Prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 (as amended) and the Information Regulator’s PAIA Manual Template for a Private Body.
1. List of acronyms and abbreviations
PAIA — Promotion of Access to Information Act 2 of 2000
POPIA — Protection of Personal Information Act 4 of 2013
Regulator — Information Regulator of South Africa
IO — Information Officer
DIO — Deputy Information Officer
2. Purpose of this manual
This manual is intended to foster a culture of transparency and accountability and to give effect to the right of access to information. It enables requesters to know:
- the records Learna™ holds;
- which records are available without a formal request;
- records kept in terms of other legislation;
- how to request access using Form 2;
- the prescribed fees and timeframes;
- grounds on which access may be refused; and
- how personal information is processed (POPIA particulars required by section 51).
This manual is available on the website; at the principal place of business for inspection during normal business hours; to any person on request and payment of the prescribed fee; and to the Regulator on request.
3. Contact details of the private body and Information Officer
Section 51(1)(a) requires the postal and street address, phone and fax number and email of the head of the body.
Private body
Registered legal name:
Trading name: Learna™
Registration number:
VAT number:
Physical / street address: Ashley Drive, Gillitts, Durban, KwaZulu-Natal, 3610, South Africa
Postal address:
Telephone: +27 83 273 1489
Email: hello@learna.co.za
Website: https://learna.co.za
Information Officer (head of the private body, or the person designated and registered with the Regulator)
Name: Trevor Roberts
Email: info@learna.co.za
Telephone: +27832731489
Physical address: Ashley Drive, Gillitts, Durban, KwaZulu-Natal, 3610, South Africa
Deputy Information Officer (if appointed)
Name:
Email:
Telephone:
4. Guide on how to use PAIA (section 10)
The Regulator has, in terms of section 10(1) of PAIA, updated and made available the revised Guide on how to use PAIA. The Guide is available in each of the official languages and in braille from the Regulator.
The Guide contains a description of, among other things, the objects of PAIA and POPIA; the postal and street address, phone and email of Information Officers; the manner and form of a request for access; assistance available from the IO and the Regulator; legal remedies; and how to make a complaint.
Members of the public can inspect or make copies of the Guide from the offices of the Regulator, during normal working hours, or download it from inforegulator.org.za. A copy of the Guide may also be requested from our Information Officer using Form 1.
Information Regulator (South Africa)
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
P.O. Box 31533, Braamfontein, Johannesburg, 2017
Website: https://inforegulator.org.za
General: inforeg@justice.gov.za / enquiries@inforegulator.org.za
PAIA complaints: PAIAComplaints@inforegulator.org.za
POPIA complaints: POPIAComplaints@inforegulator.org.za
5. Categories of records available without a person having to request access
The following records are automatically available on the website or on request to the Information Officer, without Form 2:
- Privacy & Cookie Policy
- Terms of Service and Terms & Conditions
- Copyright Notice
- Disclaimer
- ECTA Disclosure Notice
- Returns & Refunds Policy
- This PAIA Manual
- POPIA manual
- Information Officer page
- Public marketing pages (Home, About, Pricing, Why Join, Contact, Teacher Directory listings that are published)
- Company trading name, registration number and physical address as published in Site Details
6. Description of records available in accordance with other legislation
Records may be held, where applicable, in terms of:
- Companies Act 71 of 2008
- Income Tax Act 58 of 1962
- Value-Added Tax Act 89 of 1991
- 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
- Basic Conditions of Employment Act 75 of 1997
- Labour Relations Act 66 of 1995
- Unemployment Insurance Act 63 of 2001
- Compensation for Occupational Injuries and Diseases Act 130 of 1993
- Skills Development Act 97 of 1998
- Occupational Health and Safety Act 85 of 1993
- Children’s Act 38 of 2005 (insofar as learner accounts are concerned)
- Cybercrimes Act 19 of 2020
7. Subjects on which the body holds records and categories of records
Company and governance — CIPC documents, memorandum of incorporation, director records, resolutions, policies.
