Every private body in South Africa must have a PAIA manual. That includes companies of every size, close corporations and sole proprietors, because the exemptions that once spared smaller businesses lapsed at the end of 2021. Most companies downloaded a template around then, filled in the blanks, and have never opened the file since. The Information Regulator checks it first precisely because it is the easiest thing to check.
What the manual is for
The Promotion of Access to Information Act gives people a route to request records a private body holds, where they need those records to exercise or protect a right. The manual is the map: what kinds of records you hold, how someone requests access, what it costs, and who your Information Officer is. It must be available at your premises, published on your website if you have one, and handed to anyone who asks, the Regulator included.
Why a stale manual is a signal
A manual naming a director who left in 2022, or listing record categories from a business you no longer run, tells an inspector that your information governance is decorative. It also fails in its actual job, because a requester following it reaches nobody. The same logic applies to the rest of the file: the Information Officer should be registered with the Regulator, and private bodies now submit an annual PAIA report to the Regulator each year by 30 June, which is difficult to complete truthfully if no one is logging requests.
The maintenance routine
- Confirm the Information Officer named in the manual still works there and is registered with the Regulator.
- Check the record categories against the business you run today.
- Publish the current version on the website and date it.
- Log every access request, even refusals, so the annual report writes itself.
- Diarise a yearly review alongside the 30 June report.
An hour a year keeps the document honest. The alternative is explaining a 2021 template to an inspector who has read a hundred of them.
When did anyone last open your PAIA manual? Tell us what’s on fire