Legal
PAIA manual
Manual under section 51 of the Promotion of Access to Information Act 2 of 2000 and section 14 of POPIA.
1. About this manual
This manual explains how a person can ask Guard Route (Pty) Ltd for access to a record, and which records it holds. The Information Regulator publishes the Guide on how to use PAIA at inforegulator.org.za. You can also contact the Regulator at [email protected] or 010 023 5200.
2. Contact details
| Item | Detail |
|---|---|
| Name | Guard Route (Pty) Ltd |
| Registration number | 2026/832780/07 |
| Physical and postal address | 15C Benacre Lane, Modderfontein, Johannesburg, Gauteng, 1609 |
| Head of the private body and Information Officer | Calvin Brink, Founder and Chief Executive Officer |
| Telephone | 082 651 1902 |
| Email for requests | [email protected] |
3. Records available without a request
These are on this website without a request: the privacy policy, the terms of use, the safety disclaimer, the cookies notice, the product and pricing pages, and this manual.
4. Records kept under other laws
Records are kept as these laws require, where they apply: the Companies Act 71 of 2008, the Tax Administration Act 28 of 2011, the Value-Added Tax Act 89 of 1991, the Income Tax Act 58 of 1962, the Consumer Protection Act 68 of 2008, the Electronic Communications and Transactions Act 25 of 2002 and the Protection of Personal Information Act 4 of 2013.
5. Categories of records held
A listing does not mean access will be given. Access depends on the grounds for refusal below.
| Subject | Categories of records |
|---|---|
| Company records | Memorandum of incorporation, registration certificate, trade mark applications, registers, resolutions and director records. |
| Financial and tax records | Accounting records, invoices, bank statements, tax and VAT returns, annual financial statements. |
| Contracts and partners | Partner agreements, order forms, non-disclosure, service level and data processing agreements, supplier contracts and correspondence. |
| Product and technical records | Source code, designs, architecture, security and operations records. These are confidential and are the company's intellectual property. |
| User records | Account and subscription status, settings, linked services, support tickets and requests made under POPIA or PAIA. |
| Compliance records | POPIA framework, register of personal information, impact assessment, breach register, request log and training records. |
| Marketing records | Waitlist and enquiry details, presentations and pitch documents. |
6. Processing of personal information
| Item | Detail |
|---|---|
| Purpose | To provide navigation and the optional safety services; to send an SOS or alert to the services a user links; to run and secure the service; to give support and manage subscriptions; to answer enquiries and send launch notices to people who asked; to meet legal duties. |
| Data subjects and information | Users: account details, location and route, saved places, alert details and optional medical and emergency contact details. Website visitors and enquirers: name, email, city. Partners and suppliers: business contact details and contracts. Fleet drivers: name, vehicle and location, where the fleet owner uses the fleet app. |
| Recipients | The services a user links; people a user chooses; service providers such as hosting, maps, analytics, crash reporting and email providers; Apple and Google; authorities and advisers where the law requires. |
| Transfers outside South Africa | Some providers process information outside South Africa. We transfer information only as section 72 of POPIA allows. |
| Security | Encrypted connections, access controls, hardened servers, backups, logging, written agreements with providers and a security compromise plan. |
7. How to request a record
Complete Form C (request for access to a record of a private body), which is on the Information Regulator's website, and send it to [email protected] or to the address above. Describe the record, the form of access you want, and your identity. If you ask for someone else, include proof that you may.
We will decide within 30 days of receiving the request and the prescribed request fee. We may extend this once, by up to 30 days, where the Act allows, and will tell you. If access is granted you pay the prescribed reproduction and search fees, which are in the PAIA Regulations on the Regulator's website.
To ask for your own personal information under POPIA, see the privacy policy.
8. Grounds for refusal
We may or must refuse access on the grounds in Chapter 4 of Part 3 of PAIA, including protecting another person's privacy, commercial or confidential information, the safety of individuals, property, and privileged records. If we refuse, you may complain to the Information Regulator or apply to court.
9. Updates
We review this manual every year and when our details change.