PAIA Manual

1. Introduction

1.1This manual is published by Clerify (Pty) Ltd, registration number 2026/594082/07 (“Clerify”), in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 (“PAIA”), as amended by the Protection of Personal Information Act 4 of 2013 (“POPIA”). Clerify is a private body as defined in PAIA.

1.2PAIA gives effect to the constitutional right of access to information held by private bodies that is required for the exercise or protection of a right. This manual explains what records Clerify holds, how to ask for access to them, and how personal information is processed.

1.3Clerify provides a secure client intake and identity verification platform to law firms. It is a technology provider and does not provide legal advice.

2. Contact details (section 51(1)(a))

2.1Requests for access to records must be sent by email to the Information Officer at the address above.

3. The Information Regulator’s guide (section 51(1)(b))

3.1The Information Regulator has published a guide in terms of section 10 of PAIA that explains how to use PAIA and POPIA. It describes the objects of the two Acts, the contact details of information officers, how to request access to a record of a private body, the help that the Regulator can give, and the remedies that are available.

3.2The guide is available from the Information Regulator (South Africa):

4. Records that are available without a request (section 51(1)(c))

4.1The following records are available without a formal PAIA request, either on the Clerify website or on request by email:

(a)the content of the website at clerify.co.za;

(b)the Terms of Service, the Privacy Policy, the Cookie Policy and the summary of the Data Processing Agreement; and

(c)this manual.

5. Records available under other legislation (section 51(1)(d))

5.1Records are kept as required by the following legislation, among others, and are available as those Acts provide:

(a)the Companies Act 71 of 2008;

(b)the Income Tax Act 58 of 1962, the Value-Added Tax Act 89 of 1991 and the Tax Administration Act 28 of 2011;

(c)the Basic Conditions of Employment Act 75 of 1997, the Labour Relations Act 66 of 1995, the Employment Equity Act 55 of 1998 and the Unemployment Insurance Act 63 of 2001;

(d)the Electronic Communications and Transactions Act 25 of 2002;

(e)the Protection of Personal Information Act 4 of 2013; and

(f)the Financial Intelligence Centre Act 38 of 2001, to the extent that it applies to Clerify.

6. Categories of records held by Clerify (section 51(1)(e))

6.1Clerify holds the following categories of records. A record is listed to help requesters, and the listing does not mean that it will be disclosed.

6.2Client Data. The records that law firms and their clients submit through the platform, such as identity documents, proof of address and verification outcomes, are held by Clerify only as an Operator on behalf of the law firm, which is the Responsible Party. A request for access to that information should be made to the law firm concerned. Clerify will refer a request that it receives for that kind of record to the law firm.

7. Processing of personal information

7.1Full details of how Clerify processes personal information are in the Privacy Policy.

8. How to request access to a record (section 50)

8.1A requester must use the prescribed form (Form 2, “Request for Access to Record”, under the PAIA regulations), which is available from the Information Regulator’s website, and send it by email to the Information Officer.

8.2The request must give enough detail to identify the record, identify the requester, state which form of access is required, state the right that the requester wants to exercise or protect and why the record is needed for that purpose, and give an address or email address for the reply. If a person is making the request for someone else, they must prove their authority to do so.

8.3A requester who is a personal requester (someone requesting information about themselves) pays only the fee for reproduction, search and preparation. Any other requester must also pay the prescribed request fee before the request is processed. The fees are set by the PAIA regulations and are published by the Information Regulator. Clerify may ask for a deposit where the access fee is likely to be high.

8.4Clerify will decide on the request and notify the requester within 30 days of receiving it. The period may be extended once, by up to 30 days, in the circumstances in section 57 of PAIA, in which case Clerify will tell the requester.

8.5If the request is granted, Clerify will tell the requester what fee is payable and in what form access will be given.

9. Grounds for refusing access

9.1Chapter 4 of PAIA lists the grounds on which Clerify must or may refuse a request. They include the protection of the privacy of a third party who is a natural person (section 63), the protection of the commercial information of a third party (section 64), the protection of confidential information of a third party (section 65), the protection of the safety of individuals and of property (section 66), the protection of records that are privileged from production in legal proceedings (section 67), the protection of Clerify’s own commercial information (section 68), and records that relate to research (section 69).

9.2If Clerify refuses a request, it will give written reasons and will tell the requester about the available remedies.

10. Remedies

10.1A private body has no internal appeal procedure. A requester who is unhappy with a decision, or with a failure to decide, can complain to the Information Regulator, at the contact details in section 3, or can apply to a court with the right jurisdiction, within the periods set out in PAIA.

11. Availability and updating of this manual

11.1This manual is available on the Clerify website at clerify.co.za/paia and by email from the Information Officer. A copy can also be inspected during office hours by arrangement with the Information Officer.

11.2Clerify will update this manual from time to time. This version was last updated on 21 October 2026.