PAIA Manual
Compiled: 28 July 2026 — Section 51 of the Promotion of Access to Information Act 2 of 2000
1. Introduction
This manual is published by Bambanani in terms of Section 51 of the Promotion of Access to Information Act 2 of 2000 ("PAIA"). It explains what records Bambanani holds, and how to request access to them.
Bambanani is a Partnership registered with the Information Regulator of South Africa (registration number 2026-063242), operating a school-based incident reporting platform used by South African schools to let learners and staff report bullying, violence, and other safety concerns — anonymously or with contact details — for the school's designated staff to review and act on.
Every private body in South Africa is required to compile and make available a manual like this one. There is currently no size or turnover exemption available to private bodies — the exemption that previously allowed small private bodies to skip this requirement lapsed on 1 January 2022.
2. Contact details
Information Officer: Nicholas Zietkiewicz
Email: privacy@bambanani.app
Information Regulator registration number: 2026-063242
Entity type: Partnership (Nicholas Zietkiewicz, Sihle Shongwe, and possibly other owners)
All PAIA requests, and any other queries about records Bambanani holds, should be directed to the Information Officer at the email address above.
You may also contact the Information Regulator of South Africa directly at www.justice.gov.za/inforeg.
3. How to use this manual
Section 10 of PAIA requires a guide to be published to assist any person wishing to exercise a right of access to a record under PAIA — including help with the procedure, the notification requirements to be met, and how to contact the Information Officer of any public or private body. That guide is available from the Information Regulator's website (see Section 2, above). This manual should be read alongside that guide, not instead of it.
4. Records held by Bambanani, by category
| Category | What it contains | Who it relates to |
|---|---|---|
| Incident reports | Category, description, optional date/location, optional follow-up answers, optional reporter contact details, status and staff actions taken | Learners and, occasionally, staff or others described within a report |
| School account & subscription records | School name, province, subscription/account status | The subscribing school |
| Staff user accounts | Name, email, role, school association, account activity | School staff with platform access |
| Access logs | Which staff account viewed which report, and when | School staff with platform access |
| Email/notification logs | Notification emails sent (recipient, subject, status) | Staff recipients of notifications |
| Support/contact records | Correspondence with the Information Officer | Whoever contacted Bambanani |
Bambanani does not hold financial/payment records beyond basic subscription status, does not hold biometric data, and does not hold any record not listed above.
5. Categories of data subjects and personal information processed
- Learners: category of incident, free-text description, and — only if voluntarily provided — contact details. The platform is anonymous by default. A hashed, irreversible version of the submitter's IP address is stored solely to prevent spam/abuse.
- School staff: name, email, role, school, and account activity.
- School (as an organisation): name, province, subscription status.
Special personal information (POPIA Section 26) and children's personal information (POPIA Section 34) may appear within incident report free text, depending on what a reporter chooses to describe. Bambanani's legal basis for processing this is set out in an internal justification memo, available to the Information Regulator on request.
6. How to request access to a record
Who can request: any person (the requester does not need to be the data subject — see Section 7 on refusal grounds).
How: submit a request to the Information Officer (Section 2) using the form prescribed under the PAIA Regulations (currently referred to as Form 2 for requests to a private body), or by writing directly with enough detail to identify the record sought and the form in which access is required. Include your contact details so a response can be sent to you.
Fees: PAIA permits a request fee, and — if granted — an access/reproduction fee per the schedule prescribed under the PAIA Regulations. The current fee schedule is published on the Information Regulator's website; Bambanani will confirm the applicable amount, if any, when acknowledging a request.
Timeline: Bambanani will respond within the period prescribed by PAIA (ordinarily 30 days of receipt of a valid request), and will notify the requester in writing if that period needs to be extended.
If the request concerns an anonymous report: Bambanani has no way to verify a requester is the original reporter of an anonymous report, and in most cases cannot link a stored report back to any identifiable person at all — this is by design, to protect reporter anonymity. Where a record genuinely cannot be linked to the requester, Bambanani will explain this rather than disclose another person's report.
7. Grounds on which a request may be refused
Bambanani will process every request in good faith and grant access unless a ground for refusal under PAIA applies. In the context of this platform, the most likely grounds are:
- Protection of a third party's personal information — e.g. a request for a report that names or describes another learner or staff member.
- Mandatory protection of the record of a data subject who is not the requester, unless that person consents or an exception applies.
- The record cannot be found or does not exist — e.g. an anonymous report with no link to the requester.
Any refusal will state the reason and the requester's right to lodge a complaint with the Information Regulator or apply to court, as required by PAIA.
8. Records automatically available (no PAIA request needed)
- The Privacy / Collection Notice
- This PAIA Manual
- General information about how the platform works (About, For Schools, For Students)
9. Updates to this manual
This manual will be reviewed whenever the categories of records Bambanani holds change materially, and at least annually alongside the annual PAIA report submitted to the Information Regulator.
