS |
| Customers (clubs) | Signed Acceptance Forms, acceptance records, subscription and billing history, support correspondence |
| Legal and compliance | Current and past versions of Pylos's terms and policies, this manual, the security-compromise register, Information Regulator registration |
| Suppliers | Agreements and data processing agreements with sub-operators (hosting, database, email, SMS, payments, error monitoring) |
| Security and operations | Security policies, the incident-response checklist, system and security logs, backup and restore records |
| Product | Source code, technical documentation and product plans (these are Pylos's commercial information) |
| Club Data | Information that clubs store in their Pylos workspaces. Pylos holds this only as each club's operator: see section 8.6 |
8. Processing of personal information
8.1 Purposes. Pylos processes personal information to provide, secure and support the Pylos Systems software; to bill clubs; to keep records the law requires; to prove what was agreed; to improve the software; and to send product news to club owners where the law allows.
8.2 Data subjects and categories of information.
| Data subjects | Personal information |
|---|---|
| Club owners, administrators and billing contacts | Name, email, telephone, role, club, billing and payment status, acceptance records, support messages, marketing preferences |
| Other users (coaches, staff, parents, athletes) | Name, email, role, login and security logs |
| Website visitors | Security and error logs; anonymous page-speed measurements |
| Suppliers and contractors | Name, contact details, contract and payment details |
8.3 Recipients. Pylos's service providers (hosting, database, email, SMS, payments and error monitoring) under written agreements; SARS and other authorities where the law requires; and Pylos's professional advisers. Pylos does not sell personal information.
8.4 Planned transfers outside South Africa. The database and application servers are in the European Union (Ireland). The email provider stores account data and logs in the United States. Each transfer is made under POPIA section 72, as Annex B of the Operator Agreement shows.
8.5 Security measures. Pylos protects personal information with the measures in Annex A of the Operator Agreement and at pylossystems.com/trust, including separation between clubs, encryption of health information and of all traffic, logging, backups and a written incident-response checklist.
8.6 Club Data. Each club is the responsible party for the information in its workspace, and Pylos processes it only on the club's behalf. A request for Club Data should be made to the club. If it is made to Pylos, Pylos will pass it to the club.
9. How to request access to a record
9.1 Complete Form 2 (Request for Access to Record) in the PAIA Regulations, available on the Regulator's website, and email it to the Information Officer. Give enough detail to identify the record, say in what form you want it, and prove your identity. If you ask on someone else's behalf, include proof of your authority.
9.2 Pylos will decide within 30 days of receiving a complete request, and may extend this once by up to 30 more days if the law allows, with written reasons. If Pylos does not decide in time, the request is regarded as refused.
9.3 Pylos may refuse access only on the grounds in Chapter 4 of Part 3 of PAIA, for example to protect a third party's personal or commercial information, confidential information, the safety of individuals, legal privilege or Pylos's own commercial information. Where part of a record can be released, Pylos will release that part.
9.4 If your request is refused, you may complain to the Regulator (using its Form 5, within 180 days) or apply to court.
10. Fees
10.1 A requester who is not asking for their own personal information pays a request fee of R140 before the request is processed. A personal requester pays no request fee.
10.2 If access is granted, access fees for copies, electronic copies and search and preparation time are payable at the rates in Annexure B of the PAIA Regulations, as published by the Regulator. If searching and preparing the record will take more than six hours, Pylos may ask for a deposit of one-third of the estimated access fee.
11. Requests about your own personal information (POPIA)
You may ask Pylos what personal information it holds about you, ask for it to be corrected or deleted (POPIA Regulations Form 2), or object to its processing (POPIA Regulations Form 1), by emailing the Information Officer. If you are unhappy with the response, you may complain to the Regulator, 54 Maxwell Drive, Woodmead North Office Park, Johannesburg, through inforegulator.org.za.
12. Availability and updates
This manual is published at pylossystems.com/legal/paia and may be inspected free of charge at Pylos's physical address. Pylos reviews it at least once a year and whenever its details change, for example when Pylos becomes a company.