PAIA Manual

This manual is published in case FaceTrust AI processes personal information of, or otherwise deals with records relating to, data subjects in South Africa, where PAIA and its section 51 requirement for a body to publish a manual describing how to request access to its records may apply. FaceTrust AI is headquartered and primarily operates in Nigeria; where PAIA does not apply to a particular request, we still aim to handle it under the equivalent process in our Data Subject Request form.

Information Officer: FaceTrust AI Compliance Team
Email: info@facetrustai.com

• Registry identity links (masked/encrypted NIN or BVN references) and matched-name data.
• Canonical face embeddings and biometric verification/audit logs.
• Account and contact records for consumers, institution staff, and operators.
• Institution onboarding records (KYB applications, licensing details, responsible-officer information).
• Commercial and billing records for institutions.
• Internal system, security, and access logs.

Submit a request through our Data Subject Request form, specifying the record you're requesting and proof of identity sufficient for us to confirm the request relates to your own data (or, for a third party requesting on someone's behalf, written authorization). We will acknowledge a request and respond within the statutory timeframe applicable to the request, or explain any delay.

We may refuse or limit access where disclosure would reveal another person's personal or biometric information, would compromise an active fraud investigation or security control (for example, details of our anti-spoofing measures), or where an exemption under PAIA or equivalent law applies. Any refusal will state the reason and your right to appeal or seek review.

We do not currently charge a fee for a standard access request. We reserve the right to charge a reasonable fee for requests that are manifestly excessive or repetitive, calculated in line with applicable regulations, and will notify you of any fee before proceeding.

This manual should be read alongside our Privacy Policy and Data Retention Policy, which describe what we collect and how long we keep it in more detail.