Tymbr
PAIA and POPIA manual
1. Purpose of this manual
PAIA gives people the right to access records held by private bodies when they need them to exercise or protect a right. POPIA regulates how personal information is processed. Section 51 of PAIA requires every private body to publish a manual explaining what records it holds and how to request them. The exemption that once applied to small private bodies ended on 31 December 2021, so this manual applies to 20 East regardless of its size.
20 East is the trading name of Gareth Saul, a sole proprietor who operates Tymbr, a transcription service at tymbr.dev.
2. Head of the private body and Information Officer
As a sole proprietor, Gareth Saul is both the head of the private body and its Information Officer. No deputy has been appointed.
| Name | Gareth Saul |
|---|---|
| Trading as | 20 East |
| Physical address | 18 Lyndhurst Road, Kenilworth, Cape Town, 7708 |
| Postal address | 18 Lyndhurst Road, Kenilworth, Cape Town, 7708 |
| Telephone | no telephone line; email hello@tymbr.dev for questions and complaints |
| hello@tymbr.dev | |
| Website | https://tymbr.dev |
3. The Information Regulator's guide
The Information Regulator has published a guide under section 10 of PAIA that explains, in every official language, how to use the Act. The guide is available from the Regulator:
The Information Regulator (South Africa)
Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191
Email: enquiries@inforegulator.org.za
Website: https://inforegulator.org.za
4. Records we hold
20 East holds the following categories of record. Access to a record is not automatic; it depends on the requester's right of access under PAIA and the grounds for refusal in Part 3 of the Act.
| Category | Examples |
|---|---|
| Business and statutory records | Tax registrations and returns, bank records, accounting records, insurance, domain and trademark records |
| Customer account records | Account email addresses, sign-in identities, device credentials, purchase and credit usage records, support correspondence |
| Customer content | Audio recordings, transcripts, speaker rosters and voiceprints stored by customers in their own Tymbr accounts. These are held by 20 East as an operator on the customer's behalf. |
| Supplier and operator records | Agreements and correspondence with Cloudflare, Mistral, Google Cloud and the payment processor |
| Technical records | Source code, system configuration, security and access logs, incident records |
| Personnel records | None. 20 East has no employees. |
5. Records available without a request
These records are published and may be read without a PAIA request:
- The Tymbr website at tymbr.dev
- The terms of service
- The privacy policy
- This manual
In addition, a Tymbr account holder can view, download and delete their own recordings, transcripts, rosters, voiceprints, device credentials and purchase history directly in the web app at app.tymbr.dev, without making a formal request.
6. Records available under other legislation
Certain records may be available under other laws, independent of PAIA, including:
- Protection of Personal Information Act 4 of 2013 (a data subject's own personal information)
- Consumer Protection Act 68 of 2008 (records of prepaid transactions and terms)
- Electronic Communications and Transactions Act 25 of 2002 (supplier information and transaction records)
- Tax Administration Act 28 of 2011 (to the South African Revenue Service)
7. How to request a record
A request for access to a record must be made on Form 2, prescribed in the PAIA Regulations of 2021. The form is available from the Information Regulator's website or from us on request. Send the completed form to the Information Officer at hello@tymbr.dev or 18 Lyndhurst Road, Kenilworth, Cape Town, 7708.
The request must:
- identify the record, or give enough detail for us to find it with reasonable effort;
- state which right you are seeking to exercise or protect, and why the record is needed for that;
- say how you would like to receive the record, for example as a copy or by inspection;
- give your contact details and, if you are acting for someone else, proof of your authority to do so.
We will respond within 30 days of receiving the request and any fee that is payable. We may extend this once by up to 30 days where the Act allows, and we will tell you if we do. If you are a data subject asking for your own personal information, we will deal with it under POPIA and will not charge the PAIA request fee.
8. Fees
PAIA allows a private body to charge a request fee and an access fee, at the amounts set in Annexure B of the PAIA Regulations of 2021 as amended from time to time. We do not set our own amounts and will quote the current prescribed amounts when we receive a request.
| Fee | When it applies |
|---|---|
| Request fee | Payable when the request is made, except by a data subject requesting their own personal information |
| Access fee | Covers search, preparation and reproduction time and materials, at the prescribed rates |
| Deposit | May be requested where search and preparation will take more than six hours, up to one third of the estimated access fee |
If a request is refused, no access fee is charged and any deposit is refunded.
9. Grounds for refusal and remedies
We may refuse access on the grounds set out in Chapter 4 of Part 3 of PAIA, including where a record would unreasonably disclose another person's personal information, would reveal commercial or confidential information of a third party, or is privileged. Where customer content is concerned, the customer is the responsible party for other people's information in their recordings, and we will refer the request to them unless the law requires us to act.
If we refuse, we will give written reasons. You may then apply to a court, or lodge a complaint with the Information Regulator at PAIAComplaints@inforegulator.org.za.
10. Processing of personal information
This section gives the information required by section 51(1)(c) to (f) of PAIA, as inserted by POPIA.
Purpose of processing
20 East processes personal information to open and secure Tymbr accounts, to transcribe and store recordings on customers' instructions, to recognise speakers where a customer has enrolled voiceprints with consent, to sell and account for prepaid credit, and to keep the service secure and lawful.
Categories of data subjects and information
| Data subjects | Personal information |
|---|---|
| Customers (account holders) | Name and email address, sign-in identity, device credentials, purchase and usage records, support correspondence, IP addresses in logs |
| People who appear in customers' recordings | Voice, words spoken, names assigned in speaker rosters, and, where the customer has obtained consent, voiceprints (biometric information, which is special personal information) |
| Suppliers and contacts | Business contact details and correspondence |
Recipients
Personal information is shared only with operators that provide our infrastructure under written processing terms: Cloudflare (hosting, storage, database, queues and sign-in), Mistral (transcription and diarisation), Google Cloud (voiceprint inference and later sign-in) and Yoco (Yoco Technologies (Pty) Ltd, South Africa) (payments). We disclose information to authorities only where the law requires.
Planned transborder flows
Audio is transcribed in the European Union by Mistral. Cloudflare and Google Cloud may process information in regions outside South Africa under contractual terms that meet section 72 of POPIA. No other cross-border flows are planned.
General security measures
All data is scoped to one account and every access is checked against it. Data is encrypted in transit and at rest, and voiceprints are separately encrypted. Production access is restricted to the Information Officer with multi-factor authentication. Customers can delete their own content at any time, and deleted content is purged from backups within 30 days. Security incidents are logged and, where personal information is affected, reported to the Information Regulator and the affected data subjects under section 22 of POPIA.
11. Where to find this manual
This manual is published at https://tymbr.dev/paia.html. A copy is available free of charge by emailing hello@tymbr.dev, for inspection at our place of business during business hours, and to the Information Regulator on request, as the PAIA Regulations require. It is available in English. It will be updated whenever the information in it changes, and at least once a year.