PAIA Manual

Version 1.0 · Effective 1 September 2026
Published by Pinkster Protestante Kerk Kraaifontein t/a Christ Life Church

Manual published in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 by Pinkster Protestante Kerk Kraaifontein t/a Christ Life Church .

1. Introduction

This manual (the "Manual") provides an outline of the types of records held by Pinkster Protestante Kerk Kraaifontein t/a Christ Life Church ("Christ Life Church", "the Church", "we", "us" or "our") and explains how a person may submit a request for access to those records in terms of the Promotion of Access to Information Act 2 of 2000 ("PAIA" or "the Act").

This Manual has been prepared in accordance with section 51 of the Act, giving effect to everyone's constitutional right of access to information held by private bodies where such access is needed for the exercise or protection of any right. It aims to make it easier for a requester to request access to the relevant records.

2. Definitions and interpretation

Unless the context clearly indicates otherwise, the following terms have the meanings assigned to them below. Terms defined in PAIA and POPIA and not defined here carry the meaning given to them in those Acts. Words in the singular include the plural and vice versa, and any one gender includes the other genders.

• Data Subject — the person to whom personal information relates.
• Data Subject Request — a request by a data subject as allowed under POPIA.
• Information Officer — the person acting on behalf of the Church and discharging the duties and responsibilities assigned to the head of the Church by the Act, duly authorised in writing to act as such.
• Information Regulator — the Information Regulator established in terms of section 39 of POPIA.
• Manual — this manual, published in compliance with section 51 of the Act.
• PAIA — the Promotion of Access to Information Act 2 of 2000, as amended.
• POPIA — the Protection of Personal Information Act 4 of 2013, as amended.
• Privacy Policy — the policy explaining how the Church processes personal information, published on our website at /privacy-policy or available from the Information Officer.
• Record — any recorded information, regardless of form or medium, which is in the possession or under the control of the Church, whether or not it was created by the Church.
• Request — a request for access to a record held by the Church.
• Requester — any person, including a public body or an official thereof, making a request for access to a record held by the Church, and includes any person acting on behalf of that person.
• Responsible Party — a public or private body or any other person which, alone or together with others, determines the purpose of and means for processing personal information.
• SAHRC — the South African Human Rights Commission.

3. About the Church

Christ Life Church is an assembly which forms part of the Pinkster Protestante Kerk. The Church is an independent congregation based in Kraaifontein, Western Cape, where it holds its religious services and runs its programmes. The Church has an online presence at christ-life-church.co.za , where it introduces and promotes its services, activities and programmes to the congregation and the community.

3.1 Our services and activities

• Sunday worship services
• Sermons — audio recordings and teaching notes
• Growth Track
• Bible School
• God Seekers
• Children's Ministry and Sunday School
• Youth Ministry (Youth Alive)
• Worship Ministry
• Media Ministry
• Usher Ministry
• Zambia Ministry and outreaches
• Church events, and the church renovations programme

4. Particulars in terms of section 51

4.1 Contact details of the Church — section 51(1)(a)

4.2 Contact details of the designated Information Officer — section 51(1)(a)

5. Guide to PAIA — section 51(1)(b) read with section 10

1. In terms of PAIA, a requester may be granted access to records held by a private body. This access is subject to the records being required for the exercise or protection of any right. Should a public body lodge a request, it must be acting in the public interest in order to receive access.
2. The Information Regulator has, in terms of section 10(1) of PAIA, compiled and made available a guide on how to use PAIA (the "Guide") in an easily comprehensible form and manner, as may reasonably be required by a person who wishes to exercise any right contemplated in PAIA and POPIA.
3. The Guide contains a description of the objects of PAIA and POPIA; the manner and form of a request for access to a record of a private body; the assistance available from the Information Officer and from the Regulator; all remedies in law available regarding an act or failure to act in respect of a right or duty conferred by PAIA and POPIA, including how to lodge an internal appeal, a complaint to the Regulator, and an application to a court; the notices issued under section 54 regarding fees; and the regulations made under section 92.
4. The Guide may be obtained on request from our Information Officer, or from the Information Regulator at the contact details in section 10 below, or downloaded from the Regulator's website.

