1. Introduction
This manual is published by {{COMPANY_REGISTERED_NAME}} (registration number {{CIPC_REGISTRATION_NUMBER}}), which operates SD-LINK (“SD-LINK”, “we”), in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 (“PAIA”). PAIA gives everyone the right to request access to records held by a private body where the record is required to exercise or protect a right. This manual explains what records we hold and how to ask for them.
2. Contact details of the head of the private body
| Name of private body | {{COMPANY_REGISTERED_NAME}} (trading as SD-LINK) |
|---|---|
| Head of the private body | {{HEAD_OF_PRIVATE_BODY_NAME}} |
| Information Officer | {{INFORMATION_OFFICER_NAME}} — {{INFORMATION_OFFICER_EMAIL}} |
| Deputy Information Officer | {{DEPUTY_INFORMATION_OFFICER_NAME}} — {{DEPUTY_INFORMATION_OFFICER_EMAIL}} |
| Physical address | {{PHYSICAL_ADDRESS}} |
| Postal address | {{POSTAL_ADDRESS}} |
| Telephone | {{SUPPORT_PHONE}} |
| {{SUPPORT_EMAIL}} | |
| Website | https://sdlink.co.za |
3. The Information Regulator’s Guide
The Information Regulator has compiled a guide, in each official language, that explains how to use PAIA (section 10). You can ask the Regulator for it or download it from the Regulator’s website:
| Regulator | The Information Regulator (South Africa) |
|---|---|
| Address | Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191 |
| Telephone | 010 023 5200 · toll-free 0800 017 160 |
| enquiries@inforegulator.org.za | |
| PAIA complaints | PAIAComplaints@inforegulator.org.za |
| Website | inforegulator.org.za |
4. Records available without a PAIA request
The following are publicly available and need no formal request:
- the public marketplace: published courses, training-provider profiles and bursary listings;
- the certificate verification page (for anyone who has a credential ID); and
- our policies: Terms of Use, Privacy Notice, Cookie Policy, Refund & Cancellation Policy and this manual.
5. Records kept in terms of other legislation
We keep records as required by the following legislation, to the extent it applies to us:
- Companies Act 71 of 2008
- 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
- Income Tax Act 58 of 1962, Value-Added Tax Act 89 of 1991 and Tax Administration Act 28 of 2011
- Basic Conditions of Employment Act 75 of 1997 and Labour Relations Act 66 of 1995
- Skills Development Act 97 of 1998 and Skills Development Levies Act 9 of 1999
- National Qualifications Framework Act 67 of 2008
- Unemployment Insurance Act 63 of 2001
- Occupational Health and Safety Act 85 of 1993
- Financial Intelligence Centre Act 38 of 2001
6. Subjects and categories of records we hold
The list below describes the categories of records we hold. The fact that a category is listed does not mean it will be disclosed — a request is assessed against the grounds for refusal in PAIA.
| Subject | Categories of records |
|---|---|
| Company and governance | Registration documents, memorandum of incorporation, share and director registers, resolutions and minutes, statutory returns. |
| Finance and tax | Financial statements, accounting records, invoices and receipts, bank and payment-processor records, VAT and tax returns. |
| Platform user records | Account records, learner profiles and uploaded documents, applications and enrolments, assessment results and certificates, SDP organisation files and accreditation evidence, HR partner records, notifications and support requests. |
| Commercial and contractual | Agreements with SDPs, HR partners, bursary providers and suppliers; quotations; service-level and marketing materials. |
| Human resources | Records of employees and contractors (where applicable), including contracts, payroll and leave records. |
| Information technology and security | System and access logs, security incident records, IT policies and configuration records. |
| Legal and compliance | Policies and notices, complaints and their outcomes, correspondence with regulators, and legal opinions (which may be privileged). |
7. Processing of personal information
This section summarises the information POPIA requires this manual to cover. Full detail is in our Privacy Notice.
- Purposes: running accounts, enrolling and teaching learners, taking payment, issuing and verifying certificates, verifying SDP accreditation, security and fraud prevention, legal compliance, and (with consent) marketing.
- Data subjects and information: learners (identity, contact, profile, documents, learning records), SDP and HR partner representatives (identity, contact, organisation details), facilitators and employees, and visitors (technical information).
- Recipients: the SDPs and HR partners a person applies to or studies with, service providers acting as operators (for example Amazon Web Services, Paystack and Vercel), regulators and professional advisers.
- Transborder flows: some operators may process information outside South Africa; see the cross-border section of the Privacy Notice.
- Security measures: encryption in transit, role-based access and tenant isolation, private signed-link document storage, restricted staff access and logging.
8. How to request access to a record
- Complete Form 2 (Request for Access to Record), available from the Information Regulator’s website, and send it to our Information Officer at {{INFORMATION_OFFICER_EMAIL}} or to our postal address above.
- Identify the record with enough detail for us to find it, say what form of access you want, give your contact details, and — if you are asking on someone else’s behalf — attach proof of your capacity.
- Explain which right you want to exercise or protect and why the record is required for that. This is required for requests to private bodies.
- Pay the prescribed request fee (and, if a deposit applies, the deposit). Fees are set by regulation and published by the Information Regulator; personal requesters are not charged the request fee. We will tell you of any further access fee on Form 3.
We will decide within 30 days of receiving a valid request. We may extend that once, by up to a further 30 days, for the reasons PAIA lists (for example a large volume of records), and will tell you if we do.
9. Grounds on which we may refuse access
PAIA requires or permits us to refuse a request in certain cases, including where disclosure would:
- unreasonably disclose personal information about a third party;
- disclose a third party’s commercial or confidential information;
- endanger the safety of a person or the security of property;
- reveal privileged legal communications;
- reveal our own commercial information or research in a way PAIA protects; or
- the record cannot be found or does not exist (in which case we will explain this by affidavit or affirmation).
Even where a ground applies, access must still be given if the public interest in disclosure clearly outweighs the harm (section 70).
10. If your request is refused
If we refuse a request, or you do not hear from us in time, you may lodge a complaint with the Information Regulator (Form 5) at PAIAComplaints@inforegulator.org.za, or apply to a court with jurisdiction for relief. There is no internal appeal for private bodies.
11. Availability and updates of this manual
This manual is available on our website, at our physical address during business hours, and on request from the Information Officer. It is also available to the Information Regulator on request. We review it at least once a year and when our records or processing change materially.