PAIA Manual
Effective date: 1 September 2026
This is the manual required by section 51 of the Promotion of Access to Information Act 2 of 2000 ("PAIA"). Every private body must publish one. The exemption that covered small private bodies ended on 31 December 2021, and a sole proprietor is a private body for this purpose.
The manual sets out what records Chatleadr holds, how to ask for access to one, what it costs, and what to do if a request is refused.
1. Contact Details#
| Name | Jadin Roste Andrews, trading as Chatleadr |
| Legal status | a sole proprietor trading in the Republic of South Africa |
| Physical and postal address | 71 Old Main Rd, Hillcrest, 3650 |
| Information Officer | Jadin Roste Andrews |
| support@chatleadr.com | |
| Website | https://chatleadr.com |
POPIA makes the head of a private body its Information Officer. Requests under PAIA, and requests under POPIA to access, correct or delete personal information, all go to the address above.
2. Section 10 Guide#
The South African Human Rights Commission published a guide explaining how to use PAIA. It is available from the Information Regulator, which now carries the function, at https://inforegulator.org.za, and from the Regulator's enquiries address. The guide is published in each official language and is free.
Requesters who need help completing a request may contact the Information Officer at the address in section 1.
3. Records Available Without a Request#
No notice has been published under section 52(2) of PAIA. There is therefore no category of record that is automatically available without a request, other than the material already published on our website, which anyone may read without asking.
That material includes the Terms of Service, Acceptable Use and AI, the Privacy Policy, the Data Processing Terms, the sub-processor list, our published pricing and our product documentation.
4. Records Held, by Subject#
The table lists the subjects on which records are held and the categories of record under each. Listing a record here does not mean it will be released: a request is decided against the grounds of refusal in Chapter 4 of PAIA, which protect a third party's personal information, commercial information and legally privileged material.
| Subject | Categories of record |
|---|---|
| Customer accounts | Account and contact details, workspace and bot configuration, knowledge documents, workflows |
| Conversations and leads | Conversation transcripts, captured lead records, files uploaded through a form, suppression and opt-out records |
| Billing | Plan and subscription records, invoices and payment references issued by our payment provider, conversation usage counts and the credit ledger |
| Suppliers and sub-processors | Agreements with the companies listed on the sub-processor list |
| Statutory and tax | Records kept under the Income Tax Act and the Tax Administration Act |
| Operations | System and activity logs, security records, correspondence with customers |
Records about conversations and leads are usually not ours to release. Where a bot built by one of our customers collected the information, that customer is the responsible party and we hold it on their instructions. A request for it is directed to them, and section 10 of the Privacy Policy explains what to do if the requester cannot identify them.
5. Records Held Under Other Legislation#
Records are also held in terms of the following, so far as each applies:
- Income Tax Act 58 of 1962
- Tax Administration Act 28 of 2011
- Value-Added Tax Act 89 of 1991
- Electronic Communications and Transactions Act 25 of 2002
- Protection of Personal Information Act 4 of 2013
- Consumer Protection Act 68 of 2008
6. How to Make a Request#
- Complete Form C, the prescribed form for a request to a private body, in the Regulations to PAIA. The Information Regulator publishes it at https://inforegulator.org.za.
- Give enough detail to identify the record, and state the right you are seeking to exercise and why the record is required to exercise or protect it.
- Say how you want to receive the record, and give an address, an email address or a telephone number.
- Where you are asking on behalf of somebody else, attach proof of your authority.
- Send it to the Information Officer at the address in section 1.
We will decide the request within 30 days and tell you the outcome, the fee payable if access is granted, and your right of appeal. That period may be extended once by up to 30 days where the request covers a large number of records or requires a search of records held elsewhere. Where the record contains a third party's information, that party is given notice and the period is extended accordingly.
7. Fees#
Two fees apply, both set by the Regulations to PAIA.
A request fee is payable when a request is made. An access fee is payable before a granted record is released, and covers reproduction, search and preparation time, and postage.
A personal requester, meaning somebody asking for a record about themselves, pays no request fee.
The current amounts are those in the Regulations at the time of the request, and the Information Officer will confirm them in the decision.
8. If a Request Is Refused#
The decision will state the reason and the provision of PAIA relied on.
An internal appeal does not apply to a private body. A requester who is not satisfied may:
- Complain to the Information Regulator under section 77A of PAIA, within 180 days of the decision. The Regulator's contact details are at https://inforegulator.org.za.
- Apply to a court under section 78 of PAIA.
A third party whose information is affected by a decision to grant access has the same routes.
9. Processing of Personal Information#
The following is required by the amendment PAIA takes from POPIA. Each item is covered in full in the Privacy Policy, and the section is named.
| Purpose of processing | Section 5 for account information, section 4 for conversation information |
| Categories of data subject and information | Sections 2, 3 and 4 |
| Recipients | Section 8 and the sub-processor list |
| Cross-border transfers | Section 9 |
| Security measures | Section 11 |
10. Availability of This Manual#
This manual is published on our website and may be read or downloaded free of charge. A copy is available from the Information Officer on request, and is lodged with the Information Regulator.
We will update it when the information in it changes, and at least once every three years as PAIA requires.