PAIA Manual

1. Purpose of this manual

This manual is prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA). It tells requesters what records Southwest UAS Platform (Pty) Ltd (a private body under PAIA) holds, and how to request access to those records. PAIA gives effect to the constitutional right of access to information under section 32 of the Constitution of the Republic of South Africa.

2. Particulars of the private body

3. Head of the private body

4. Information Officer and Deputy Information Officer

The Information Officer is the head of the private body (see section 3). A Deputy Information Officer will be designated at general availability and registered with the Information Regulator.

All requests under PAIA and all POPIA-related correspondence should be addressed to:

5. Guide on how to use PAIA

The Information Regulator of South Africa has published a Guide on how to use PAIA in terms of section 10 of the Act. This guide explains how to request access to records held by public bodies and private bodies.

The guide is available from the Information Regulator at:

6. Records automatically available without a formal PAIA request

The following records are available without a formal PAIA request:

• This PAIA Manual.
• The FlightDocket Privacy Policy (privacy-policy.html).
• Company registration and public disclosures as lodged with the CIPC.
• The FlightDocket public-facing website at flightdocket.com.
• Published commercial terms (subscription tiers, mission credit rates, rollover rules) on the public website.
• Regulatory framework alignment disclosures on the public website.

7. Categories of records held

7.1 Records held by Southwest UAS Platform (Pty) Ltd as a private body

7.2 Records held on behalf of operator tenants

FlightDocket holds regulatory and operational records on behalf of each operator tenant. These records include:

• Mission records generated by the tenant (staging artefacts, submissions, assessments, FOM bundles, authorisations, closure records, evidence bundles).
• Credential and airworthiness records uploaded by the tenant (pilot licences, medicals, aircraft registrations, insurance, operating certificates).
• Safety Management System records entered by the tenant (hazards, occurrences, corrective actions, change management items).
• Team structure and client relationship records, where the tenant subscribes to tier functionality that uses them.
• Part 108 / SORA authorisation dossiers generated by the platform from tenant-supplied operation parameters.

Records held on behalf of operator tenants are not held by Southwest UAS Platform (Pty) Ltd in its own capacity. The operator tenant is the responsible party for those records. Requests for access to tenant-held records should be directed to the operator tenant, not to Southwest UAS Platform (Pty) Ltd.

8. Records held in terms of other legislation

Records are also held to satisfy obligations under the following legislation. This list is not exhaustive.

• Companies Act 71 of 2008
• Tax Administration Act 28 of 2011
• Value-Added Tax Act 89 of 1991
• Protection of Personal Information Act 4 of 2013 (POPIA)
• Promotion of Access to Information Act 2 of 2000 (PAIA)
• Electronic Communications and Transactions Act 25 of 2002
• Basic Conditions of Employment Act 75 of 1997
• Unemployment Insurance Act 63 of 2001
• Skills Development Levies Act 9 of 1999
• Occupational Health and Safety Act 85 of 1993
• SACAA Civil Aviation Regulations (CAR) & Civil Aviation Technical Standards (CATS) Part 101; anticipated Part 108
• Air Services Licensing Act 115 of 1990

9. Request procedure

9.1 How to make a request

A request for access to records must be made on the prescribed form and lodged with the Information Officer. The required form is:

• Form 2: Request for Access to Record of Private Body (Regulation 7, PAIA Regulations, 2021). Available from inforegulator.org.za.

The requester must:

1. Complete the prescribed Form 2 in full.
2. Provide sufficient detail to enable the record to be identified.
3. Identify the form in which access is required (copy, inspection, etc.).
4. Provide a postal address, email address, fax, or other means by which the requester can be reached.
5. Where the request is made on behalf of another person, provide proof of the capacity in which the request is made.
6. Submit the form by email to the Information Officer or by registered mail to the registered postal address.

9.2 Response timeframes

The Information Officer must respond within thirty (30) days of receipt of a valid request. The period may be extended by a further thirty (30) days where the request is complex or a large number of records must be consulted, and notice of the extension must be given to the requester in writing within the original thirty-day period.

9.3 Fees

PAIA prescribes two categories of fees:

• Request fee — payable before the request is processed (unless the requester is a personal requester seeking access to their own personal information).
• Access fee — payable after the request has been processed and the records have been identified, based on the reproduction and preparation effort involved.

Current fee levels are set out in Annexure B of the PAIA Regulations, 2021. Fee quotations are provided before access is granted.

9.4 Grounds for refusal

A request may be refused in whole or in part on any ground set out in Chapter 4 of Part 3 of PAIA, including:

• Mandatory protection of the privacy of a third party who is a natural person (section 63).
• Mandatory protection of commercial information of a third party (section 64).
• Mandatory protection of confidential information of third parties (section 65).
• Mandatory protection of safety and security of property (section 66).
• Mandatory protection of records privileged from production in legal proceedings (section 67).
• Commercial information of Southwest UAS Platform (Pty) Ltd itself (section 68).
• Research information of Southwest UAS Platform (Pty) Ltd (section 69).

9.5 Internal remedies

Southwest UAS Platform (Pty) Ltd does not operate an internal appeals process because it is a private body. A requester who is dissatisfied with the response to a request may lodge a complaint with the Information Regulator under section 77A of PAIA, or apply to a court for appropriate relief under section 78 of PAIA.

10. Access to personal information under POPIA

Where the request relates specifically to the requester's own personal information, it is processed as a data subject access request under POPIA (section 23). Such requests are handled through the same Information Officer contact and follow the same response timeframe. See the Privacy Policy for full details of data subject rights under POPIA.

11. Complaints to the Information Regulator

A requester dissatisfied with the response to a PAIA request, or a data subject dissatisfied with the handling of personal information under POPIA, may lodge a complaint with:

12. Review of this manual

This manual is reviewed at least annually and amended as necessary. The current version is always published at flightdocket.com/legal/paia-manual.html. The date of last review is shown at the top and in the footer.