PAIA Manual
Prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 (as amended)
Date of compilation: 30 April 2026
1. List of Acronyms and Abbreviations
| "IO" | Information Officer |
| "PAIA" | Promotion of Access to Information Act No. 2 of 2000 (as amended) |
| "POPIA" | Protection of Personal Information Act No. 4 of 2013 |
| "Regulator" | Information Regulator of South Africa |
| "RDA" | Responsive Design Agency (Pty) |
| "Republic" | Republic of South Africa |
2. Purpose of This PAIA Manual
This PAIA Manual is useful for the public to:
- Check the categories of records held by Responsive Design Agency (Pty) which are available without a person having to submit a formal PAIA request.
- Have a sufficient understanding of how to make a request for access to a record, by providing a description of the subjects on which we hold records and the categories of records held on each subject.
- Know the description of the records which are available in accordance with any other legislation.
- Access the relevant contact details of the Information Officer who will assist the public with the records they intend to access.
- Know the description of the guide on how to use PAIA, as updated by the Regulator, and how to obtain access to it.
- Know the purpose of processing of personal information and the description of the categories of data subjects and of the information or categories of information relating thereto.
- Know the recipients or categories of recipients to whom personal information may be supplied.
- Know whether we have planned to transfer or process personal information outside the Republic of South Africa and the recipients or categories of recipients to whom such information may be supplied.
- Know whether we have appropriate security measures to ensure the confidentiality, integrity and availability of personal information which is processed.
3. Key Contact Details
3.1 Information Officer
Organisation: Responsive Design Agency (Pty), operating as Taal Rooster
Email: contact@taalrooster.co.za
3.2 Deputy Information Officer
Responsive Design Agency (Pty) has not designated a Deputy Information Officer. All access to information requests are handled directly by the Information Officer at contact@taalrooster.co.za.
3.3 Access to Information — General Contact
Email: contact@taalrooster.co.za
3.4 Head Office
Physical address: 14 Sweet Home Way, Elfindale, Cape Town, 7945, South Africa
Postal address: 14 Sweet Home Way, Elfindale, Cape Town, 7945, South Africa
Email: contact@taalrooster.co.za
Website: taalrooster.co.za
4. Guide on How to Use PAIA
The Regulator has, in terms of section 10(1) of PAIA (as amended), updated and made available the revised Guide on how to use PAIA ("Guide"), in an easily comprehensible form and manner, as may reasonably be required by a person who wishes to exercise any right contemplated in PAIA and POPIA.
The Guide is available in each of the official languages and in braille. A copy of this PAIA Manual is available in the following two official languages for public inspection during normal office hours:
- English
- Afrikaans
The Guide can be obtained:
- Upon written request to the Information Officer.
- From the website of the Information Regulator at www.justice.gov.za/inforeg/.
5. Records Available Without a Formal Request
The following categories of records are automatically available to the public without a person having to submit a formal PAIA request. These are accessible on our website.
| Category of Records | Types of Record | Available on Website | Available on Request |
|---|---|---|---|
| Legal Policies | Privacy Policy | ✓ | ✓ |
| Legal Policies | Terms of Service | ✓ | ✓ |
| Legal Policies | Refund Policy | ✓ | ✓ |
| Legal Policies | Data Processing Agreement | ✓ | ✓ |
| Legal Policies | PAIA Manual (this document) | ✓ | ✓ |
6. Records Available in Accordance with Other Legislation
The following records are created and maintained in accordance with applicable South African legislation:
| Category of Records | Applicable Legislation |
|---|---|
| PAIA Manual | Promotion of Access to Information Act 2 of 2000 |
| Privacy Policy | Protection of Personal Information Act 4 of 2013 |
| Terms of Service | Electronic Communications and Transactions Act 25 of 2002 |
| Refund Policy | Consumer Protection Act 68 of 2008; ECTA 25 of 2002 |
| Data Processing Agreement | Protection of Personal Information Act 4 of 2013 |
| Parental consent records | Protection of Personal Information Act 4 of 2013; Children's Act 38 of 2005 |
| Subscription & billing records | Tax Administration Act 28 of 2011; Companies Act 71 of 2008 |
7. Subjects on Which Records Are Held and Categories of Records
The following table describes the subjects in respect of which Responsive Design Agency (Pty) holds records and the categories of records held on each subject:
| Subject | Categories of Records |
|---|---|
| User & Account Data | Full name, email address, hashed password, role (teacher / student / school admin / moderator), school affiliation, profile data, account creation date, date of birth (for age verification), OAuth tokens (encrypted). |
| Subscription & Billing | Subscription tier, billing cycle, payment status, Paystack customer and subscription identifiers, transaction references, invoice dates. No full card numbers are stored by RDA. |
| Educational Content | Classes, assignments, rubrics, assignment instructions, explainer videos, attached images, due dates, scheduled publish dates, assignment templates. |
| Student Submissions | Video submission references (stored in school-controlled Google Drive or Microsoft OneDrive — not on RDA servers), submission timestamps, grading data, rubric scores, timestamped teacher comments, audio notes, peer feedback records, moderation checklists. |
| Usage & Audit Logs | Platform activity logs for security and compliance purposes. Logs do not contain email addresses or IP addresses. Retained for seven years. |
| Communications | Transactional emails (assignment notifications, grading alerts, parental consent requests), email delivery status, unsubscribe preferences, suppression list. |
| Consent Records | Parental or guardian consent records for minor data subjects (students under 18 years of age), consent status, consent timestamps. |
| Legal & Compliance | This PAIA Manual, Privacy Policy, Terms of Service, Data Processing Agreement, Refund Policy, and any amendments thereto. |
8. Processing of Personal Information
8.1 Purpose of Processing Personal Information
Responsive Design Agency (Pty) processes personal information for the following purposes:
- To create and manage user accounts and authenticate users on the Taal Rooster platform.
