PAIA Manual
Prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 (as amended).
Date of compilation: 1 September 2026
1. List of acronyms and abbreviations
- "DIO" — Deputy Information Officer
- "IO" — Information Officer
- "Minister" — Minister of Justice and Constitutional Development
- "PAIA" — Promotion of Access to Information Act No. 2 of 2000 (as amended)
- "POPIA" — Protection of Personal Information Act No. 4 of 2013
- "Regulator" — Information Regulator (South Africa)
- "Republic" — Republic of South Africa
- "Studio Broder" — Studio Broder CC, registration number CK97/21154/23, trading as Studio Broder Fine Jewellery Design
2. Purpose of this PAIA Manual
This Manual is intended to help members of the public to:
- check the categories of records held by Studio Broder that are available without having to submit a formal PAIA request;
- understand how to request access to a record, through a description of the subjects on which Studio Broder holds records and the categories of records held on each subject;
- know which records are available in accordance with other legislation;
- obtain the contact details of the Information Officer;
- know how to obtain the Regulator’s Guide on how to use PAIA;
- know whether Studio Broder processes personal information, and for what purpose;
- know the categories of data subjects and the information held about them;
- know the recipients to whom personal information may be supplied;
- know whether personal information is transferred outside the Republic; and
- know what security measures are in place to protect that information.
3. Key contact details for access to information
3.1 Information Officer
Name: Broder Scharein
Capacity: Member, Studio Broder CC
Telephone: +27 43 726 0225
Email: broderscharein@icloud.com
3.2 Deputy Information Officer
No Deputy Information Officer has been designated. Studio Broder is a small private body and the Information Officer attends to all requests personally.
3.3 General contact for access to information
Email: broderscharein@icloud.com · Telephone: +27 43 726 0225
3.4 Head office
Physical and postal address: Studio Broder, Shop 5, Beacon Bay Crossing, Bonza Bay Road, Beacon Bay, East London, Eastern Cape, 5241
Telephone: +27 43 726 0225 · Email: broderscharein@icloud.com · Website: www.studiobroder.co.za
4. Guide on how to use PAIA
The Regulator has, in terms of section 10(1) of PAIA, updated and made available a Guide on how to use PAIA, in an easily comprehensible form, for any person who wishes to exercise a right contemplated in PAIA or POPIA. The Guide is available in each of the official languages and in braille.
The Guide contains a description of the objects of PAIA and POPIA; the contact details of information officers and deputy information officers; the manner and form of a request for access to a record of a public body (section 11) and of a private body (section 50); the assistance available from information officers and from the Regulator; all remedies available in law, including internal appeals, complaints to the Regulator and applications to court; the provisions requiring public and private bodies to compile manuals; the provisions for voluntary disclosure of categories of records; the notices regarding fees payable; and the regulations made under section 92.
The Guide may be inspected or copied at the offices of public and private bodies, including the office of the Regulator, during normal working hours. It may also be obtained on request from the Information Officer, or from the Regulator’s website at inforegulator.org.za.
A copy of this Manual is available in English.
5. Records available without a formal request
The following records may be accessed without a PAIA request:
| Category of records | Types of record | On website | On request |
|---|---|---|---|
| Legal and policy documents | Terms of Service; Privacy Policy; Returns, Refunds & Warranty; Shipping & Delivery; Contact Information; this PAIA Manual | X | X |
| Product information | Product descriptions, specifications, materials and stone disclosures, pricing, images | X | X |
| Business information | Trading name, registration number, VAT number, physical address, contact details, trading hours | X | X |
| Marketing material | Newsletters, promotional material, social media content | X | X |
6. Records available in terms of other legislation
| Category of records | Applicable legislation |
|---|---|
| Founding statement, member records, statutory registers and annual returns | Close Corporations Act 69 of 1984; Companies Act 71 of 2008 |
| Accounting records and financial statements | Close Corporations Act 69 of 1984; Companies Act 71 of 2008 |
| Income tax records and returns | Income Tax Act 58 of 1962; Tax Administration Act 28 of 2011 |
| VAT records, tax invoices and returns | Value-Added Tax Act 89 of 1991 |
| Employment contracts, payroll, leave and disciplinary records | Basic Conditions of Employment Act 75 of 1997; Labour Relations Act 66 of 1995 |
| UIF and skills development records | Unemployment Insurance Act 63 of 2001; Unemployment Insurance Contributions Act 4 of 2002; Skills Development Levies Act 9 of 1999 |
| Injury on duty records | Compensation for Occupational Injuries and Diseases Act 130 of 1993 |
| Customer transaction, order, delivery and returns records | Consumer Protection Act 68 of 2008; Electronic Communications and Transactions Act 25 of 2002 |
| Personal information records, consents and processing records | Protection of Personal Information Act 4 of 2013 |
| This PAIA Manual | Promotion of Access to Information Act 2 of 2000 |
7. Subjects on which records are held, and categories of records
| Subject | Categories of records |
|---|---|
| Company and statutory | Founding statement, member records, statutory registers, licences and permits, annual returns |
| Financial | Accounting records, financial statements, tax and VAT records, bank records, invoices, receipts, payment gateway records |
| Customer | Orders, invoices, delivery records, correspondence, valuations, repair and warranty records, specifications for pieces made or altered to order |
| Product and design | Designs, sketches, product photographs, material and stone specifications, supplier certificates |
| Stock and insurance | Stock registers, valuation registers, insurance policies and claims |
| Marketing | Mailing list subscriptions and consents, campaign records, website analytics |
| Supplier and contractor | Agreements, purchase records, correspondence, banking details |
| Employment | Contracts, payroll, leave and disciplinary records, statutory returns |
8. Processing of personal information
8.1 Purpose of processing
Studio Broder processes personal information in order to sell and deliver jewellery; to provide repairs, resizing, cleaning, re-plating and valuation services; to make or alter pieces to a customer’s specification; to handle returns, refunds and warranty claims; to comply with its tax, accounting, employment and other statutory obligations; to prevent and detect fraud; to maintain the security of its website and premises; and, where the data subject has consented, to send marketing communications.
