PAIA Manual

1. Introduction to PAIA

PAIA gives effect to the constitutional right of access to information. It applies to records held by public bodies and, in specified circumstances, by private bodies such as Claar. This manual is published in compliance with section 51 of PAIA and is available free of charge.

2. About Claar

• Name of private body: Claar (Pty) Ltd
• Company registration number: 2026/295558/07
• Nature of business: compliance software-as-a-service for accountable institutions
• Postal address: available on request via the Information Officer
• Website: claar.co.za

3. Information Officer

The Information Officer is responsible for receiving and responding to requests under PAIA.

• Email: privacy@claar.co.za
• General enquiries: info@claar.co.za

4. Guide on how to use PAIA

The Information Regulator has published a Guide on how to use PAIA, available from its website. The Guide explains how to make a request for access to a record held by a public or private body. It is available at inforegulator.org.za.

5. Records held by Claar

The following categories of records are held:

Records held on behalf of customers (accountable institutions)

• Subject profiles and associated identity documents
• Verification results (DHA, liveness, PEP, sanctions, adverse media, credit, proof of address)
• Transaction records, parties, and source-of-funds declarations
• Risk ratings, compliance officer appointments, and Risk Management and Compliance Programmes
• Staff FICA checks, training registers, and evidence packs

These records are processed in our capacity as an operator. Access requests in respect of these records must generally be directed to the customer that owns the data; Claar will support such requests in accordance with our contract with the customer.

Records held by Claar itself

• Corporate, governance, and statutory records
• Human resources records
• Financial and tax records
• Contracts with customers, suppliers, and sub-processors
• Operational and security audit logs

6. Records automatically available

The following records are available without the need for a formal PAIA request: this PAIA Manual, our POPIA Privacy Policy, and general marketing and product information published on our website.

7. How to request access

Requests must be made on Form 02 prescribed by the Information Regulator. The completed form must be submitted to the Information Officer using the contact details in section 3. Requests must:

• provide sufficient particulars to enable the record to be identified;
• identify the requester (and, if applicable, the person on whose behalf the request is made);
• indicate the form of access required;
• state the right sought to be exercised or protected, where applicable.

8. Fees

Fees payable in respect of PAIA requests are those prescribed by the Minister from time to time. A request fee, access fee, and deposit may apply. Current fees will be communicated on receipt of a request.

9. Grounds for refusal

Access to a record may be refused on any of the grounds set out in Chapter 4 of Part 3 of PAIA, including protection of the privacy of third parties, commercial information of third parties, confidential information, research information, and records privileged from production in legal proceedings.

10. Remedies

If a request is refused, the requester may lodge a complaint with the Information Regulator or apply to court for appropriate relief in terms of section 78 of PAIA.

11. Updates

This manual is reviewed annually and updated as required. The "Last updated" date at the top of this page reflects the most recent revision.