Jump to section
- 1. Acronyms and definitions
- 2. Purpose of this Manual
- 3. About Paper Kite Learning
- 4. Key access-to-information contacts
- 5. The Information Regulator's PAIA Guide
- 6. Records available without a formal PAIA request
- 7. Records available under other legislation
- 8. Subjects and categories of records held
- 9. How to request access to a record
- 10. Fees, decisions and possible refusal
- 11. Remedies and complaints
- 12. Processing of personal information
- 13. Availability, updating and approval
Issued version
Issued by Johan Mulder, Director and Head of the Private Body / Information Officer. No Deputy Information Officer has been designated because the company is currently operated by one person.
K2026684028 (SOUTH AFRICA) (PTY) LTD
trading as Paper Kite Learning
Document status and control
| Item | Detail |
|---|---|
| Legal entity | K2026684028 (SOUTH AFRICA) (PTY) LTD |
| Trading name | Paper Kite Learning |
| Registration number | 2026/684028/07 |
| Document | Section 51 PAIA Manual for a private body |
| Version | 1.0 - final for publication |
| Date compiled | 3 September 2026 |
| Publication status | Final - ready for publication and controlled issue |
| Next review | By 3 September 2027, and after any material change |
1. Acronyms and definitions
| Term | Meaning |
|---|---|
| Head | The head of the private body as contemplated in PAIA; for this company, the person who serves as the chief executive officer or equivalent head |
| IO | Information Officer |
| Manual | This PAIA Manual |
| PAIA | Promotion of Access to Information Act 2 of 2000, as amended |
| Paper Kite Learning / PKL | K2026684028 (SOUTH AFRICA) (PTY) LTD trading as Paper Kite Learning |
| Personal information | Personal information as defined in POPIA |
| POPIA | Protection of Personal Information Act 4 of 2013 |
| Private body | A private body as defined in PAIA |
| Record | Recorded information, regardless of form or medium, in the possession or under the control of Paper Kite Learning, whether or not it was created by Paper Kite Learning |
| Regulator | Information Regulator (South Africa) |
| Requester | A person requesting access to a record under PAIA, including a person acting on behalf of another person |
2. Purpose of this Manual
This Manual is prepared under section 51 of PAIA. It is intended to help members of the public understand what records Paper Kite Learning holds, which records may be accessed without a formal request, how to submit a formal request, and how personal information is processed and protected.
In particular, this Manual allows a person to:
- identify categories of records that may be available without a formal PAIA request;
- understand the subjects on which Paper Kite Learning holds records and the categories held for each subject;
- obtain the contact details used for access-to-information requests;
- understand how to use the Information Regulator's PAIA Guide and official forms;
- identify records created or retained under other applicable South African legislation;
- understand the purposes for which personal information is processed, the relevant data subjects, recipients, possible cross-border processing and general security measures; and
- understand the available remedies if a request is refused or not answered.
3. About Paper Kite Learning
Paper Kite Learning is a South African private company that creates and supplies original digital educational resources. Its current focus is downloadable PDF resource packs for Grade 12 Mathematics and Physical Sciences in English and Afrikaans, with additional grades and subjects planned.
The current business model is digital only. Payhip is the intended storefront and digital-delivery platform. A payment processor will be used only once approved and activated. Planned services such as tutoring, memberships, subscriptions and institutional licensing are not treated as current operations in this Manual and must be assessed before launch.
| Company information | Detail |
|---|---|
| Registered name | K2026684028 (SOUTH AFRICA) (PTY) LTD |
| Trading name | Paper Kite Learning |
| Registration number | 2026/684028/07 |
| Nature of body | Private company incorporated in South Africa |
| Website | https://paperkitelearning.co.za |
4. Key access-to-information contacts
Sole-operator structure
Johan Mulder is the company's sole active director and the person responsible for PAIA and POPIA matters. No Deputy Information Officer is designated at the date of issue.
| Role / contact | Details |
|---|---|
| Head of Private Body / Information Officer | Name: Johan Mulder Official title: Director Telephone: 079 322 2603 Email: info@paperkitelearning.co.za |
| Deputy Information Officer | None designated as at the date of issue |
| General PAIA contact | info@paperkitelearning.co.za Subject line: PAIA request |
| Postal address | 6 Genl Alberts Street, Secunda, Mpumalanga, 2302, South Africa |
| Physical / head-office address | 6 Genl Alberts Street, Secunda, Mpumalanga, 2302, South Africa |
| Telephone | 079 322 2603 |
| Website | https://paperkitelearning.co.za |
| Fax | Not applicable |
5. The Information Regulator's PAIA Guide
The Information Regulator has published a Guide under section 10 of PAIA to help people exercise rights under PAIA and POPIA. The Guide explains the objects of the legislation, request procedures, available assistance and remedies, applicable fees, official forms, and how to obtain access to records.
