PAIA Manual
Version 2026-10-12. This manual is published under section 51 of the Promotion of Access to Information Act, 2000 (PAIA), as amended by the Protection of Personal Information Act, 2013 (POPIA). It explains what records Spens Slim keeps and how to ask for them.
1. About Spens Slim
Spens Slim is a web app for tracking the food in a home pantry, sold by subscription. It is a private body: a sole proprietorship owned and run by Ian Frost. Its website is https://spensslim.co.za.
2. Contact details of the head of the private body
- Head of the private body and Information Officer: Ian Jonathan Frost
- Information Officer registration (Information Regulator): 2026-068940
- Street address (also the postal address): 1 Springwell Avenue, Willaway, Midrand, Gauteng, South Africa
- Cellphone / WhatsApp: 071 641 0589
- Email: nova_f2026@outlook.com
There is no Deputy Information Officer.
3. The Regulator's Guide on PAIA
The Information Regulator publishes a Guide (section 10 of PAIA) that explains how to use PAIA and POPIA. It is available in every official language.
- You can get it from the Information Regulator's website, inforegulator.org.za/paia, or by asking the Regulator (Form 1).
- You can also ask Ian for a copy. It is free and is sent by email or WhatsApp.
Information Regulator: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191. Email: enquiries@inforegulator.org.za.
4. Records available without a request
These records are freely available on the website, with no PAIA request and no fee:
- Terms of use and subscription, including the price
- Privacy Notice
- This PAIA Manual
Customers can see and download their own pantry and account information at any time with Account & settings → Download all my data. This is also free.
5. Records kept under other laws
Some records are kept because these laws require it (where they apply):
- Income Tax Act, 1962 and Tax Administration Act, 2011
- Value-Added Tax Act, 1991
- Electronic Communications and Transactions Act, 2002
- Consumer Protection Act, 2008
- Protection of Personal Information Act, 2013
- Promotion of Access to Information Act, 2000
- Copyright Act, 1978
6. Subjects and categories of records held
- Customer accounts: pantry name, cellphone number, names of household members, PIN hash, plan and paid-until date, date and version of terms accepted, admin notes (for example, the date and amount of a payment).
- Customer pantry data: items, counts, barcodes, product names and pictures, the history of what was added and taken out, and the shopping list.
- Payments and finance: EFT payments received, refunds, bank statements, and tax records.
- Correspondence: WhatsApp messages and emails with customers and suppliers.
- Security records: short-lived records of wrong-PIN attempts and sign-ups by internet (IP) address, and a log of PIN resets (date and method, never the PIN).
- Suppliers and services: agreements and invoices for hosting (Cloudflare) and the domain name (xneelo).
- Legal and compliance: the Terms, the Privacy Notice, this manual, the Information Officer registration, and records of PAIA and POPIA requests.
- Intellectual property: the Spens Slim app, its name, design and source code.
7. How personal information is processed (POPIA)
- Purpose: to provide the pantry service, keep accounts secure, manage trials and subscriptions, and keep records that the law requires.
- Who the information is about, and what it is:
- Customers: cellphone number, names, pantry contents and history, payment records.
- People named in a household: first names or nicknames only.
- Suppliers: business contact details and invoices.
- Who receives it:
- Cloudflare, Inc., which hosts the app and database.
- SMSPortal (South Africa), which receives a cellphone number and a one-time code, only when a customer uses "Forgot your PIN?".
- Open Food Facts, which receives barcode numbers only.
- WhatsApp, only when a customer chooses to use it.
- SARS and other authorities, where the law requires it.
- Sending it outside South Africa: Cloudflare may store or process information in other countries, under data-processing terms that give protection comparable to POPIA (section 72).
- Security:
- all connections are encrypted (HTTPS)
- PINs are stored only as one-way hashes
- wrong PIN attempts are limited
- each household can see only its own data
- admin access is limited to Ian
- database backups are kept for 30 days
The Privacy Notice has the full details.
8. How to request access to a record
- If it is your own data: download it from the app first. For anything else about yourself, simply WhatsApp or email Ian. No form or fee is needed for a customer's own personal information (POPIA section 23).
- Other records: fill in Form 2 (Request for Access to Record) and email it to Ian. Include:
- proof of who you are
- enough detail to identify the record
- how you want access (a copy by email, or to look at it)
- which of your rights the record is needed to exercise or protect (PAIA section 53)
- Ian will tell you the outcome within 30 days. In the cases PAIA allows, he may extend this once by up to 30 more days, and he will tell you why.
- A request may be refused only on the grounds in Chapter 4 of Part 3 of PAIA. Examples are protecting another person's privacy, a third party's commercial information, and legally privileged records. You will be told the reason.
- If you are not satisfied: Spens Slim is a private body, so there is no internal appeal. You can complain to the Information Regulator (Form 5) or apply to court, within 180 days.
9. Fees
These are the prescribed fees for private bodies (PAIA Regulations, 2021). No fee is charged for your own personal information, or for the records in section 4.
| Item | Fee |
|---|---|
| Request fee (not for your own personal information) | R140.00 |
| Printed or photocopied A4 page | R2.00 per page |
| Copy on a flash drive or CD you provide | R40.00 |
| Copy on a CD provided by Spens Slim | R60.00 |
| Transcription of audio, per A4 page | R24.00 |
| Search and preparation, after the first hour | R145.00 per hour or part, at most R435.00 |
| Postage | Actual cost (email is free) |
If the search would take more than 6 hours, a deposit of one third of the access fee may be asked for first. If you are refused access, the deposit is refunded.
10. Where to find this manual
This manual is on the website at spensslim.co.za/paia. A copy is available free from Ian, and it will be given to the Information Regulator on request. It will be updated whenever something important changes.