Access to Information Manual (PAIA Manual) Primal Protocols

Prepared in accordance with Section 51 of the Promotion of Access to Information Act, No. 2 of 2000 ("PAIA") and the Protection of Personal Information Act, No. 4 of 2013 ("POPIA").

CONTENTS

• 1. Introduction
• 2. Business Details
• 3. Guidance from the Information Regulator
• 4. Records Available in Accordance with Other Legislation
• 5. Records Held by Primal Protocols
• 6. Processing of Personal Information (POPIA)
• 7. Requesting Access to a Record
• 8. Grounds for Refusal of Access
• 9. Availability and Updates to this Manual

1. INTRODUCTION

Primal Protocols is a private, online platform dedicated to providing well-researched health, wellness, and nutritional information. We operate strictly for educational purposes and do not provide medical advice or medical services.

The Promotion of Access to Information Act (PAIA) requires private bodies to compile a manual that assists the public in knowing what types of information the body holds and outlines the procedure to request access to that information. This manual is intended to foster a culture of transparency and accountability while fully respecting the privacy frameworks established by the Protection of Personal Information Act (POPIA).

2. BUSINESS DETAILS

For the purposes of this manual, the Head of the Private Body also serves as the designated Information Officer.

• Business Name: Primal Protocols
• Head of Business / Information Officer: Wayne Woodman
• Email Address: legal@primalprotocols.com
• Website: www.primalprotocols.com
• Physical Address: 203 Lawson Road, Belthon Estate, 7780, Cape Town, South Africa

3. GUIDANCE FROM THE INFORMATION REGULATOR

The Information Regulator has updated and made available a guide to help you understand your rights under PAIA and POPIA, and how to exercise them. This guide is available in all official South African languages.

You can direct any queries regarding this guide to the Information Regulator:

• Physical Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
• Postal Address: P.O Box 31533, Braamfontein, Johannesburg, 2017
• Email: enquiries@inforegulator.org.za
• Website: https://inforegulator.org.za/

4. RECORDS AVAILABLE IN ACCORDANCE WITH OTHER LEGISLATION

Primal Protocols retains certain records as mandated by South African law. Where applicable, information is retained in compliance with the following legislation (amongst others):

• Consumer Protection Act 68 of 2008
• Copyright Act 98 of 1978
• Cybercrimes Act 19 of 2020
• Electronic Communications and Transactions Act 25 of 2002
• Income Tax Act 58 of 1962
• Protection of Personal Information Act 4 of 2013

5. RECORDS HELD BY PRIMAL PROTOCOLS

To facilitate our operations and provide our services, we hold various categories of records. Please note that listing a category here does not mean a request for access will be automatically granted; all requests are subject to statutory grounds for refusal.

5.1 Records Automatically Available

Certain records are freely available to the public without needing to submit a formal PAIA request. These include:

• Publicly accessible website content, articles, and nutritional data.
• Website Terms and Conditions.
• Privacy Policy and Cookie Policy.

5.2 Business and Operational Records

• Internal correspondence and administrative documents.
• Strategic and operational plans.
• Domain registration and hosting agreements.

5.3 Financial Records

• Management accounts and accounting records.
• Banking records and statements.
• Tax records and returns.

5.4 IT and Security Records

• Website analytics and traffic logs.
• Cybersecurity incident logs.
• Software and platform licensing agreements.

5.5 User and Customer Records

• Newsletter subscriber lists.
• Direct correspondence, feedback, and inquiries submitted by users.

6. PROCESSING OF PERSONAL INFORMATION (POPIA)

Primal Protocols processes personal information responsibly, securely, and strictly for legitimate business purposes.

6.1 Purpose of Processing

We process data to communicate effectively with our audience, deliver requested educational content (such as newsletters), analyze website performance to improve user experience, and comply with legal obligations.

6.2 Categories of Data Subjects

• Website visitors and users.
• Newsletter subscribers.
• Service providers and independent contractors.

6.3 Categories of Personal Information

• Contact details (Names, Email addresses).
• Digital identifiers (IP addresses, cookie identifiers, browser types).
• Communication history and correspondence.

6.4 Third-Party Disclosures

We do not sell personal data. We may share necessary information with trusted third-party service providers who assist us in operating our platform, such as:

• Website hosting providers.
• Email marketing and dispatch services.
• Analytics and performance monitoring operators.

6.5 Cross-Border Data Transfers

Some of our third-party service providers (such as cloud hosts or analytics providers) may be located outside of South Africa. We ensure that data is only transferred to jurisdictions with data protection laws substantially similar to POPIA, or where we have adequate contractual safeguards in place.

6.6 Information Security

We implement reasonable technical and organizational measures to prevent loss, damage, unauthorized destruction, or unlawful access to personal information. This includes encryption, secure hosting environments, and access controls.

7. REQUESTING ACCESS TO A RECORD

If you wish to request access to a record held by Primal Protocols, you must follow the statutory procedure:

• Complete the Prescribed Form: You must complete "Form 2: Request for Access to Record", which is available for download on the Information Regulator's website at https://inforegulator.org.za/paia-forms/.
• Submission: Submit the completed form to the Information Officer via the email address listed in Section 2.
• Provide Detail: Ensure the form contains sufficient detail to allow the Information Officer to identify the exact record requested, your identity, the form of access you require, and the specific right you are seeking to exercise or protect.
• Prescribed Fees:
  • If you are requesting access to your own personal information, no request fee is charged.
  • For all other requests, a standard, non-refundable request fee must be paid before the request is processed, in accordance with the prescribed fees published by the Information Regulator (Form 3).
  • If the search and preparation of the records take longer than the statutory hours, an additional deposit may be required.

8. GROUNDS FOR REFUSAL OF ACCESS

We may, and in some cases are legally obliged to, refuse access to certain records. Grounds for refusal include, but are not limited to:

• The mandatory protection of the privacy of a third party (including a deceased person).
• The mandatory protection of commercial information of a third party (e.g., trade secrets, financial details).
• The mandatory protection of confidential information of third parties if disclosure would constitute an action for breach of a duty of confidence.
• The mandatory protection of the safety of individuals and the protection of property.
• Records that are legally privileged from production in legal proceedings.
• The commercial information of Primal Protocols, such as financial models, trade secrets, or intellectual property.

9. AVAILABILITY AND UPDATES TO THIS MANUAL

This manual is available for download on the Primal Protocols website. We will update this manual periodically to reflect changes in legislation or material changes to our business operations.