Financial and tax — invoices, statements, payment confirmations, bank records, SARS submissions, supplier invoices.
Customer and family — parent and teacher accounts; learner logins, grades and parent email routing; subscription and seat records; billing addresses; WhatsApp numbers where provided.
Teacher Directory — applications, qualifications, SACE details, police-clearance status, listing profiles, contact-request records.
Campus and learning — space and course membership, posts, progress, profile photos and covers.
Operations and IT — hosting and access logs, analytics, software licences, security logs.
Suppliers — contracts, contact details, purchase orders.
Personnel — director and staff records where staff are engaged.
Legal and compliance — contracts, complaints, PAIA/POPIA request files, incident records.
8. Processing of personal information (POPIA particulars in this manual)
8.1 Purpose of processing — to conclude and perform subscription contracts; create learner and teacher access; bill and support accounts; operate Campus and the Teacher Directory; protect children and the security of the Site; meet legal duties; and, where consent is given, send optional marketing.
8.2 Categories of data subjects and information
- Parents / customers — identity, contact, billing, subscription, WhatsApp
- Learners — first name, grade, login, parent email, Campus activity
- Teachers — identity, contact, qualifications, listing, verification documents
- Website visitors — technical and cookie data
- Suppliers and staff — as applicable
8.3 Recipients — operators who process information on our instructions (hosting, email, community software, PayFast); regulators and courts where required by law; other Campus members limited to the spaces they are authorised to use.
8.4 Planned transborder flows — some operators may store or process information outside South Africa. Transfers are handled in line with POPIA section 72.
8.5 Security measures — access control, HTTPS, least-privilege accounts, operator contracts, backups, and monitoring reasonable for a digital education platform. No method of transmission is completely secure.
9. How to request access (Form 2)
A request for access to a record of a private body must be made on Form 2 (Request for Access to Record) prescribed by the PAIA Regulations. Form 2 is available from inforegulator.org.za/paia-forms and from our Information Officer.
The requester must provide enough detail to identify the record and the requester; indicate the form of access required; specify a postal address, fax or email in South Africa; identify the right the requester seeks to exercise or protect and why the record is required; and, if the request is made on behalf of another person, submit proof of capacity.
Submit Form 2 to the Information Officer at info@learna.co.za or Ashley Drive, Gillitts, Durban, KwaZulu-Natal, 3610, South Africa. The Information Officer will assist a requester, free of charge, to complete the form where reasonably necessary.
The Information Officer will decide within 30 days of receipt (section 56). The period may be extended once by a further 30 days in the circumstances in section 57. Outcome and fees are notified on Form 3.
A complaint about a PAIA decision may be made to the Regulator on the prescribed complaint form, without affecting the right to approach a court.
10. Fees
Fees are the prescribed private-body fees published by the Regulator (see PAIA Fees Structure). The current schedule includes:
- Request fee payable by every requester: R140.00 (not payable where the requester seeks access to their own personal information)
- Photocopy / printed A4 black-and-white copy: R2.00 per page
- Computer-readable copy on a flash drive provided by the requester: R40.00
- Search and preparation: R145.00 per hour or part thereof after the first hour, capped as prescribed
- Deposit if the search is likely to exceed six hours
VAT is added if Learna™ is registered for VAT. Access may be withheld until fees are paid.
11. Grounds for refusal
Access may be refused on the grounds in Chapter 4 of PAIA (sections 62–70), including mandatory protection of privacy of a third party who is a natural person; commercial information of a third party; confidential information of third parties; safety of individuals and protection of property; legally privileged records; and research information of a third party or of the private body. Where possible, records will be severed so that the non-refusable part is disclosed (section 59).
12. Availability and updating of this manual
The head of will update this manual on a regular basis. Date of compilation and revision appear in the document meta on this page.