- To enable teachers to create classes, assignments, and rubrics, and to grade student video submissions.
- To enable students to submit video responses and receive graded feedback.
- To facilitate peer feedback and peer moderation workflows.
- To manage school administrator accounts and school-level configuration.
- To process subscription payments and manage billing through Paystack.
- To send transactional communications (assignment notifications, grading alerts, parental consent requests, account emails).
- To obtain and record parental or guardian consent for minor data subjects in accordance with POPIA section 35.
- To maintain audit logs for security, compliance, and dispute-resolution purposes.
- To comply with applicable South African law, including POPIA, PAIA, the Consumer Protection Act, and the Electronic Communications and Transactions Act.
8.2 Categories of Data Subjects and Personal Information Processed
| Category of Data Subjects | Personal Information That May Be Processed |
|---|---|
| Teachers | Full name, email address, school affiliation, role, account credentials (hashed), OAuth tokens (encrypted), grading and comment activity, subscription status. |
| Students | Full name, email address, date of birth, school affiliation, role, account credentials (hashed), video submission references, grades and rubric scores, peer feedback records, parental consent status. |
| School Administrators | Full name, email address, school affiliation, role, account credentials (hashed), school configuration settings. |
| Moderators | Full name, email address, school affiliation (if internal) or invitation details (if external), role, moderation checklist responses. |
| Parents / Guardians | Email address (for parental consent communications), consent status, consent timestamp. No account is created for parents or guardians. |
8.3 Recipients of Personal Information
Personal information may be shared with the following categories of recipients strictly to the extent necessary for the purposes described in section 8.1:
| Recipient / Category | Purpose |
|---|---|
| Supabase Inc. (database & auth infrastructure) | Hosting of the platform database, authentication, and realtime services. |
| Paystack (Stripe Technology Europe Limited) | Processing subscription payments in South African Rand. |
| Google LLC (Google Drive / Google Workspace) | Cloud storage of student video submissions where the school uses Google Drive as its storage provider. |
| Microsoft Corporation (OneDrive / Microsoft 365) | Cloud storage of student video submissions where the school uses OneDrive as its storage provider. |
| Sentry (Functional Software, Inc.) | Application error monitoring. Personal data (email, username, IP) is stripped before transmission; only technical error data is sent. |
| Schools and their authorised staff | Teachers, school admins, and moderators within the same school access the data of students in their classes as part of the educational service. |
| Information Regulator of South Africa | Upon lawful request in the exercise of regulatory authority under POPIA or PAIA. |
8.4 Planned Transborder Flows of Personal Information
In accordance with POPIA section 72, Responsive Design Agency (Pty) discloses the following planned transfers of personal information outside the Republic of South Africa:
| Operator | Country / Region | Categories of Information |
|---|---|---|
| Supabase Inc. | United States of America | User account data, application data, audit logs. |
| Paystack / Stripe Technology Europe | Ireland / United States of America | Subscriber identification and transaction data for billing. |
| Google LLC | United States of America (and regional data centres) | Student video files (where school uses Google Drive); OAuth tokens (encrypted). |
| Microsoft Corporation | United States of America (and regional data centres) | Student video files (where school uses OneDrive); OAuth tokens (encrypted). |
Where personal information is transferred to a third country, Responsive Design Agency (Pty) takes reasonable steps to ensure that an adequate level of protection applies, consistent with POPIA section 72 and the conditions for lawful processing set out in POPIA Chapter 3.
8.5 Information Security Measures
Responsive Design Agency (Pty) implements the following technical and organisational security measures to ensure the confidentiality, integrity and availability of personal information:
- Encryption in transit: All communications between users and the platform are encrypted using TLS/HTTPS.
- Encryption at rest: Database data is encrypted at rest via Supabase. OAuth access tokens are individually encrypted at the application layer before storage.
- Access controls: Role-based access control (teacher, student, school admin, moderator) limits data access to only what is necessary for each role. Row-level security policies are enforced at the database layer.
- Password security: Passwords are hashed using Supabase Auth's secure hashing. Passwords are checked against the Have I Been Pwned (HIBP) breach database at registration.
- Audit logging: Platform activity is logged for security and compliance purposes. Logs are retained for seven years and do not contain email addresses or IP addresses.
- Minimal data collection: IP addresses are deliberately excluded from application logs. Error reports transmitted to Sentry are stripped of personal identifiers before transmission.
- Video data ownership: Student videos are stored exclusively in the school's own Google Drive or Microsoft OneDrive account, governed by the school's agreement with those providers. RDA does not host video content on its own servers.
- Breach notification: In the event of a data breach, Responsive Design Agency (Pty) will notify affected data subjects and the Information Regulator in accordance with POPIA section 22.
9. Availability of This Manual
A copy of this PAIA Manual is available:
- On the Taal Rooster website at taalrooster.co.za/paia-manual.
- To any person upon written request to the Information Officer at contact@taalrooster.co.za. A reasonable fee, as contemplated in the PAIA Regulations, may be charged for a printed copy.
- To the Information Regulator upon request.
10. Updating of This Manual
Responsive Design Agency (Pty) will update this PAIA Manual on a regular basis to reflect changes in its records, processing activities, or applicable legislation. The current version will always be available at the address set out in section 9.
Issued by the Information Officer of Responsive Design Agency (Pty)
Date: 30 April 2026
Contact: contact@taalrooster.co.za
Contact
Business Name: Responsive Design Agency (Pty)
Trading As: Taal Rooster
Address: 14 Sweet Home Way, Elfindale, Cape Town, 7945, South Africa
Information Officer: contact@taalrooster.co.za
General enquiries: contact@taalrooster.co.za