6. Records available without a request — section 51(1)(c)

The following records are automatically available to the public without having to submit a formal request:

• All records lodged by the Church in terms of government requirements with statutory bodies.
• All records in booklets, brochures, pamphlets, bulletins and magazines published by the Church, or by any of its agents or representatives, for distribution to the public.
• News and other information published by the Church.
• All records published on the Church's website, christ-life-church.co.za , including sermon recordings and teaching notes, ministry information, event details and staff information.

7. Records available in terms of other legislation — section 51(1)(d)

The Church is required to keep particular records in terms of certain statutes. Insofar as it may be applicable, the Church keeps records to the extent required by the following legislation, as amended, and codes of best practice. The list below is not exhaustive.

• Basic Conditions of Employment Act 75 of 1997
• Constitution of the Republic of South Africa, 1996
• Electronic Communications and Transactions Act 25 of 2002
• Employment Equity Act 55 of 1998
• Financial Intelligence Centre Act 38 of 2001
• Income Tax Act 58 of 1962
• Labour Relations Act 66 of 1995
• Non-Profit Organisations Act 71 of 1997
• Occupational Health and Safety Act 85 of 1993
• Promotion of Access to Information Act 2 of 2000
• Protected Disclosures Act 26 of 2000
• Protection of Personal Information Act 4 of 2013
• Skills Development Act 97 of 1998
• Skills Development Levies Act 9 of 1999
• Unemployment Insurance Act 63 of 2001
• Unemployment Insurance Contributions Act 4 of 2002
• Value-Added Tax Act 89 of 1991

Information and records held by the Church in terms of any of the above legislation will be made available in terms of the provisions of the relevant legislation, but without prejudice to the provisions of PAIA.

8. Types of records held by the Church — section 51(1)(e)

8.1 Personnel documents and records

"Personnel" refers to any person who works for or provides services to or on behalf of the Church and receives or is entitled to receive remuneration, and any other person who assists in carrying out or conducting the business of the Church. This includes, without limitation, board or council members, all permanent, temporary and part-time staff, contract workers, and volunteers.

8.2 Congregant and member records

A "congregant" or "member" refers to any natural person or juristic entity that receives services from or is a member of the Church. These records include, but are not limited to:

• Records provided by congregants in relation to specific services required, including personal and special personal information needed to enable the Church to perform its services.
• Records generated by or within the Church relating to its congregants, including transactional and giving records.
• Records pertaining to third-party information provided by congregants.
• Records provided by third parties in the course of doing business with the Church.
• Ministry registers and attendance records, including for the Children's Ministry, Sunday School, Youth Ministry, Growth Track, Bible School and life groups.
• Prayer requests and pastoral care records.

8.3 Statutory records of the Church

• Minutes of meetings of the Church leadership and other decision-making committees.
• Constitution and documents of incorporation.
• PBO certificate.
• Minutes of members' meetings and sub-committee meetings, where required.
• Delegations of authority.
• Other statutory documents of a legal and financial nature.

8.4 Other records of the Church

• Documents relating to the operational and financial affairs of the Church.
• Contracts and agreements.
• Congregant and other databases.
• Financial records, including tithes, offerings, donations and audits.
• Information on existing and past litigation.
• Administrative information and licences.
• Human resources information.
• Insurance policies.
• Communication and publicity records.
• Internal and external correspondence.
• Property, building, maintenance and renovation records, including plans, quotations and contractor agreements.
• Sermon recordings, teaching notes, photographs and media assets.
• Records of church services, events and outreaches.
• Internal policies and procedures.
• Records held by officials of the Church.

8.5 Records containing personal information

Where any of the above records contain personal information and a request is submitted, the provisions of both PAIA and POPIA will apply. "Personal Information", as defined in POPIA, means information relating to an identifiable, living, natural person and, where applicable, an identifiable, existing juristic person.

