PAIA Manual

1. Purpose

This manual is published in accordance with Section 51 of the Promotion of Access to Information Act, 2000 (PAIA). It describes the records held by Orion DevCore, the procedures for requesting access, and the applicable fees.

2. Company Details

Business Name

Orion DevCore (sole proprietorship)

Owner

Graham Schubach

Email

graham@oriondevcore.com

Phone

+27 72 497 1810

Website

oriondevcore.com

Postal Address

26 Vasco da Gama, Jeffreys Bay, 6330

3. Records Available

Orion DevCore holds the following categories of records:

Company Records

• CIPC registration documents
• Contracts and agreements
• Financial records and tax returns

Customer Records

• Names, phone numbers, email addresses (where provided)
• Conversation logs with Naledi AI assistant
• Billing and payment history

Technical Records

• System logs (non-personal, operational)
• AI model usage data (aggregated)

Other Records

• Correspondence (email, WhatsApp messages)
• Marketing materials

4. Automatically Available Records

The following records are available without needing to submit a formal PAIA request:

• Our full Terms of Service and Privacy Policy
• The Naledi Privacy Notice
• This PAIA manual
• Information available on our website at oriondevcore.com

5. How to Request Access

To request access to records not already publicly available:

1. Complete the prescribed Form C (available at inforegulator.org.za)
2. Submit the completed form to: graham@oriondevcore.com
3. Include sufficient detail to identify the record(s) requested
4. Indicate the form of access required (copy, inspection, etc.)

We will respond within 30 days of receipt. If the request is for a large volume of records, we may extend this period by a further 30 days, with written notice.

6. Fees

PAIA prescribes the following fee structure (as per the latest Government Gazette):

• Request fee: R50.00 (payable on application)
• Access fee: Variable depending on the format and volume of records
• Photocopy/print: R1.10 per page (A4)
• Electronic copy: R1.50 per file

You will be notified of the estimated access fee before the request is processed. Fees are waived for personal requests where the total is under R100.

7. Grounds for Refusal

Access may be refused on grounds including but not limited to:

• Mandatory protection of personal information (POPIA)
• Commercial confidentiality
• Legal privilege
• Security of property
• Records containing third-party personal data
• Burden on the organisation (voluminous or complex requests)

Any refusal will be accompanied by written reasons.

8. Remedies

If you are dissatisfied with our response to a PAIA request:

1. Internal appeal: Contact the owner at graham@oriondevcore.com within 30 days
2. External appeal: Lodge a complaint with the Information Regulator