1. Particulars of Sebenza (Section 51(1)(a))
| Name | Sebenza (working name) |
|---|---|
| Type | Private body, South African talent-intelligence platform |
| Postal address | To be confirmed before commercial launch |
| Physical address | To be confirmed before commercial launch |
| Telephone | To be published with commercial launch |
| Email (Information Officer) | popia@sebenzasa.com |
| Website | https://sebenzasa.com |
2. Information Officer & Deputy (Section 51(1)(b))
The Information Officer is responsible for all PAIA and POPIA compliance matters, including responding to access requests.
| Information Officer | To be designated (named individual recorded in docs/popia/INFORMATION_OFFICER.md) |
|---|---|
| Deputy Information Officer | To be designated alongside |
| popia@sebenzasa.com |
3. Guide on how to use the Act (Section 51(1)(c))
The Information Regulator (South Africa) has published a Guide on how to use PAIA. It is available at inforegulator.org.za.
4. Records held by Sebenza (Section 51(1)(d))
The records held fall into the following categories:
- User account records name, email, role, hashed password, two-factor secrets, KYC transaction references.
- Profile records handle, profession, skills, experience, qualifications, employment status, work availability, date of birth, nationality, and only when the user opts into KYC verification later from their dashboard the encrypted SA ID or passport number plus issuing country, and a private copy of the SA ID book/card or passport bio page held in a user-scoped folder of the private object store. ID number and document are not collected at sign-up.
- Organisation records registered employer organisations and members.
- Activity records sign-ins, search events, contact reveals, document downloads, placement confirmations, consent grants/revocations, administrator actions.
- Seeker invitation records for each invitation an employer sends, the inviting organisation id, the inviter's user id, the recipient email + optional name/profession/note, the lifecycle state (pending / accepted / declined / withdrawn / expired), the timestamps, and when accepted the linked profile id.
- File uploads CVs, qualification documents, profile photos (stored privately in Supabase Storage; access via short-lived signed URLs only).
- Audit log every access to special-category personal information, with actor + subject + timestamp. Retained for 5 years.
- Aggregate analytics anonymised cohort statistics for the longitudinal outcomes dataset (suppressed below 10 individuals per cell, per Phase 7.5.4).
5. Records automatically available (Section 51(1)(e))
The following are published without a PAIA request:
- Public talent profiles (only those whose owner has granted
searchabilityconsent), at /search. - Aggregate national analytics at /insights freshness band counts, skills-gap demand vs supply, supply heatmap, longitudinal outcomes (suppressed cells only).
- This PAIA manual and the Privacy Policy.
6. How to request access (Section 51(1)(d)–(f))
You have a right to your own records and, in certain circumstances, to records of other persons (subject to PAIA's third-party-protection regime).
Your own records easiest path
Sign in and use /dashboard/privacy → Download my data. We stream a JSON file with every row referencing your account. This is free, instant, and audit-logged (PAIA + POPIA §23 satisfied in one click).
Records about a third party formal PAIA request
Complete Form 2 of the PAIA Regulations and submit it to the Information Officer at popia@sebenzasa.com. We respond within 30 calendar days as required by PAIA, and follow the third-party-notification procedure if applicable.
Fees
No fee for your own records via the dashboard download path. For formal PAIA requests, the prescribed PAIA fees apply (see the Regulator's fee schedule).
7. Grounds for refusal (Section 51(1)(g))
Access may be refused on the grounds set out in PAIA, including (but not limited to):
- Protection of a third party's personal information (Section 63).
- Protection of confidential information of a third party (Section 64).
- Protection of the safety of individuals and of property (Section 66).
- Records protected by legal privilege (Section 67).
- Records relating to commercial activities (Section 68) and records of research (Section 69), where applicable.
If we refuse access, we give written reasons referencing the specific PAIA section and notify you of your appeal rights.
8. Right to lodge a complaint with the Information Regulator
If you are unhappy with our response, you may lodge a complaint with the Information Regulator (South Africa): inforegulator.org.za. You may also approach a court of competent jurisdiction.
9. Availability
This manual is published on /paia and is available, on request and at no charge, in printable format via the Information Officer.