PAIA Manual

1. Introduction

The Promotion of Access to Information Act, 2000 ("PAIA") gives effect to Section 32 of the Constitution of the Republic of South Africa, 1996, which provides that everyone has the right of access to information held by the State and to information held by another person that is required for the exercise or protection of any rights.

This Manual is published by Eclipse Softworks, the operator of the My Vitals platform, in accordance with Section 51 of PAIA. It describes the records held by Eclipse Softworks and the procedure for requesting access to those records.

2. Contact Details of the Private Body

3. Guide on How to Use PAIA

The South African Human Rights Commission ("SAHRC") has compiled a guide on how to use PAIA. This guide is available at www.sahrc.org.za or by contacting the SAHRC directly. The guide is available in all official languages of South Africa.

4. Categories of Records Held

Eclipse Softworks holds the following categories of records in connection with the operation of the My Vitals platform:

4.1 Patient Records

• Patient registration and identity information
• Contact details (email, phone, address)
• Medical history, allergies, and current medications
• Appointment booking history and clinical notes
• Identification documents (SA ID, passport)
• Insurance and medical aid details
• Emergency contact information
• Consent records and timestamps

4.2 Healthcare Provider Records

• Doctor and clinic registration information
• HPCSA registration numbers and professional credentials
• Practice details and consultation fees
• Appointment schedules and availability
• Subscription and payment records

4.3 Financial Records

• Payment transaction records (processed via Paystack)
• Receipts and invoices
• Subscription billing history

4.4 Platform & Technical Records

• System access and audit logs
• User communications and messages (platform messaging)
• Notification preferences
• Technical logs for security and debugging

4.5 Corporate Records

• Company registration and statutory documents
• Employment and contractor agreements
• Legal correspondence and contracts
• Insurance policies

5. Subjects on Whom Records Are Held

• Patients registered on the My Vitals platform
• Doctors and healthcare practitioners
• Clinic administrators
• Pharmacies and pharmacy staff
• Employees and contractors of Eclipse Softworks
• Suppliers and service providers

6. Grounds for Refusal of Access

Eclipse Softworks may refuse a request for access to records on any of the grounds set out in Chapter 4 of PAIA, including but not limited to:

• Protection of personal information of a third party
• Commercial information of Eclipse Softworks (trade secrets)
• Research information
• Records privileged from legal proceedings
• Records whose disclosure would be contempt of court
• Records that would endanger the life or safety of an individual
• Records relating to the defence, security, or international relations of the Republic

7. How to Request Access to Records

To request access to records, a requester must submit a written request using the prescribed Form C as set out in the Regulations to PAIA (available from the SAHRC or the Information Regulator). The request must be submitted to the Information Officer at:

7.1 Information Required in the Request

• Full name and contact details of the requester
• Sufficient description of the records requested
• The form of access requested (copy, inspection, etc.)
• Proof that the requester is entitled to access the records
• If applicable, the right being exercised or protected and the reasons the records are needed

7.2 Request Fee

A request fee may be payable as prescribed by the regulations to PAIA. Requesters who are personal data subjects (patients or registered users requesting their own data) are not required to pay a request fee.

7.3 Response Timeframes

Eclipse Softworks will respond to a PAIA request within 30 days of receipt, unless extended in accordance with PAIA. An extension may be granted for an additional 30 days if the request requires an extensive search or consultation with third parties.

8. Records Available Without a Formal PAIA Request

The following records and information are publicly available on the My Vitals platform or upon request, without requiring a formal PAIA process:

• Privacy Policy
• Terms of Service
• POPIA Compliance Statement
• Disclosure of Information Policy
• This PAIA Manual

Registered patients may also access and correct their own personal information by logging in to their My Vitals account and visiting their Profile or Settings page.

9. Information Regulator

If you believe that Eclipse Softworks has failed to comply with the provisions of PAIA, you may lodge a complaint with the Information Regulator of South Africa: