1. Introduction

This Promotion of Access to Information Act (“PAIA”) Manual is prepared in accordance with Section 51 of the Promotion of Access to Information Act 2 of 2000 (“PAIA”), as amended by the Protection of Personal Information Act 4 of 2013 (“POPIA”).

The purpose of this Manual is to:

• Inform members of the public of the categories of records held by the Company;
• Explain how to request access to records held by the Company;
• Describe the processing of personal information by the Company;
• Provide contact details for requests relating to PAIA and POPIA; and
• Promote transparency, accountability, and lawful access to information.

This Manual is available on the Company’s website and may also be requested from the Information Officer.

2. Definitions

Unless otherwise indicated, terms used in this Manual shall bear the meanings assigned to them in PAIA and POPIA.

• “Company” means WritersHand Studios (Pty) Ltd.
• “Information Officer” means the person duly appointed in terms of POPIA.
• “PAIA” means the Promotion of Access to Information Act 2 of 2000.
• “POPIA” means the Protection of Personal Information Act 4 of 2013.
• “Requester” means any person requesting access to records held by the Company.
• “Record” means any recorded information regardless of form or medium.

3. Company Details

Company Name: WritersHand Studios (Pty) Ltd
Registration Number: [Registration Number]
Physical Address: Unit 1, 3 Belvedere Road, Muizenberg, Cape Town
Postal Address: 7950
Telephone Number: +27 87 135 0111
Email Address: [email protected]
Website: https://www.writershandstudios.com

4. Information Officer Details

The Company has appointed the following Information Officer in accordance with POPIA:

Information Officer: Jody Kolbee
Email Address: [email protected]
Telephone Number: +27 87 135 0111

All requests for information and/or personal information should be directed to the Information Officer.

5. Guide on How to Use PAIA

A guide on how to use PAIA is available from the Information Regulator.

Contact Details of the Information Regulator

Information Regulator (South Africa)
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001

General Enquiries: 010 023 5200
Website: Information Regulator South Africa
Email: [email protected]

6. Applicable Legislation

The Company retains records in accordance with legislation applicable to its operations, which may include but is not limited to:

• Promotion of Access to Information Act 2 of 2000
• Protection of Personal Information Act 4 of 2013
• Companies Act 71 of 2008
• Labour Relations Act 66 of 1995
• Basic Conditions of Employment Act 75 of 1997
• Employment Equity Act 55 of 1998
• Income Tax Act 58 of 1962
• Value Added Tax Act 89 of 1991
• Electronic Communications and Transactions Act 25 of 2002
• Consumer Protection Act 68 of 2008
• Copyright Act 98 of 1978

7. Categories of Records Held by the Company

The Company maintains records including, but not limited to, the following categories:

7.1 Corporate Records

• Company registration documents
• Memorandum of Incorporation
• Shareholder records
• Director records
• Statutory records

7.2 Financial and Accounting Records

• Financial statements
• Tax records
• Invoices and receipts
• Banking records
• Audit reports

7.3 Human Resources Records

• Employment contracts
• Payroll records
• Leave records
• Employee disciplinary records
• Training records

7.4 Operational Records

• Service agreements
• Supplier agreements
• Client contracts
• Marketing materials
• Internal policies and procedures

7.5 Information Technology Records

• Website information
• System logs
• Security protocols
• Electronic communications

7.6 Customer and Client Records

• Customer contact details
• Service history
• Communication records
• Support records

8. Records Automatically Available

Certain records may be made available automatically without the need to submit a formal PAIA request, including:

• Marketing brochures
• Public website content
• Company profiles
• Published articles
• Publicly available terms and conditions
• Public policies and notices

9. Processing of Personal Information in terms of POPIA

9.1 Purpose of Processing Personal Information

The Company may process personal information for purposes including:

• Providing products and services;
• Managing customer relationships;
• Human resources and employment administration;
• Marketing and communication;
• Compliance with legal and regulatory obligations;
• Website administration and analytics;
• Security and fraud prevention.

9.2 Categories of Data Subjects and Personal Information

Customers and Clients

• Names and surnames
• Contact details
• Billing information
• Identification numbers where required

Employees

• Employment history
• Payroll information
• Qualifications
• Banking details

Suppliers and Service Providers

• Business information
• Contact details
• Banking information

10. Recipients of Personal Information

The Company may share personal information with:

• Employees and authorised personnel;
• Professional advisors;
• Regulatory authorities;
• IT service providers;
• Payment processors;
• Third-party contractors where necessary.

The Company takes reasonable technical and organisational measures to protect personal information.

11. Request Procedure in terms of PAIA

A requester seeking access to records held by the Company must submit a written request to the Information Officer.

The request should contain:

• Full names and contact details of the requester;
• Adequate description of the record requested;
• The format in which access is requested;
• Proof of identity where applicable;
• Proof of authority where acting on behalf of another person.

Requests may be submitted via email or delivered to the Company’s registered address.

12. Prescribed Fees

Applicable request fees and access fees may be payable in accordance with PAIA regulations.

The requester will be informed of:

• Any applicable request fee;
• The manner of payment; and
• Whether an access fee is payable before access is granted.

13. Grounds for Refusal of Access

Access to records may be refused in terms of PAIA where:

• The disclosure would involve unreasonable disclosure of personal information;
• The information is commercially confidential;
• The record is privileged from production in legal proceedings;
• Disclosure would endanger safety or security;
• The request is frivolous or manifestly vexatious.

14. Remedies Available

If a requester is dissatisfied with a decision of the Company, the requester may:

• Lodge a complaint with the Information Regulator; or
• Apply to a court of competent jurisdiction for appropriate relief.

15. Availability of this Manual

This Manual is:

• Available on the Company website; and
• Available for inspection upon request at the Company’s offices.

16. Updating of this Manual

The Company reserves the right to amend this Manual from time to time to reflect changes in legislation, operational requirements, or business practices.

17. Version Control

Version: 1.0
Effective Date: 01 June 2025
Last Updated: 27 July 2025