SmartAlex Information Officer Designation and Registration
1. Purpose and scope
This Information Officer Designation and Registration Notice (the "Notice") explains who the Information Officer of THERCSGROUP PTE. LTD., trading as SmartAlex ("SmartAlex", "we", "us", or "our"), is, how that office is designated and registered, and what the office does, when the SmartAlex platform, websites, applications, and APIs (the "Services") are used to process personal information connected with the Republic of South Africa. It is issued under the Protection of Personal Information Act 4 of 2013 ("POPIA"), read with the Promotion of Access to Information Act 2 of 2000 ("PAIA").
It supplements our Privacy Policy, our POPIA Notice, our Data Subject Request Procedure, and our PAIA Manual. Those documents own the substance of how personal information is processed, how data subjects exercise their rights, and how access to records is requested. This Notice deals only with the office of the Information Officer, its designation under the law, and its registration with the Information Regulator, and it points to the other documents rather than repeating them. Where there is a conflict between this Notice and any of those documents on the identity or duties of the Information Officer, this Notice applies; on any other question, the more specific document applies.
This Notice is a statement of how SmartAlex approaches these laws. It is not legal advice, and it does not create a contract or vary any agreement between you and us.
2. Who our Information Officer is
Under section 1 of POPIA, read with section 1 of PAIA, the Information Officer of a private body is the head of that body. For a juristic person, the head is the chief executive officer or an equivalent officer, or a person duly authorised by that officer, or the person who is acting in that capacity. The role therefore attaches to an office by operation of law. It does not require a separate act of appointment for the office holder to become the Information Officer, and the responsibility rests with the office regardless of who holds it at any time.
Our Information Officer is the person holding the office of chief executive of SmartAlex, or an equally senior person duly authorised by that office. The Information Officer function is exercised through that office and can be reached at privacy@getsmartalex.com. Where the office changes hands, the duties described in this Notice pass with the office, and this Notice is updated to reflect the new holder.
3. Registration with the Information Regulator
Under section 55(2) of POPIA, an Information Officer must be registered with the Information Regulator before taking up the duties of the office. Registration is an administrative step that identifies the office holder to the Regulator; it does not create the office, which arises by law as described in section 2.
Our Information Officer, and any Deputy Information Officers we designate, are registered with the Information Regulator as POPIA requires. Registration is completed through the Regulator's online registration facility. That facility is published by the Information Regulator, and the current registration portal can be reached from the Regulator's website at https://inforegulator.org.za. The exact portal address should be confirmed against the Regulator's website at the time of registration, as the Regulator maintains and updates it.
4. Deputy Information Officers
Under section 56 of POPIA, we may designate one or more Deputy Information Officers to assist the Information Officer in carrying out the duties of the office. A Deputy Information Officer helps discharge those duties but does not displace the office of the Information Officer, and overall accountability for compliance remains with the Information Officer.
Where we designate Deputy Information Officers, they are registered with the Information Regulator in the same way as the Information Officer. Deputy Information Officers may be designated in writing by the Information Officer. Where no Deputy Information Officer has been designated, the Information Officer carries out the duties directly.
5. What the Information Officer does
The duties of the Information Officer are set out in section 55(1) of POPIA and expanded in Regulation 4 of the Regulations made under POPIA. In plain terms, the Information Officer is responsible for the following.
- Encouraging compliance. Encouraging SmartAlex to comply with the conditions for the lawful processing of personal information under POPIA.
- Handling requests. Dealing with requests made to SmartAlex under POPIA, and with requests for access to records made under PAIA.
- Working with the Regulator. Working with the Information Regulator in relation to investigations conducted under POPIA in connection with SmartAlex, and otherwise cooperating with the Regulator.
- Compliance framework. Developing, implementing, monitoring, and maintaining a compliance framework so that the processing of personal information meets the requirements of POPIA.
- Impact assessment. Ensuring that a personal information impact assessment is done to establish whether adequate measures and standards exist to comply with the conditions for lawful processing.
- PAIA Manual. Developing, keeping up to date, and making available the manual required under PAIA. Our current manual is our PAIA Manual.
- Internal awareness. Developing internal measures, together with adequate systems, to process requests for information or access, and running internal awareness sessions about the provisions of POPIA, the Regulations, codes of conduct, and information obtained from the Regulator.
6. How to contact the Information Officer
The Information Officer is the point of contact for requests that concern personal information and access to records. A data subject who wishes to exercise a right under POPIA, such as access to, correction of, or deletion of personal information, and a requester who wishes to seek access to a record under PAIA, may contact the Information Officer at privacy@getsmartalex.com.
The formal procedures for these requests are set out elsewhere in the legal library and are not repeated here. Our PAIA Manual explains the formal access-request procedure under PAIA, including the prescribed request form (Form 2), the fees, and the grounds on which access may be refused. Our Data Subject Request Procedure explains how to make and how we handle a data subject request under POPIA.
7. Escalation to the Information Regulator
A data subject who is not satisfied with how SmartAlex has dealt with a request or with the processing of personal information may complain to the Information Regulator. The Information Officer will cooperate with the Regulator in any resulting investigation. The Regulator can be contacted at POPIAComplaints@inforegulator.org.za or through its website at https://inforegulator.org.za.
8. Updates and contact
This Notice is reviewed periodically and updated to reflect changes in South African law, in the office holders named above, or in our registration with the Information Regulator. The effective date below reflects the most recent revision. For questions about this Notice or to reach the Information Officer, contact privacy@getsmartalex.com. A South African data subject who wishes to complain about the processing of personal information may also contact the Information Regulator at POPIAComplaints@inforegulator.org.za or https://inforegulator.org.za.
This Notice is issued by THERCSGROUP PTE. LTD. (UEN 202543608D), 160 Robinson Road, #14-04 Singapore Business Federation Center, Singapore 068914, and is governed by the laws of the Republic of Singapore.
9. Version and effective date
This Notice is version 1.0 and is effective from 7 July 2026.