PAIA Manual

• Company Name: BTM EDU (Pty) Ltd
• Trading Name: BTM EDU
• Physical Address: Shop 16 North Park Mall, Pretoria North, 256 Burger Street
• Email: info@btmedu.co.za
• Website: www.btmedu.co.za

This manual is prepared in accordance with Section 51 of PAIA and provides information on how to access records held by BTM EDU (Pty) Ltd. It also incorporates the requirements of POPIA, regulating the processing and protection of personal information.

This manual is intended to:

• Inform the public of categories of records held
• Outline the process to request access to such records
• Provide guidance on exercising rights under PAIA and POPIA
• Promote transparency and accountability

• Information Officer: Tshego Phaloane (Director)
• Email: info@btmedu.co.za

The Information Officer is responsible for:

• Ensuring POPIA compliance
• Handling access requests
• Managing data protection

A guide on how to use PAIA is available from:

• The Information Regulator (South Africa)
• Website: justice.gov.za/inforeg
• Email: inforeg@justice.gov.za

The following records may be available without a formal request:

• Company profile
• Service descriptions
• Public website information
• Marketing materials

7.1 Company Records

• Registration documents
• Shareholder records
• Director information

7.2 Financial Records

• Invoices and quotations
• Bank statements
• Accounting records
• Tax records

7.3 Customer / School Records

• School contact details
• EMIS numbers
• Orders and quotations
• Delivery records

7.4 Supplier Records

• Supplier details
• Pricing lists
• Contracts and agreements

7.5 Operational Records

• Inventory records
• Stock movement records
• Delivery notes

7.6 System & Technical Records

• User accounts
• System logs
• Uploaded documents (Excel, PDF, Word, images)

7.7 Human Resources Records (if applicable)

• Employment contracts
• Payroll records

8.1 Purpose of Processing

• Quotation and invoicing
• Inventory management
• Financial reporting
• Supplier and customer management
• Compliance with legal obligations

8.2 Categories of Data Subjects

• Customers / Schools
• Suppliers
• Employees
• Users of the system

8.3 Categories of Personal Information

• Names and contact details
• Business information
• Financial information
• Transaction records

8.4 Recipients of Information

• Service providers (hosting, cloud platforms such as Emergent)
• Banks and payment processors
• Regulatory authorities

8.5 Cross-Border Transfers

Where information is transferred outside South Africa, adequate safeguards are implemented and POPIA compliance is maintained.

8.6 Security Measures

• Access control systems
• Data encryption where applicable
• Secure servers
• Role-based permissions

9.1 Submission of Request

A requester must complete the prescribed PAIA request form, submit to the Information Officer, and provide sufficient detail to identify the record.

9.2 Request Form

The prescribed form is available from the Information Regulator website or upon request from BTM EDU.

9.3 Fees

A requester may be required to pay a request fee and an access fee. Fees are determined in accordance with PAIA regulations.

9.4 Response Time

BTM EDU will respond within 30 days. This may be extended where necessary.

9.5 Grounds for Refusal

• Personal privacy is compromised
• Commercial information is protected
• Legal privilege applies
• Security concerns exist

If a request is denied, the requester may lodge a complaint with the Information Regulator or approach a court of law.

• Access their information
• Request correction
• Request deletion
• Object to processing
• Withdraw consent
• Lodge complaints

This manual is available on the company website, on request via email, and at the company's premises.

This manual will be reviewed and updated periodically.

Name: Tshego Phaloane
Position: Director / Information Officer
Date: 28 April 2026