PAIA Manual
Version 1 · Last updated: November 2026
1. About This Manual
This manual is published by Life Therapy (Pty) Ltd (registration no. 2019/570691/07) under section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA). PAIA gives everyone the right to ask for access to records a private body holds, where the record is needed to exercise or protect a right. This manual describes the records we hold, how to ask for them, what it costs, and how we process personal information under the Protection of Personal Information Act 4 of 2013 (POPIA). It is available on our website and, on request, at our place of business. A printed copy may be asked for at the cost of copying.
2. Who to Contact
Head of the company and Information Officer: Roxanne Bouwer Email: hello@life-therapy.co.za Phone: +27 71 017 0353 Address: The Colosseum, Foyer 3, 1st Floor, Century Way, Century City, Cape Town, 7441, Western Cape All requests under PAIA, and all questions about this manual or about your personal information, go to the Information Officer.
3. The Regulator's Guide to PAIA
The Information Regulator publishes a guide on how to use PAIA and POPIA (section 10 of PAIA), in each official language. It explains the rights these Acts give you and how to use them. It is available from the Regulator's website, inforegulator.org.za, or from: The Information Regulator (South Africa) Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191 Enquiries: enquiries@inforegulator.org.za
4. Records Available Without a Request
These are published on our website and may be read without a PAIA request: - Our Privacy Policy, Terms and Conditions, and My Commitment to You, each with its version and date. - This manual. - Information about our sessions, courses, packages and products, and their prices. Your own bookings, invoices, course progress and documents are available to you in your client portal, and you may ask for a copy of everything we hold about you without a PAIA request (section 8).
5. Records Kept Under Other Laws
We keep records as these laws require, where they apply to us: - Companies Act 71 of 2008 - Income Tax Act 58 of 1962 - Value-Added Tax Act 89 of 1991 - Tax Administration Act 28 of 2011 - Consumer Protection Act 68 of 2008 - Electronic Communications and Transactions Act 25 of 2002 - Protection of Personal Information Act 4 of 2013 - Promotion of Access to Information Act 2 of 2000
6. The Records We Hold
- Company records: registration documents, the share register, directors' records, and agreements with the providers who process information for us. - Financial records: invoices, payment requests, payment records, session credits, accounting and tax records. - Client records: identity and contact details; bookings and their history; assessment answers; session notes; document acceptances and consents given; messages and emails exchanged; course enrolments and progress. - Records about other people a client gives us: couples partners, people who pay for a client's sessions, gift recipients, children added by a parent or guardian, and emergency contacts. - Marketing records: newsletter and marketing subscriptions, and the consents and opt-outs behind them. - Website and system records: sign-in activity, the audit trail of changes to records, and logs of emails, WhatsApp messages and calendar updates.
7. How We Process Personal Information
Why: to provide coaching and counselling and the courses and products we offer; to manage bookings, accounts, invoices and payments; to meet our legal obligations; to keep our systems and your account secure; and, with consent, to send news and offers. Whose information: clients and their children; the other people a client gives us details of (section 6); people who buy from us or subscribe to our news; and the providers we work with. Who receives it: only the providers who process it on our behalf, each for one purpose: our database and hosting, email and calendar providers, our payment provider, WhatsApp, our video storage, our Instagram messaging service, and website analytics where a visitor accepts it. Our Privacy Policy names each one and what it holds. We do not sell personal information. Information sent outside South Africa: some of these providers keep information on servers in the European Union, the United States and elsewhere. We use only providers bound to protect it to a standard substantially similar to POPIA (section 72 of POPIA), or where the transfer is needed for our agreement with you. How it is protected: information travels encrypted; phone numbers, addresses, emergency contacts, assessment answers and session notes are also encrypted in our database; admin accounts use two-step sign-in; and clinical records can be opened only by the practitioner's own account. How long each kind of record is kept is in our Privacy Policy: in short, seven years, or for a child until their 21st birthday if that is later.
8. How to Request Access
Send your request to the Information Officer by email (section 2), using Form 2, the request form prescribed by the PAIA Regulations of 2021. Form 2 is available from the Information Regulator's website. Say which record you want, in what form, and which right the record is needed for. If you want the personal information we hold about you, you may simply email us; you do not need Form 2, and no request fee applies. Fees: a request fee of R140 is payable before a request is processed, except by someone asking for their own personal information. If access is granted, an access fee for searching for, preparing and copying the records may be payable, as set out in Annexure B of the PAIA Regulations. If the search will take long, we may ask for a deposit first. We send our payment details with our acknowledgement of your request. Timing: we decide within 30 days of receiving a complete request and tell you in writing. We may extend this once, by up to 30 days, where PAIA allows, and we tell you why. If we do not answer in time, the request is regarded as refused.
9. Records About Your Health
Session notes and assessment answers are records about a person's mental health. Where we believe giving access to such a record might cause serious harm to the person it is about, PAIA (section 61) lets us first consult a health practitioner the requester nominates, and to give access only through that practitioner where that is safer. We never give anyone else access to a client's health records without the client's written consent, unless the law requires it.
10. When a Request May Be Refused
PAIA requires or allows a private body to refuse access in certain cases, including where giving access would: - unreasonably disclose personal information about another person (section 63); - disclose another party's confidential or commercial information (sections 64 and 65); - endanger someone's life or safety (section 66); - disclose legally privileged records (section 67); - disclose our own commercial information or harm our position in negotiations (section 68). Even where one of these applies, access must be given if disclosure would reveal a serious breach of the law or a serious risk to public safety, and the public interest clearly outweighs the harm (section 70). If we refuse, we tell you why.
11. If You Disagree With Our Decision
You may complain to the Information Regulator within 180 days of our decision (section 77A of PAIA), or apply to court (section 78). You may also complain to the Regulator about how we process your personal information under POPIA.
12. Changes to This Manual
We update this manual when the records we hold or how we process personal information change. Each version is published here with its date, and earlier versions are kept.