8.2 Categories of data subjects and information held
| Category of data subject | Personal information that may be processed |
|---|---|
| Customers | Name, email address, telephone number, delivery and billing address, order and payment history, ring size and design preferences, valuation and repair records, correspondence |
| Website visitors | IP address, device and browser information, website usage data collected through cookies |
| Newsletter subscribers | Name, email address, marketing consent and opt-out status |
| Suppliers and service providers | Contact names, registration and VAT numbers, addresses, banking details, contractual records |
8.3 Recipients of personal information
| Personal information | Recipients or categories of recipients |
|---|---|
| Order, customer and website data | Shopify — e-commerce platform and website hosting |
| Payment information | Payfast — payment gateway (card data is processed by Payfast; Studio Broder does not receive or store full card numbers) |
| Name, delivery address and telephone number | The Courier Guy — delivery |
| Name and email address | Email and marketing service provider |
| Financial and transactional records | Accountants and professional advisors; South African Revenue Service |
| Insurance claim information | Insurers and loss adjusters |
| Records required by law | Courts, regulators, law enforcement and other authorities where legally obliged to disclose |
8.4 Planned transborder flows of personal information
Yes. Shopify, and certain email, marketing and analytics service providers, store and process personal information on servers located outside the Republic.
These transfers are permitted under section 72 of POPIA on the basis that the recipients are subject to binding agreements which provide an adequate level of protection substantially similar to the conditions for lawful processing under POPIA, and because the transfer is necessary for the performance of the contract between Studio Broder and the data subject.
8.5 Information security measures
Studio Broder takes reasonable technical and organisational measures to secure the integrity and confidentiality of personal information, as required by section 19 of POPIA. These include:
- encrypted (HTTPS/TLS) connections across the website;
- payment processing through a PCI-DSS compliant provider, so that raw card data is never held by Studio Broder;
- access controls, unique user accounts and strong authentication on business systems;
- restricting access to personal information to those who require it to perform their duties;
- confidentiality obligations imposed on staff and on operators by written agreement;
- secured physical premises and controlled access to paper records; and
- regular backups of business records.
Where there are reasonable grounds to believe that personal information has been accessed or acquired by an unauthorised person, Studio Broder will notify the Regulator and the affected data subjects as required by section 22 of POPIA.
9. How to request access to a record
A request must be made on the prescribed Form 2 (Request for Access to Record of Private Body), available from the Information Officer or from inforegulator.org.za, and submitted to the Information Officer at the address in paragraph 3.
In terms of section 50(1) of PAIA, a requester must be given access to a record of a private body only if the record is required for the exercise or protection of a right, the procedural requirements have been met, and no ground for refusal applies. The request must therefore state which right is to be exercised or protected, and explain why the record is required for that purpose.
A decision will be given within 30 days, which may be extended by up to a further 30 days in the circumstances set out in section 57 of PAIA, in which case the requester will be notified in writing. If access is refused, reasons will be given together with an explanation of the available remedies.
10. Fees
A request fee and an access fee are payable as prescribed by regulation and revised from time to time. The requester will be notified in writing of the access fee before the request is processed, and a deposit may be required where preparation is expected to exceed six hours.
A data subject requesting access to their own personal information does not pay a request fee, although a reproduction fee may apply. A fee is also payable per A4 photocopy of this Manual, as contemplated in Annexure B of the Regulations.
11. Grounds for refusal
Access may be refused on the grounds set out in Chapter 4 of Part 3 of PAIA, including the mandatory protection of the privacy of a third party who is a natural person; the commercial information of a third party or of Studio Broder, including trade secrets, designs and information that could harm its commercial or financial interests; information supplied in confidence by a third party; records privileged from production in legal proceedings; and requests that are manifestly frivolous or vexatious. Where a ground for refusal applies to only part of a record, access will be given to the remainder.
12. Remedies
There is no internal appeal against a decision of a private body. A requester who is dissatisfied may lodge a complaint with the Regulator, or apply to a court of competent jurisdiction within 180 days.
Information Regulator (South Africa), Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191
PAIA complaints: PAIAComplaints@inforegulator.org.za · POPIA complaints: POPIAComplaints@inforegulator.org.za
General enquiries: enquiries@inforegulator.org.za · +27 10 023 5200 · inforegulator.org.za
13. Availability of this Manual
A copy of this Manual is available on the website at www.studiobroder.co.za; at the head office of Studio Broder for public inspection during normal business hours; to any person on request and on payment of the prescribed fee; and to the Information Regulator on request.
14. Updating of this Manual
This Manual will be reviewed and updated whenever the records held or the processing activities of Studio Broder change materially, and in any event at least annually.
Issued by:
Broder Scharein
Member and Information Officer, Studio Broder CC