9. Processing of personal information — section 51(1)(f)

Personal information, including special personal information (POPIA sections 26 to 33) and children's information (POPIA sections 34 and 35), is processed by the Church in accordance with our Privacy Policy, which sets out:

• the categories of personal information we process;
• the purposes for which we process it, and the lawful basis for each;
• how we handle prayer requests and pastoral information, which commonly contain special personal information;
• how we handle children's information;
• the recipients we share personal information with;
• any planned transfers outside the Republic of South Africa; and
• the security safeguards we apply.

The Church may also hold records pertaining to other parties, including contractors, suppliers and service providers. Conversely, such parties may hold records that belong to the Church.

10. The Information Regulator

Section 39 of POPIA establishes the Information Regulator and section 40 identifies its functions. The Regulator monitors compliance with POPIA and PAIA and handles complaints about the protection of personal information and about access to information held by the Church.

11. Data subject participation and the Information Officer's duties

This Manual, together with our Privacy Policy, gives effect to sections 23 and 55 of POPIA.

Section 23(1) of POPIA provides that a data subject, having provided adequate proof of identity, has the right to:

1. request a responsible party to confirm, free of charge, whether or not it holds personal information about the data subject; and
2. request from a responsible party the record, or a description of the personal information about the data subject held by it, including information about the identity of all third parties, or categories of third parties, who have or have had access to the information —
   • within a reasonable time;
   • at a prescribed fee, if any;
   • in a reasonable manner and format; and
   • in a form that is generally understandable.

Section 55(1)(b) of POPIA provides that an Information Officer's responsibilities include dealing with requests made to the body.

12. Steps to consider before submitting a request

12.1 Step 1 — the purpose of the information requested

Section 7(1) of PAIA provides that the Act does not apply to a record if:

1. the record is requested for the purpose of criminal or civil proceedings;
2. the request is made after the commencement of those proceedings; and
3. the production of or access to that record for that purpose is provided for in any other law.

If section 7(1) applies, the requester may not bring a request in terms of PAIA and must instead use the rules and procedures for discovery of information of the relevant legal forum. The Church reserves the right to claim all expenses and other damages incurred as a result of a requester submitting a request in contravention of section 7(1).

12.2 Step 2 — does the information exist in the form of a record?

PAIA only applies to documents that are in existence at the time the request is received. It does not compel anyone to create a record that does not yet exist at the time the request is made.

12.3 Step 3 — is the record in the possession or under the control of the Church?

The requested record must be in the Church's possession or under its control. If it is not, the requester must request the record from the party in whose possession or control it is.

12.4 Electronic communication

The provisions of the Electronic Communications and Transactions Act 25 of 2002 apply to all forms, records, documents and information that are electronically communicated.

13. How to request a record — PAIA section 53

1. A request for access to a record contemplated in section 53(1) of the Act must be made on Form 2 (Request for Access to Record) prescribed by the PAIA Regulations, and submitted to the Information Officer at the contact details in section 4.2 above. The current version of the form is available from the Information Regulator's website at https://inforegulator.org.za/ , or on request from our Information Officer.
2. The Information Officer must assist a requester with any request for access to information. If a request is made orally, because of illiteracy or a disability, the Information Officer will complete Form 2 on behalf of the requester and provide a copy to the requester, as contemplated in section 18(3) of the Act.
3. The request fee payable by every requester referred to in section 54(1) of the Act is set out in section 17 below.
4. Failure to make use of the prescribed form could result in the request being refused or delayed.
5. The requester must provide sufficient detail on the request form to enable the Information Officer to clearly identify:
   • the record or records requested;
   • the requester (with positive proof of identification);
   • the form of access required, together with the requester's postal address, email address and telephone number in the Republic; and
   • if the requester wishes to be informed of the decision in any manner in addition to written notice, the manner and particulars thereof.
6. Access is not automatic. The requester must identify the right he or she is seeking to exercise or protect, and explain why the requested record is required for the exercise or protection of that right.
7. If a request is made on behalf of another person, the requester must submit proof, to the satisfaction of the Information Officer, of his or her authority to make the request. Failure to do so will result in the request being rejected.

