PAIA Manual
Manual of The Polymath (Pty) Ltd, a private body, prepared under section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA) and the Protection of Personal Information Act 4 of 2013 (POPIA).
Published on 5 November 2026
1. Introduction
PAIA gives a person the right of access to records held by a private body when the record is needed to exercise or protect a right. This manual says what records The Polymath (Pty) Ltd holds, which of them can be had without a formal request, and how to ask for access to the others. It also sets out, as POPIA requires, how we process personal information.
It works together with our Privacy Notice, which explains in everyday language how we handle personal information in PolyTrack.
2. About The Polymath (Pty) Ltd
PolyTrack is a risk management platform provided by The Polymath (Pty) Ltd, a company based in Pretoria, South Africa (registration number 2026/275612/07). For PolyTrack we act only as a software provider: PolyTrack does not give insurance advice and does not handle premiums or claim payments.
We act in two roles. As a responsible party we decide how to use the information of the people who hold PolyTrack accounts or sign up for one. As an operator we process, on a client's behalf, the information about other people that our clients load into PolyTrack; for that information the client is the responsible party.
3. Who to contact
Requests under this manual go to the Information Officer, who is also the head of the company for the purposes of PAIA.
- Information Officer: Ewoud Malan (registered with the Information Regulator, registration number 2026-069855)
- Email: ewoud@thepolymath.co.za
- Street address: 35 4th Street, Menlo Park, Pretoria
- Postal address: 35 4th Street, Menlo Park, Pretoria
- Telephone: 067 855 8273
- Website: polytrack.co.za
4. The Information Regulator's guide
The Information Regulator has compiled a guide, in each official language, on how to use PAIA and POPIA. It is available from the Regulator:
- Website: inforegulator.org.za
- General enquiries: enquiries@inforegulator.org.za
- PAIA complaints: PAIAComplaints@inforegulator.org.za
- POPIA complaints: POPIAComplaints@inforegulator.org.za
- Telephone: 010 023 5200, or toll-free 0800 017 160
- Address: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191
5. Records available without a request
These are published, or given to anyone who asks, and need no PAIA request:
- this manual;
- the Privacy Notice and the Terms & Conditions of PolyTrack;
- the public pages of PolyTrack and its sign-up pages, and our published product information.
6. Records available under other legislation
We keep records as other legislation requires, to the extent it applies to us. Such records are available as that legislation provides. The legislation under which we keep records is:
- Companies Act 71 of 2008;
- Income Tax Act 58 of 1962;
- Value-Added Tax Act 89 of 1991;
- Tax Administration Act 28 of 2011;
- 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; and
- Consumer Protection Act 68 of 2008.
We have no employees at present. If that changes, the employment and occupational health and safety legislation that then applies will be added to this list.
7. Records we hold
We hold the following categories of records. A record being listed does not mean it will be released: access is decided on a request, as section 13 explains.
| Category | What it includes |
|---|---|
| Company records | Incorporation and registration documents, resolutions, the records of directors and shareholders, and our registration with the Information Regulator. |
| Financial and tax records | Accounting records, invoices and receipts, tax and VAT returns, and records of subscriptions and payments. Card and bank details are never held by us: payments are made on PayFast's own pages. |
| Customer account records | Account and profile details (name, email address, role, job title, telephone numbers and, for brokers and insurers, business details such as an FSP number), sign-in and security records, sign-up records, the plan chosen and the person responsible for the subscription. |
| Agreements | Our agreements with clients, brokers, insurers and service providers, and the terms they accepted. |
| Security and audit records | An audit log of changes made in PolyTrack and who made them, a log of the emails PolyTrack sends, and records of password reset requests. |
| Correspondence and support | Emails and messages with clients, users and service providers, and support requests. |
| Policies and procedures | Our internal policies, including those on information security and privacy. |
| Software and intellectual property | The PolyTrack software, its documentation and design, which are proprietary to The Polymath (Pty) Ltd. |
Records we hold as an operator. Our clients load information about other people into PolyTrack: for example their employees, drivers, contractors and people involved in incidents. These records belong to the client, who is the responsible party. A request for them should be made to that client; we will help the client respond.
