PAIA & POPIA Manual

Manual prepared in accordance with Section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA) and the Protection of Personal Information Act 4 of 2013 (POPIA)

Last Updated: 15 September 2026

FOR: South African Conversations (Pty) Ltd

1. Introduction

  • This Manual is published pursuant to Section 51 of PAIA, which requires every private body to compile a manual describing the records it holds and how to request access to them. PAIA gives effect to Section 32 of the Constitution, which provides for the right of access to information held by private and public bodies.
  • This Manual also explains how to access, object to, or request correction or deletion of personal information held by us under Sections 23, 24 and 25 of POPIA.
  • This Manual is available on our website www.southafricanconversations.co.za and at our Operational Postal Address on request. A copy will be made available to the Information Regulator on request.

2. Contact details – private body

  • Name: South African Conversations (Pty) Ltd
  • Registration No: 2018/605841/07
  • CIPC Registered Office: 303 Harrow Towers, Muller Street, Yeoville, Johannesburg, 2198, Gauteng, South Africa
  • Operational Postal Address: Postnet Suite 72, Private Bag X7, Muizenberg, 7945, Cape Town, Western Cape, South Africa
  • Phone: 021 300 0547
  • Email: talk.to.us [at] southafricanconversations [dot] co.za
  • Website: www.southafricanconversations.co.za
  • Information Officer: Theresa Muller – talk.to.us [at] southafricanconversations [dot] co.za – 021 300 0547 – Postnet Suite 72, Private Bag X7, Muizenberg, 7945, Cape Town, Western Cape, South Africa
  • Deputy Information Officer: To be appointed – see section on succession below; contact Information Officer above in the meantime.

3. Guide on how to use PAIA – Section 10 Guide

  • The Information Regulator has published a Guide on how to use PAIA. The Guide is available from: The Information Regulator (South Africa), JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001. Website: https://inforegulator.org.za. Email: enquiries@inforegulator.org.za

4. Categories of records held – Section 51 of PAIA

  • We hold records under the following categories. Note that inclusion does not mean automatic access will be granted; requests will be evaluated under PAIA.
  • Company Secretarial: Incorporation documents, MOI, share register, board resolutions, CIPC correspondence (COR39, annual returns), B-BBEE certificates.
  • Financial: Accounting records, annual financial statements, tax returns, invoices, banking records.
  • Human Resources: Employee / contractor contracts (if applicable), payroll records.
  • Operational: Business plans, project records, correspondence with NPOs, story submissions (names, photos, stories with consent), newsletter subscriber lists.
  • Website and IT: Website logs, analytics, cookie data, email correspondence.
  • Legal: Agreements, NDAs, MOUs with partners and NPOs.

5. Purpose of processing personal information – Section 51 of PAIA / POPIA Section 18

  • We process personal information for:
  • Administration and management of the company
  • Communicating with data subjects, responding to enquiries
  • Sending newsletters and updates where consent given
  • Receiving, curating and publishing stories, names and photos with explicit consent
  • Providing income opportunities, information and platforms for marginalised voices
  • Website operation, security and analytics
  • Compliance with legal obligations (Companies Act, Tax Acts, POPIA, PAIA, B-BBEE)

6. Data subjects and categories of personal information

  • Website visitors and newsletter subscribers: name, email, phone, IP, cookies, usage data
  • Story contributors: name, photo, story content, location, contact details
  • NPO contacts and partners: name, organisation, email, phone
  • Service providers / contractors: name, contact, banking details
  • Employees (if any): ID, contact, employment details

7. Recipients of personal information

  • Employees and authorised representatives who need to know
  • Operators: website host, email newsletter provider, Google Analytics, accountants, legal advisors
  • Regulators and law enforcement where required by law
  • The public, where you have consented to publication of your story/name/photo

8. Planned transborder flows of personal information

  • Personal information may be transferred outside South Africa to our Operators, including Google (USA) for analytics and email service providers whose servers may be outside South Africa. We will ensure appropriate safeguards in line with Section 26 of POPIA.

9. Security measures – Section 51 of PAIA

  • We take appropriate, reasonable technical and organisational measures to secure personal information, including access controls, password protection, secure hosting, limited access on a need-to-know basis, and confidentiality agreements with Operators.

10. How to request access – Section 51 and Part 3 of PAIA

  • Use the prescribed Form 2 (Request for Access to Record) available on the Information Regulator website or from our Information Officer.
  • Submit Form 2 to the Information Officer at talk.to.us [at] southafricanconversations [dot] co.za with proof of identity and details of the record requested.
  • A request fee may be payable as prescribed. If access is granted, an access fee may apply.
  • We will respond within 30 days, with a possible 30-day extension as allowed by PAIA.
  • Grounds for refusal include mandatory protection of privacy of a third party, commercial information, confidential information, safety of individuals, and legally privileged records.

11. POPIA requests – correction, deletion, objection

  • To request access to, correction, deletion or destruction of personal information, or to object to processing, use prescribed Form 1 (Objection) and Form 2 (Correction/Deletion) under POPIA.
  • Submit to the Information Officer: talk.to.us [at] southafricanconversations [dot] co.za.
  • We will respond within a reasonable time, and action verified deletion requests within 30 days, subject to any records we are legally required to retain (see the Privacy Policy, section 9).
  • Internal process note: each request received is logged in the Data Subject Requests Log kept alongside this Manual – date received, action taken, and date completed – so that every request is tracked and actioned within the required timeframe.

12. Remedies

  • If you are not satisfied with our response you may lodge a complaint with the Information Regulator using the prescribed complaint form, or apply to court.

13. Availability of Manual

  • This Manual is available on our website www.southafricanconversations.co.za//paia-popia-manual and at our Operational Postal Address. A copy can be provided in PDF format on request.

14. Information Officer succession

  • Theresa Muller is currently the company’s sole employee and Information Officer. When the company makes its next senior hire, a Deputy Information Officer should be appointed and registered with the Information Regulator. This Manual, and the company’s Master Action List, should be updated at that time with the appointee’s details.

15. Updating of Manual

  • We may update this Manual from time to time. The current version will be posted on our website with the Last Updated date.

Signed: Theresa Muller – Information Officer – 15 September 2026