The Guide, private-body Manual template and current forms are available from the Regulator's PAIA page: inforegulator.org.za/paia/.
The Guide is available from the Regulator in South Africa's official languages and in accessible formats offered by the Regulator. Paper Kite Learning will make the English and Afrikaans electronic versions available for inspection upon reasonable request.
| Information Regulator | Current channel |
|---|---|
| Website | https://inforegulator.org.za/ |
| PAIA information and forms | https://inforegulator.org.za/paia/ |
| eServices portal | https://eservices.inforegulator.org.za/ |
| General enquiries | enquiries@inforegulator.org.za |
| Telephone | 010 023 5200 |
| Toll-free | 0800 017 160 |
6. Records available without a formal PAIA request
The following records are generally available without completing Form 2, subject to website availability, identity or contractual controls where applicable, and any lawful restriction. Their inclusion does not mean that every underlying or related record is automatically available.
| Category | Records | How to access |
|---|---|---|
| Legal and privacy information | Current PAIA Manual, Privacy Notice and Terms and Conditions | Website or request by email |
| Company information | Trading name, registration number, public contact details and general business description | Website or request by email |
| Product information | Public product descriptions, subjects, grades, languages, prices and purchasing information | Website |
| Website information | Publicly displayed pages, notices, support details and frequently asked information | Website |
| Published educational information | Public samples, explanatory content and promotional descriptions intentionally released by PKL | Website or the published channel |
Purchased educational resources are supplied to authorised purchasers under the applicable licence and Terms and Conditions. They are not automatically available to the general public merely because they are records held by Paper Kite Learning.
7. Records available under other legislation
Paper Kite Learning may create, receive or retain records under the legislation below, to the extent that each law applies to its operations. Inclusion does not mean that access must be granted where PAIA or another law permits or requires refusal.
| Legislation | Indicative records |
|---|---|
| Companies Act 71 of 2008 | Incorporation, constitutional, director, securities, accounting, resolution and company-administration records |
| Promotion of Access to Information Act 2 of 2000 | This Manual, PAIA requests, correspondence, decisions, fee and disclosure records |
| Protection of Personal Information Act 4 of 2013 | Privacy notices, data-subject requests, security, operator, incident and compliance records |
| Income Tax Act 58 of 1962 and Tax Administration Act 28 of 2011 | Tax returns, assessments, supporting records, accounting records and authority correspondence |
| Consumer Protection Act 68 of 2008 | Customer, transaction, support, complaint, refund and consumer-disclosure records |
| Electronic Communications and Transactions Act 25 of 2002 | Electronic transaction, communication, website and e-commerce records |
| Copyright Act 98 of 1978 | Authorship, source, licence, permission, infringement and intellectual-property records |
| Basic Conditions of Employment Act 75 of 1997 and Labour Relations Act 66 of 1995 | Employment and labour records, if Paper Kite Learning becomes or acts as an employer |
| Unemployment Insurance Act 63 of 2001 and Compensation for Occupational Injuries and Diseases Act 130 of 1993 | Registration, contribution, remuneration, incident and claim records, where applicable |
8. Subjects and categories of records held
| Subject | Categories of records |
|---|---|
| Company and governance | Registration and incorporation; constitutional documents; registers; resolutions; policies; statutory and regulatory correspondence |
| Finance and tax | Accounting records; bank and payment-status records; invoices and receipts; expense and supplier records; budgets; tax records; financial statements |
| Customers and transactions | Customer contact details; orders; products purchased; amounts and payment status; download/access events; refunds; complaints; support correspondence; acceptance and version records |
| Educational products and intellectual property | Product manuscripts; source material; drafts; design assets; answer guides; quality reviews; licences; permissions; authorship and publication records |
| Website and digital operations | Website content; domain and hosting records; technical and security logs; releases; backups; access permissions; incident and maintenance records |
| Providers, contractors and advisers | Due diligence; contracts; instructions; invoices; correspondence; access records; operator and confidentiality arrangements |
| Privacy, PAIA and compliance | Privacy Notice; PAIA Manual; requests; identity verification; decisions; complaints; incident records; risk assessments; training and compliance records |
| Communications | Email and telephone notes; enquiries; service notices; public communications; legal and regulatory correspondence |
| People records, where applicable | Director, employee, contractor, applicant, remuneration, tax, leave, performance, disciplinary, health-and-safety and training records |
| Planned services | Research, design and launch records for tutoring, memberships, subscriptions and institutional licensing; customer or learner records only once lawfully launched |
A listed category describes records that may exist. It does not create an automatic right of access. Each request is assessed under PAIA, including whether the record is required to exercise or protect a right and whether a ground for refusal applies.