8. Purposes of processing
We process the personal information of account holders:
- to provide PolyTrack under our agreement with you or your organisation, including sign-in, notifications, reminders and reports;
- to keep PolyTrack secure, investigate faults and prevent misuse (our legitimate interest);
- to bill subscriptions and keep financial records (our agreement and legal obligations); and
- to let the people your organisation works with see what they are entitled to see: a client's appointed broker, and insurers or specialists the client has granted access to.
We do not sell personal information and do not use it for advertising. As an operator we process clients' information only on the client's instructions.
9. People the information is about
- Account holders: client users, brokers, insurers, health and safety specialists and consultancies, and people who have signed up or been invited to. We hold their account, sign-in, activity and billing information.
- People in our clients' records (as operator): employees, drivers, contractors, supplier contacts and people involved in incidents. Depending on the modules a client uses, this can include training records (including ID numbers), driver records (including ID and licence details and driving behaviour from vehicle trackers) and incident records. Incident records can include the names of injured people and details of their injuries, which is health information and special personal information under POPIA.
- Visitors to our pages: the technical records needed to run and secure the site.
10. Who receives the information
We share information only so that these providers can provide their part of the service:
- xneelo (South Africa): hosting of the application and database.
- Cloudflare R2 (European Union): storage of uploaded documents.
- Brevo (France, European Union): sending PolyTrack's emails.
- Cloudflare (proxy and security): traffic to PolyTrack passes through Cloudflare's network, which can handle it in any country where Cloudflare operates, including the United States.
- Sentry (European Union, with processing that may also take place in the United States): error monitoring.
- PayFast (South Africa): subscription payments.
- Public registers (SARS, the FSCA and CIPC): checking a VAT, FSP or company registration number that a user enters; only the number is sent.
Used only if a user or client connects them: Google Calendar and Microsoft 365 (adding reminders to the user's own calendar), Microsoft Teams and Slack (posting alerts to a client's own channel) and vehicle tracking providers (reading a client's own tracking data). Within PolyTrack, information is shared with the people entitled to it, as section 8 says.
11. Transfers outside South Africa
Some of our service providers process personal information outside South Africa: Cloudflare (document storage in the European Union), Brevo (emails, France) and Sentry (error monitoring). Cloudflare and Sentry are United States companies and may also process information in the United States. Cloudflare's proxy can handle traffic in any country where Cloudflare operates, including the United States. If a user or organisation connects them, Google Calendar, Microsoft 365, Microsoft Teams and Slack may process information in other countries, including the United States. We tell the user this before they connect them.
We share personal information with these providers only under binding data processing agreements that require them to protect it to a standard substantially similar to POPIA, also when they pass it on to their own sub-processors, as section 72 of POPIA requires. Where we process information as an operator for a client, the client approves these providers in its agreement with us.
12. Security measures
We protect personal information with measures that include the following:
- access by role: a client sees only its own organisation, a broker only their own clients, and an insurer or specialist only the organisations that granted them access;
- passwords are stored hashed, and two-factor authentication is available;
- the connection to PolyTrack is encrypted (HTTPS), and secrets such as two-factor and integration keys are encrypted in the database;
- repeated sign-in and password reset attempts are limited; and
- documents are not publicly reachable: PolyTrack checks who may open each one.
If we become aware of a security compromise affecting personal information, we will notify the Information Regulator and the affected people, or the client concerned where we act as operator, as POPIA requires.
13. How to request access
- Complete Form 2, “Request for access to record”, from the PAIA Regulations, 2021, available on the Information Regulator's website.
- Say clearly which record you want, and which right you wish to exercise or protect with it. If you ask for someone else, send proof of your authority.
- Send it to the Information Officer at the email or addresses in section 3. We may need to confirm your identity first.
The PAIA Regulations set a request fee and, if access is granted, fees for searching for, preparing and copying the records. We will tell you what is payable before we do the work. We will reply within 30 days, which PAIA allows us to extend once by up to 30 days if we tell you why.
Access may be refused on the grounds PAIA sets out, for example to protect another person's privacy or confidential commercial information. If you disagree with our decision you may complain to the Information Regulator (PAIAComplaints@inforegulator.org.za) or apply to court.
To ask for your own personal information, to correct or delete it, or to object to its processing, see the Privacy Notice, or write to the Information Officer.
14. Availability and updates
This manual is available on our website at polytrack.co.za/paia, from the Information Officer at the addresses in section 3 on request, and to the Information Regulator on request. We update it when the records we hold or how we handle personal information change.