Last updated June 2024
(Prepared in accordance with Section 51 of the Promotion of Access to Information Act, No. 2 of 2000)
Introduction to JourneyCX
JourneyCX is a Customer Experience and CRM platform providing cloud-based software services including:
- Customer relationship management
- Ticketing and helpdesk solutions
- Voice/call analytics (optional)
- Sales management
- Project and task collaboration
- Billing and financial workflow tools
JourneyCX processes personal information in accordance with POPIA and complies with PAIA disclosure obligations.
Guide of the Information Regulator
(A Section 10 PAIA Guide)
A PAIA Guide containing instructions on how to exercise rights under PAIA is available from the Information Regulator.
Information Regulator (South Africa)
Email: inforeg@justice.gov.za
Website: www.inforegulator.org.za
Records Automatically Available (No Request Required)
The following may be viewed publicly on the website:
- Marketing material
- Product descriptions
- Pricing tables
- Terms of Use & Privacy Policy
- Cookie Policy
- Standard support documentation
- PAIA Manual (this document)
Categories of Records Held by JourneyCX
(Section 51(1)(e))
Records may include:
5.1 Personnel Records (Employees & Contractors)
- Employment contracts
- Payroll information
- Leave records
- Training and performance reviews
5.2 Client / Customer Records
- Subscription & billing details
- Ticket interactions
- CRM contact data
- Support logs
- Account correspondence
5.3 Company Records
- Registration documents
- Shareholder information
- Directors’ details
- Vendor agreements
- Licences, permits & certifications
5.4 Financial Records
- Invoices and statements
- Payments & receipts
- Purchase orders
- Expense records
- Tax submissions
5.5 Marketing Records
- Campaign performance
- Subscription consent records
5.6 Platform Telemetry (System Generated)
- Usage analytics (aggregate)
- Interaction logs
- Error logs
5.7 Voice Interaction/Call Analytics (Optional Modules)
- Voice recordings
- Transcriptions
- Sentiment scoring metadata
(Not biometric for identification.)
Information Available in Terms of Legislation
JourneyCX holds records required to be retained under:
- Companies Act 71 of 2008
- Income Tax Act
- VAT Act
- Basic Conditions of Employment Act
- Electronic Communications and Transactions Act
- POPIA (Act 4 of 2013)
Processing of Personal Information in Terms of POPIA
JourneyCX complies with the 8 POPIA conditions:
- Accountability
- Processing limitation
- Purpose specification
- Further processing limitation
- Information quality
- Openness
- Security safeguards
- Data subject participation
Details are expanded in our Privacy Policy.
Purpose for Processing Personal Information
We process personal information to:
- Deliver platform functionality
- Manage accounts and authentication
- Provide customer support
- Maintain compliance documentation
- Process billing and payments
- Improve service performance
- Conduct lawful analytics
Categories of Data Subjects
JourneyCX may process information relating to:
- Clients and users
- Prospective customers
- Employees and contractors
- Website visitors
Suppliers and vendors
How to Request Access to Records
Requests must be submitted using Form C (downloadable from the Information Regulator website).
Requests must be submitted to:
Email: privacy@journeycx.net
Subject: PAIA Request – {{Your Name}}
JourneyCX will respond within the statutory timeframe.
Applicable fees may apply as published by the Minister.
Grounds for Refusal of Access
JourneyCX may refuse access where disclosure would:
- Endanger personal safety
- Unreasonably invade third-party privacy
- Harm commercial confidentiality
- Reveal research in progress
- Breach legal privilege
- Contravene POPIA conditions
A refusal will always include written reasons.
Remedies Available to Requesters
If a request is refused, you may:
- Submit an internal appeal
- Lodge a complaint with the Information Regulator
- Apply to a court for relief
Security Safeguards
JourneyCX maintains:
- Encryption at rest and in transit
- Role-based access
- Data minimisation practices
- Multi-factor authentication (where enabled)
- Regular security assessments
- Access logging
Vendors are contractually bound to equivalent security standards.
Cross-Border Processing
Where data is transferred outside South Africa, JourneyCX ensures:
- Adequate protection levels
- GDPR-comparable safeguards, or
- Standard Contractual Clauses
Transfers occur only with lawful basis.
Retention and Destruction of Records
Records are retained only:
- As long as required for lawful purposes
- For contractual obligations
- For compliance with tax or accounting law
Upon expiry, records are:
- Deleted
- Destroyed securely, or
Anonymised
POPIA Compliance in This Manual
This PAIA Manual incorporates POPIA requirements relating to:
- Categories of processed information
- Purpose specifications
- Data subject rights
Cross-border transfers
Availability of the PAIA Manual
This Manual is available:
- On our website
- Electronically via email request
- At our registered office (by appointment)
No fee is charged for electronic copies.
Contact Details of the Information Regulator
Information Regulator (South Africa)
JD House, 27 Stiemens Street, Braamfontein
Email: PAIAComplaints@inforegulator.org.za (PAIA)
Email: POPIAComplaints@inforegulator.org.za (POPIA)
