FFSA Document

PART A – PAIA MANUAL

Document Control

1. Purpose

1.1 This Manual is published in accordance with section 51 of the Promotion of Access to Information Act, 2000.

1.2 Its purpose is to:

  • set out the procedure for requesting access to records held by FFSA; and
  • describe, at a high level, the categories of records held.

1.3 Nothing in this Manual creates an automatic right of access to any record. All requests are assessed strictly in accordance with PAIA.

2. Information Officer

Title: Information Officer
Organisation: Free Flight South Africa
Email: privacy@FFSA.co.za
Postal Address: PO Box 191, Celtis Ridge, 0130

The Information Officer may designate one or more Deputy Information Officers in writing.

3. Records Available Without a PAIA Request

3.1 The following records are available without the submission of a PAIA request:

  • FFSA Memorandum of Incorporation
  • FFSA Operations Manual
  • FFSA Manual of Procedures
  • Public safety notices and circulars
  • Public information published on the FFSA website
  • Annual or regulatory reports formally released to members or authorities

4. Categories of Records Held

4.1 FFSA holds records relating to its governance, safety oversight, and regulatory functions. These include, but are not limited to:

  • Membership administration records
  • Licensing, ratings, and currency records
  • Training, instructor, and school records
  • Site and club records
  • Incident, accident, and hazard reports
  • Safety investigations and risk assessments
  • Complaints, disciplinary, and corrective action records
  • Insurance and claims-related records
  • Governance, committee, and policy records
  • Correspondence with regulators and stakeholders

4.2 Records may be held electronically, including within FFSA information systems such as MAS.

5. Grounds for Refusal or Limitation of Access

5.1 Access to records may be refused, in whole or in part, where disclosure would:

  • unreasonably disclose personal information relating to another individual;
  • compromise aviation safety, site safety, or risk management activities;
  • prejudice the effectiveness, fairness, or integrity of investigative, disciplinary, or corrective processes;
  • reveal confidential statements, safety reports, or information provided on an expectation of confidentiality;
  • expose individuals to harassment, intimidation, or unreasonable reputational harm;
  • undermine FFSA’s governance, oversight, or regulatory functions.

5.2 The existence of a record does not in itself create a right of access to that record.

6. Incident, Accident, and Safety Records

6.1 Records relating to incidents, accidents, hazards, safety reports, and safety investigations are generated and maintained primarily for safety oversight, risk mitigation, and regulatory compliance.

6.2 Such records may include:

  • witness statements;
  • preliminary findings;
  • internal analysis and recommendations;
  • correspondence with insurers or regulators.

6.3 Access to these records may be refused or limited where disclosure would reasonably be expected to:

  • discourage candid safety reporting;
  • prejudice ongoing or future investigations;
  • compromise aviation or public safety;
  • expose individuals to retaliation or undue harm.

6.4 Where appropriate, FFSA may provide summarised or anonymised information without disclosing underlying records.

7. Complaints, Disciplinary, and Corrective Action Records

7.1 Records relating to complaints, allegations, disciplinary processes, corrective actions, or sanctions are confidential by default.

7.2 Such records may include:

  • complaints and supporting material;
  • internal correspondence;
  • committee deliberations;
  • findings, recommendations, or sanctions;
  • appeal-related material.

7.3 FFSA is not obliged to disclose:

  • internal deliberations or decision-making processes;
  • evidentiary material beyond what is required by law or procedural fairness;
  • records where disclosure would undermine enforcement or governance functions.

8. Request Procedure

8.1 Requests for access to records must:

  • be submitted in writing to the Information Officer;
  • identify the record with sufficient detail;
  • state the requester’s right of access;
  • indicate the preferred form of access.

8.2 Requests may be subject to fees as prescribed by PAIA.

9. Decisions and Timeframes

9.1 FFSA will process requests within the timeframes prescribed by PAIA.

9.2 In assessing requests, FFSA will consider:

  • the rights of the requester;
  • the rights and safety of other affected persons; and
  • the integrity of FFSA’s safety, disciplinary, and governance systems.

9.3 Requests may be granted, partially granted, or refused with written reasons.

10. Remedies

10.1 A requester may lodge a complaint or pursue remedies with the Information Regulator as provided for in PAIA.