9. How to request access to a record
A requester seeking a record of a private body must identify the right to be exercised or protected and explain why the requested record is required for that purpose. A request must relate to an existing record rather than require Paper Kite Learning to answer general questions or create a new record.
- Obtain the current prescribed Form 2: Request for Access to Record from the Information Regulator's PAIA page.
- Describe the requested record with enough detail to enable Paper Kite Learning to identify and locate it, including any known date, product, order reference, subject or correspondence reference.
- Identify the right to be exercised or protected and explain why the record is required for that exercise or protection.
- State the preferred form and manner of access and the preferred language. Access may be supplied in the language and form in which the record exists where the requested alternative is not reasonably available.
- Attach reasonable proof of identity. If acting for another person, attach proof of authority and the information reasonably needed to verify both parties.
- Send the completed Form 2 and supporting documents to info@paperkitelearning.co.za with the subject line “PAIA request”, or deliver/post them to the physical address in section 4.
- Pay any prescribed request fee when notified, unless an exemption applies. Access and reproduction fees may also apply if the request is granted.
Official Form 2: Request for Access to Record
Assistance and accessible requests
A person who cannot complete the form because of illiteracy, disability or another reasonable barrier may contact Paper Kite Learning for assistance. Reasonable alternative communication or access arrangements will be considered, subject to identity, security, feasibility and PAIA.
10. Fees, decisions and possible refusal
10.1 Prescribed fees
The request fee, access fee, reproduction costs, search-and-preparation charges, deposits and delivery costs are governed by PAIA and Annexure B to the current PAIA Regulations. Paper Kite Learning will use the current prescribed amounts rather than relying on amounts copied into this Manual, because the official fee schedule may be amended.
- A personal requester seeking access to a record containing their own personal information may qualify for an exemption from the request fee.
- A requester will be notified of applicable fees using the prescribed outcome/fee notice before access is provided.
- A deposit may be required where the permitted search and preparation threshold is exceeded.
- Inspection may be free, but reproduction or delivery requested after inspection may attract prescribed fees.
The current Regulations and forms are available from the Information Regulator's PAIA page.
10.2 Time for a decision
Paper Kite Learning will notify the requester of its decision as soon as reasonably possible and ordinarily within 30 days after receiving a valid request, subject to any lawful extension. PAIA permits an extension of up to a further 30 days in specified circumstances. If extended, the requester will be told the period, reason and available remedies.
10.3 Grounds for refusal
Access may be refused only on a ground recognised by PAIA or another applicable law. Depending on the record, mandatory or permitted grounds may protect:
- the privacy and personal information of another person;
- commercial, financial, technical or confidential information of a third party;
- information supplied in confidence;
- the safety of individuals or the security of property or systems;
- records protected by legal professional privilege;
- the commercial information, research or intellectual property of Paper Kite Learning or another person;
- law-enforcement, investigation or legal-proceeding interests; and
- administrative capacity where a request is manifestly frivolous, vexatious or would cause a substantial and unreasonable diversion of resources, where PAIA permits refusal.
Where required, Paper Kite Learning will notify an affected third party and allow representations before deciding whether to grant access. Severable portions of a record will be considered where protected information can reasonably be removed.
11. Remedies and complaints
A private body does not have the statutory internal-appeal procedure that applies to certain public bodies. If a request is refused, not answered within the applicable period, or otherwise disputed, the requester or affected third party may use the remedies available under PAIA.
- Ask Paper Kite Learning to clarify or reconsider the decision where appropriate.
- Lodge a complaint with the Information Regulator using the current prescribed Form 5, generally within 180 days of the relevant decision or failure to respond.
- Approach a court with jurisdiction for appropriate relief, subject to PAIA and applicable procedural rules.
Official Form 5 and complaint information: inforegulator.org.za/paia/. Complaints may also be initiated through the Regulator's eServices portal at eservices.inforegulator.org.za.
12. Processing of personal information
This section summarises Paper Kite Learning's processing for PAIA Manual purposes. The public Privacy Notice provides the fuller, customer-facing explanation and should be read together with this Manual.
12.1 Purposes of processing
- operate, maintain and secure the website and digital services;
- respond to enquiries and provide customer support;
- process, record and fulfil digital-resource purchases and downloads;
- administer payments, refunds, disputes and fraud-prevention controls without ordinarily receiving full card credentials;
- maintain accounting, tax, corporate, contractual and compliance records;
- manage providers, contractors, advisers and access permissions;
- protect and enforce intellectual-property, contractual and legal rights;
- handle privacy and PAIA requests, complaints and security incidents; and
- comply with legal, regulatory and lawful authority requirements.
