VarsityOS
PAIA Manual
Section 51 Manual · Promotion of Access to Information Act 2 of 2000
Last updated: 14 June 2026 · Reporting year: 1 April 2025 – 31 March 2026
Section 51 Manual — Private Body
This manual is compiled by Mirembe Muse (Pty) Ltd in terms of Section 51 of the Promotion of Access to Information Act 2 of 2000 ("PAIA"). It describes how members of the public may request access to records held by the company.
1. Details of the Private Body
Company name: Mirembe Muse (Pty) Ltd
Trading as: VarsityOS (varsityos.co.za)
Company type: Private company registered in South Africa
POPIA Registration No.: 2026-005658 (Registration Date: 3 April 2026)
Information Officer
Name: Nandawula Kabali-Kagwa
Appointed: 28 August 2025
Email: privacy@mirembemuse.co.za
Alternate email: privacy@varsityos.co.za
PAIA requests submitted to the Information Officer must be addressed in writing to the above email addresses. Postal and physical address available on written request.
Information Regulator (Supervising Authority)
The Information Regulator of South Africa oversees PAIA and POPIA compliance.
Website: www.inforeg.org.za
Email: inforeg@justice.gov.za
Tel: 010 023 5200
Physical: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
2. PAIA Guide
The Information Regulator has published a PAIA Guide describing how to use the Act to request records from public and private bodies. The Guide is available free of charge from:
- The Information Regulator website: www.inforeg.org.za
- The PAIA Unit, Department of Justice and Constitutional Development
- Any Public Library in South Africa
The Guide is available in all 11 official languages of South Africa.
3. Records Available Without a PAIA Request
The following documents are publicly available and do not require a formal PAIA request:
- This PAIA Section 51 Manual (varsityos.co.za/paia)
- Privacy Policy (varsityos.co.za/privacy)
- Terms and Conditions (varsityos.co.za/terms)
- Product pricing and subscription tiers (available on our website)
- POPIA Registration confirmation (available on request, no fee)
4. Records Available for Inspection
The following categories of records are available for inspection subject to payment of the prescribed fee and submission of a valid Form C request:
- Company registration documents (CIPC)
- POPIA registration certificate (Information Regulator)
- General corporate records required to be available by law
5. Categories of Records Held
Mirembe Muse (Pty) Ltd holds the following categories of records in the course of operating VarsityOS:
User Account Records
- Names and email addresses of registered users
- Authentication credentials (hashed passwords — not recoverable)
- Account creation and last-login dates
- Subscription tier and payment status
Academic & Personal Records
- University, faculty, year of study, and module information voluntarily entered by the user
- Study tasks, deadlines, timetable entries, and exam schedules entered by the user
- AI conversation history with Nova (stored only for paid subscribers)
Financial Records (User-Entered)
- Monthly budget allocations and expense records entered by the user
- NSFAS allowance amounts entered by the user
- Savings goals and stokvel contribution records entered by the user
Health & Wellness Records
- Sleep logs, mood entries, and fitness records voluntarily entered by the user
- Wellness check-in responses
Payment & Transaction Records
- Subscription payment history (amounts, dates, transaction IDs)
- Payment status records from Paystack
- Refund records
Technical & Security Records
- Server access logs (IP address, request timestamps)
- Error logs and crash reports
- Security event records (failed logins, suspicious activity flags)
Corporate Records
- Contracts and agreements with suppliers and service providers
- Employee and contractor records
- Internal financial statements and tax records
Note: records held by third-party processors (Supabase, Anthropic, Paystack, Vercel) on our behalf are subject to their own PAIA/data access regimes. We will assist with directing requests to the relevant party where appropriate.
6. How to Submit a PAIA Request
To request access to records held by Mirembe Muse (Pty) Ltd, follow these steps:
Obtain Form C
Download the prescribed Form C from the Information Regulator website (inforeg.org.za) or request it from our Information Officer at no charge.
Complete Form C
Provide your full name, contact details, a description of the records you require, and the reason for the request. Be as specific as possible to enable us to locate the relevant records.
Pay the Request Fee (R50)
A non-refundable request fee of R50.00 is payable before we are required to process your request (Section 54(1) of PAIA). See the fees schedule in Section 7 below.
