Brynne98

PAIA Manual

Prepared under section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA), following the Information Regulator’s template for private bodies. Last updated: 17 October 2026.

1. About this manual

This manual is for Brynne Prince, a sole proprietor in South Africa who publishes the Health Switch RSA app for iPhone and Android. It says what records we hold, how to ask for them, and how we process personal information under the Protection of Personal Information Act 4 of 2013 (POPIA).

2. Contact details

The head of this private body, and its Information Officer under POPIA, is Brynne Prince. There is no Deputy Information Officer.

3. The Regulator’s guide to PAIA

The Information Regulator publishes a guide on how to use PAIA and POPIA, in every official language and in braille. It explains the rights in both Acts, how to make a request, the fees, and every remedy, including a complaint to the Regulator or an application to court.

Get the guide from the Regulator’s website, https://inforegulator.org.za/paia-guidelines/, or ask us by email and we will send it.

Information Regulator

4. Records available without a request

Anyone may read these without a PAIA request:

5. Records kept under other laws

We keep records that these laws require, where they apply:

6. Records we hold

Subject Records
The directory Hospital and ward numbers, and every earlier version of each entry.
Imported directory The original Accurx export, kept as received.
Contributions Who changed what (by anonymous installation identity), when, and reports that a number does not work.
Feedback and ideas Text sent from the App’s Feedback and Feature ideas screens.
Sales Subscription sales reports from Apple, Google and RevenueCat. These hold no names or card details.
App health Usage analytics, crash reports and launch-speed reports.
Correspondence Emails sent to us.
Finance and tax Store payouts, invoices and tax records.

7. Processing of personal information

7.1 Purpose

To run the App and its shared directory, to process and restore purchases, to fix crashes and keep the App fast, to show ads to phones without Pro, and to answer people who contact us. The Privacy Policy gives the detail for each.

7.2 Data subjects and their information

Data subject Information
People who use the App Anonymous installation identities, contributions, reports, feedback, purchase history (product, date, price), device model and system version, usage events, crash reports, and, through AdMob, an advertising identifier where allowed and an approximate location from the IP address.
People named in the directory Work names or roles, and the hospital line they answer.
People who email us Name, email address and what they wrote.

The App never asks for names, email addresses, phone numbers, professional registration or patient information.

7.3 Recipients

The services that process data for us, each for the purpose given in the Privacy Policy: Convex (server), Expo (updates and launch speed), PostHog (analytics), Sentry (crash reports), RevenueCat (purchases), Google AdMob (ads), and Apple and Google (app stores and payment). Contributions are shown to every user of the App. We do not sell personal information.

7.4 Transfers outside South Africa

Convex and Expo are in the United States. PostHog and Sentry use EU servers. Google, Apple and RevenueCat may process data in the United States and other countries. These transfers follow section 72 of POPIA, as set out in the Privacy Policy.

7.5 Security

Data travels encrypted (HTTPS) between the App and each service. The anonymous identity is kept in the phone’s secure storage. Only the publisher has admin access to the server and the services’ dashboards.

8. How to ask for a record

  1. Fill in Form 2 (Request for Access to Record), from the Regulator: https://inforegulator.org.za/wp-content/uploads/2020/07/InfoRegSA-PAIA-Form02-Reg7.pdf
  2. Email it to brynneprince98@gmail.com with proof of identity. If you ask for someone else, add proof that you may act for them.
  3. Say which records you want, the form of access you want (copy, email, inspection), and how we should reply.
  4. For a record that is not your own personal information, say which right you want to use or protect, and why you need the record for it (PAIA section 53).

If you cannot fill in the form because of illiteracy or a disability, you may make the request by email or phone after contacting us, and we will help.

A request for your own personal information, or to correct or delete it, can also be made under POPIA by a plain email. See “Your rights” in the Privacy Policy.

9. Fees

PAIA allows a request fee and an access fee, as set in the PAIA Regulations. We charge no request fee. If a request needs copies or time beyond what the Regulations allow free of charge, we will tell you the fee before we do the work. There is never a fee to ask for your own personal information.

10. Decision and refusal

We decide within 30 days of receiving the request and tell you the result, with reasons if we refuse. We may extend this once, by up to 30 days, for a large or complex request, and will tell you in writing.

We may refuse access on the grounds in Chapter 4 of Part 3 of PAIA, mainly to protect:

We also refuse requests that are clearly frivolous or vexatious, or that would take an unreasonable diversion of resources.

If you disagree with a decision, you may complain to the Information Regulator within 180 days, or apply to court.

11. Availability and updates

This manual is published at https://brynne98.github.io/health-switch/paia.html and sent free on request. We update it when what we hold or how we process it changes. The date at the top shows the latest version.