PAIA Manual

1.1 Company Details

1.2 Information Officer

1.3 Deputy Information Officer

The South African Human Rights Commission (SAHRC) has compiled a guide on how to use PAIA. This guide is available from:

HealthHalo holds the following categories of records:

3.1 Clinical and Patient Records

3.2 Financial Records

3.3 Company and Governance Records

3.4 Staff and HR Records (if applicable)

HealthHalo is currently operated solely by its two co-founding directors. Should staff be employed in future, the following records will be held:

• Employment contracts
• Payroll and UIF records
• POPIA training records
• Performance records

4.1 Who May Request Access

Any person (data subject or third party) may submit a request for access to records held by HealthHalo in accordance with PAIA. Patients wishing to access their own clinical records may do so directly via their HealthHalo patient portal or by submitting a formal PAIA request.

4.2 PAIA Request Form

Requests must be submitted using the prescribed PAIA request form (Form C), which is available from:

• The South African Government website: www.gov.za
• The Information Regulator: inforegulator.org.za
• HealthHalo (email support@healthhalo.co.za to request a copy)

4.3 How to Submit a PAIA Request

1. Complete the prescribed PAIA Form C (or send a written request for patient own-records)
2. Submit by email to: support@healthhalo.co.za
3. Include: your full name, ID number, contact details, description of the record(s) requested, the form in which you wish to receive the records, and a copy of your ID document
4. Pay the prescribed request fee (if applicable — see Section 4.5)
5. HealthHalo will acknowledge receipt within 5 business days
6. A decision will be communicated within 30 calendar days of receipt (extendable to 60 days in complex cases)

4.4 Grounds for Refusal

HealthHalo may refuse access to records on the following grounds (as permitted by PAIA):

• The record contains third-party personal information about another individual
• Disclosure would be unreasonable and cause harm to a third party
• The record is subject to legal professional privilege
• Disclosure would be contrary to the public interest
• The record relates to confidential third-party commercial information

A refusal will be communicated in writing with reasons and information about the right to appeal.

4.5 Request Fees

Prescribed fees are set by the Department of Justice and updated periodically. Current prescribed fees are available from: www.justice.gov.za

This manual is available to the public at no charge:

• Online at: healthhalo.co.za/paia-manual
• By email request: support@healthhalo.co.za

This manual will be updated whenever material changes occur to the records held or the structure of HealthHalo.

HealthHalo complies with the Protection of Personal Information Act, 4 of 2013 (POPIA). Our full Privacy Policy covers:

• What personal information is collected and why
• How personal information is processed and stored
• Who personal information is shared with
• How long personal information is retained
• The rights of data subjects under POPIA
• How to lodge a complaint with the Information Regulator

7.1 Information Officer Registration

HealthHalo's Information Officer has been registered with the Information Regulator of South Africa in compliance with POPIA Section 55.

8.1 Internal Appeal

If your PAIA access request is refused or you are dissatisfied with a decision, you may submit an internal appeal to:

• Email: dr.mchauke@healthhalo.co.za
• Addressed to: Dr Musa Chauke, Information Officer — HealthHalo (Pty) Ltd

Appeals will be reviewed and responded to within 30 days.

8.2 External Complaint — Information Regulator

If you remain unsatisfied after the internal appeal, you may lodge a complaint with the Information Regulator of South Africa:

8.3 Court Application

As a last resort, a requester may apply to the High Court for an order requiring the release of records. HealthHalo will cooperate fully with any court-ordered disclosure.

I, Dr Musa Chauke, in my capacity as Information Officer of HealthHalo (Pty) Ltd, hereby declare that this Manual has been compiled in good faith, accurately reflects the records held by the company, and will be updated as required by law.