12.2 Categories of data subjects and information
| Data subject | Personal information that may be processed |
|---|---|
| Customers and purchasers | Name, email address, telephone if supplied, order reference, product, amount, payment status, download/access records, refund, complaint and support records |
| Website visitors | IP address, device/browser information, request time, requested page and necessary technical/security logs generated by hosting or security infrastructure |
| Enquirers and privacy/PAIA requesters | Contact information, message/request content, identity-verification information, authority to act, requested records and correspondence |
| Learners | Limited information voluntarily included in support correspondence; information written into a downloaded resource normally remains on the user's device unless deliberately sent to PKL |
| Providers, contractors and advisers | Names, business contact information, registration/tax details where relevant, contracts, bank/payment information, invoices, instructions and access records |
| Directors and people, where applicable | Identity and contact details, role, statutory records, remuneration/tax, qualifications, performance, leave, disciplinary, health-and-safety and training information where lawfully required |
| Regulators, complainants and third parties | Names, official/business contact details, correspondence, case references, evidence and records relevant to legal or regulatory matters |
12.3 Recipients or categories of recipients
| Information / purpose | Recipients or categories of recipients |
|---|---|
| Orders and digital delivery | Payhip and the active checkout/payment provider |
| Website, communications and security | Hosting, infrastructure, security, domain and email service providers |
| Accounting, tax, legal and insurance | Accountants, tax advisers, legal advisers, insurers and auditors where applicable |
| Legal and regulatory compliance | Information Regulator, revenue authorities, CIPC, courts, law-enforcement bodies and other authorised public bodies where required or permitted |
| Business reorganisation | A lawful successor, purchaser or professional adviser subject to appropriate confidentiality and legal safeguards |
Paper Kite Learning does not sell or rent personal information.
12.4 Planned cross-border processing
Some service providers may process or store personal information outside South Africa. Payhip states that it uses infrastructure in the European Union and may make international transfers in connection with its services. The location of hosting, email and the active payment processor must be confirmed in the operational provider register before active checkout.
Where Paper Kite Learning is responsible for an international transfer, it will rely on a ground permitted by section 72 of POPIA, such as adequate protection under law, binding corporate rules or an agreement, consent where appropriate, or a transfer necessary for a contract or the data subject's benefit.
12.5 General security measures
Paper Kite Learning uses or plans reasonable and appropriate technical and organisational safeguards proportionate to the nature of the information and the risk, including:
- data minimisation and collection of only necessary fields;
- named accounts, role-appropriate access and prompt removal of access;
- strong credentials and multi-factor authentication where available;
- supported software, updates and endpoint protection;
- secure hosting, transmission, storage and backups appropriate to the provider and data;
- provider due diligence, confidentiality and written operator controls;
- logging, monitoring and incident escalation appropriate to the service;
- retention rules, lawful holds and secure deletion or de-identification; and
- privacy-request and security-compromise procedures.
Full payment-card numbers, card verification values and online-banking credentials are ordinarily handled by the active payment platform or processor and are not intended to be received or stored by Paper Kite Learning.
13. Availability, updating and approval
13.1 Availability of this Manual
A copy of this approved and issued Manual is available:
- on the Paper Kite Learning website at a stable public legal-information URL;
- from Paper Kite Learning by request to info@paperkitelearning.co.za;
- for inspection at the physical address in section 4 during reasonable business hours and by prior arrangement;
- to any person upon request, subject to any reasonable prescribed copying or delivery fee; and
- to the Information Regulator upon request.
The electronic copy published by Paper Kite Learning will be available without charge. A prescribed fee may apply to physical copies, reproduction or delivery.
13.2 Updating the Manual
The Head of the Private Body will review and update this Manual regularly, and particularly when the company's contact details, records, processing activities, providers, services, security arrangements or applicable legal requirements materially change. Superseded versions will be retained as controlled records.
13.3 Approval and issue
Issued and controlled
This is version 1.0 of the Manual. The Head of the Private Body is responsible for keeping the Manual and the company's Information Officer registration current.
| Approval field | Entry |
|---|---|
| Issued by | Johan Mulder |
| Capacity | Director - Head of Private Body / Information Officer |
| Date issued | 3 September 2026 |
| Final version | 1.0 - final for publication |
Official reference sources
- Promotion of Access to Information Act 2 of 2000
- PAIA Regulations, 2021 - Government Gazette 45057
- Information Regulator PAIA page, Guide, templates and forms
- Official private-body PAIA Manual template
- Protection of Personal Information Act 4 of 2013
Document relationship
This Manual addresses access to records under PAIA and includes the POPIA information required for a private-body manual. The separate Paper Kite Learning Privacy Notice remains the primary public explanation of how personal information is processed.