14. Our decision — PAIA section 56

1. The requester will be notified within 30 days, in the manner indicated by him or her, of the outcome of the request, or alternatively whether an extension not exceeding a further 30 days is required to deal with the request.
2. If the request for access is granted, a further access fee must be paid for the search, preparation and reproduction of the records, as well as for any time that has exceeded the prescribed hours to search for and prepare the record for disclosure. Access will be withheld until the requester has paid the applicable fee.
3. If the request for access is refused, reasons for the refusal will be provided and the requester will be advised that he or she may lodge an application with a court against the refusal, together with the procedure for lodging that application.
4. If the search for the record and its preparation for disclosure would, in the opinion of the Information Officer, require more than six hours, the Information Officer will inform the requester to pay a deposit of not more than one third of the amount payable, if the request is granted.
5. Records that cannot be found or that are lost. If all reasonable steps have been taken to find a requested record and there are reasonable grounds to believe the record is in the Church's possession but cannot be found, or does not exist, the Information Officer will notify the requester by way of affidavit or affirmation as prescribed by the Act that it is not possible to give access to the requested record. If the record is subsequently found, the requester must be given access to it, unless access is refused on any of the grounds provided for in the Act.

15. Grounds for refusal of a request

The main grounds on which a request may be refused relate to:

• the unreasonable disclosure of personal information about a third party, including a deceased person (subject to section 63(2) of the Act);
• disclosure that could reasonably be expected to endanger the life or physical safety of an individual;
• disclosure that would likely prejudice or impair the security of a building, structure or system, including a computer or communication system, a means of transport, or any other property;
• the mandatory protection of the privacy of a third party who is a natural person, which would involve the unreasonable disclosure of personal information about that person;
• the mandatory protection of commercial information of a third party, if the record contains trade secrets; financial, commercial, scientific or technical information the disclosure of which could likely cause harm to the financial or commercial interests of that third party; or information disclosed in confidence by a third party to the Church, if disclosure could put that third party at a disadvantage in negotiations or commercial competition;
• the mandatory protection of confidential information of third parties protected in terms of any agreement;
• the mandatory protection of the safety of individuals and the protection of property;
• the mandatory protection of records that would be regarded as privileged in legal proceedings;
• the activities of the Church, including financial, commercial, scientific or technical information the disclosure of which could likely cause harm to the financial or commercial interests of the Church; information which, if disclosed, could put the Church at a disadvantage in negotiations; a computer programme owned by the Church and protected by copyright; or research information of the Church or a third party where disclosure would place the research at a serious disadvantage;
• requests for information that are clearly frivolous or vexatious, or which involve an unreasonable diversion of resources.

16. Remedies and limitation of liability

1. The Church does not have an internal appeal procedure.
2. Any decision made by the Information Officer is final.
3. Should the requester not be satisfied, the requester should exercise the external remedies provided for in the Act, namely a complaint to the Information Regulator or an application to a court.
4. The requester may also lodge an internal appeal or an application to court against the tender or payment of the request fee.

Limitation of liability. The Church is relieved from liability and shall have no duty whatsoever in relation to the integrity or accuracy of the information requested; any delay associated with delivery, except to comply with the procedures stipulated in this Manual; or whether the information requested will conform with the requirements of the requester, except that it should correspond with the title and description provided by the requester.

17. Prescribed fees

The fees below are those prescribed by the Regulations Regarding the Promotion of Access to Information, 2021, which came into operation on 1 January 2022. A request fee must be paid before the request will be considered. The requester will then be notified of the access fee payable. Fees are subject to change when the Minister publishes an amendment in the Government Gazette.

18. Availability of this Manual

This Manual is available:

• on the Church's website at christ-life-church.co.za/paia-manual;
• on request from the Information Officer at ian@christ-life-church.co.za; and
• for inspection at 143 8th Avenue, Kraaifontein, Western Cape during office hours (Monday to Friday 09:00 – 17:00 and Saturday 09:00 – 13:00, excluding public holidays).

Signed on behalf of Pinkster Protestante Kerk Kraaifontein t/a Christ Life Church by the Information Officer, Pastor Ian Maree, Lead Pastor.