Submit to Information Officer
Email completed Form C and proof of fee payment to privacy@varsityos.co.za. Mark the subject line: PAIA Request — [Your Name].
Response Timeline
We will respond within 30 days of receipt of a valid request (Section 56 of PAIA). If we need more time, we may extend by a further 30 days and will notify you in writing. If your request is granted in part or refused, we will provide written reasons.
Important: PAIA vs POPIA Rights
If you are requesting access to your own personal information held by us, you may also exercise your rights under POPIA Section 23 by emailing privacy@varsityos.co.za directly — no Form C or request fee required. See our Privacy Policy for details.
7. Prescribed Fees Schedule
Fees are prescribed by the Minister of Justice under Section 54 of PAIA. The following fees apply (as per PAIA Regulations, last amended 2021):
| Item | Fee |
|---|---|
| Request fee (non-refundable, payable upfront) | R 50.00 |
| Search, preparation, and reproduction — per hour (first hour free) | R 30.00/hr |
| Photocopy / printout — per A4 page | R 1.10/page |
| Electronic file (PDF or similar) — per file | R 7.50/file |
| USB flash drive or other storage medium | Actual cost |
| Postage (if records sent by post) | At cost |
| Deposit — 1/3 of estimated access fee (if search time exceeds 6 hrs) | As calculated |
Requesters who demonstrate they are unable to afford fees may apply for waiver in terms of Section 54(8) of PAIA. Indigent requesters (including students who meet the criteria) may request fee exemption by providing supporting documentation.
8. Grounds for Refusal
We may refuse a PAIA request on the following grounds (Sections 63–70 of PAIA):
- The records contain the personal information of a third party who has not consented to disclosure (s63)
- Disclosure would constitute an unreasonable invasion of privacy of a third party (s63)
- The records contain confidential third-party commercial information (s64)
- The records contain confidential communications between the company and its legal advisors (s65)
- Disclosure of the records would endanger the safety or health of an individual (s66)
- The records contain internal deliberative processes that, if disclosed, could harm the company's decision-making functions (s67–68)
- Disclosure is prohibited under another law (s70)
- The request is manifestly frivolous or vexatious, or the disclosure of records would be an abuse of the right of access (s45)
Any refusal will be provided in writing with reasons. You have the right to appeal a refusal internally (to our Information Officer) and thereafter to seek review by the Information Regulator or the court.
9. Internal Remedies and Appeals
If we refuse your request or do not respond within the prescribed period:
- Internal appeal: Submit a written appeal to the Information Officer at privacy@varsityos.co.za within 180 days of the decision
- Complaint to the Information Regulator: Lodge a complaint at inforeg.org.za
- Court application: Apply to the High Court for an order compelling disclosure under Section 82 of PAIA
10. Annual Report — 2025/2026
Reporting period: 1 April 2025 – 31 March 2026 · Submitted to the Information Regulator per Section 32(2) of PAIA.
| Category | Count |
|---|---|
| Total PAIA requests received | 0 |
| Requests granted in full | 0 |
| Requests granted in part | 0 |
| Requests refused | 0 |
| Requests withdrawn by requester | 0 |
| Requests deemed refused (no response in time) | 0 |
| Requests pending at year-end | 0 |
| Internal appeals lodged | 0 |
| Appeals upheld | 0 |
| Referrals to the Information Regulator | 0 |
Reporting entity: Mirembe Muse (Pty) Ltd (VarsityOS)
Information Officer: Nandawula Kabali-Kagwa
Signature date: 14 June 2026
Next report due: On or before 31 May 2027 (for period 1 April 2026 – 31 March 2027)
This report was submitted to the Information Regulator in terms of Section 32(2) of the Promotion of Access to Information Act 2 of 2000. Mirembe Muse (Pty) Ltd became operational in August 2025 and received no PAIA requests during its first reporting year.
11. Updates to This Manual
This manual will be reviewed and updated at least annually. Material changes will be reflected with an updated "Last updated" date. Mirembe Muse (Pty) Ltd will update this manual within 30 days of any change to its structure, records held, or fees schedule. The current version is always available at varsityos.co.za/paia.