PAIA Manual

For purposes of this Manual:

• "Bowker Attorneys" or "the Firm" means Candice Bowker, in her professional capacity carrying on the profession of attorney as a sole proprietor under the style Bowker Attorneys;
• "Head" means Candice Bowker as the head of the private body for PAIA purposes;
• "Information Officer" or "IO" means the person contemplated in POPIA and, in the context of this Firm, Candice Bowker subject to registration with the Information Regulator;
• "PAIA" means the Promotion of Access to Information Act 2 of 2000, as amended;
• "POPIA" means the Protection of Personal Information Act 4 of 2013; and

"Regulator" means the Information Regulator (South Africa).

Bowker Attorneys is a private body for purposes of PAIA. As a sole proprietorship it is not described in this Manual as a separate incorporated juristic person.

This Manual is prepared to assist members of the public to understand how to request access to records held by Bowker Attorneys and to provide the information required by section 51 of PAIA, read with POPIA and the applicable PAIA Regulations.

In particular, this Manual describes:

• records that may be available without a formal PAIA request;
• the subjects on which the Firm holds records and the categories of records held;
• records created or retained in accordance with other legislation;
• how to make a request for access to a record of this private body;
• the contact details of the Head / Information Officer;
• the purposes for which personal information is processed, categories of data subjects and categories of personal information;
• categories of recipients of personal information;
• planned or possible transborder flows of personal information; and

general information-security measures.

Name / style: Bowker Attorneys

Head of private body / sole proprietor: Candice Bowker

Legal Practice Council firm number: 75739

General email: info@bowkerattorneys.co.za

PAIA / privacy email: info@bowkerattorneys.co.za

Website: https://bowkerattorneys.co.za

Information Officer: Candice Bowker

No Deputy Information Officer is listed in this Manual unless and until one is formally designated and, where required, registered. The Manual will be updated if a Deputy Information Officer is appointed.

The Information Regulator has issued a Guide under section 10 of PAIA explaining how PAIA and related rights may be exercised. The Guide is available through the Information Regulator in all official languages and in Braille.

Members of the public may obtain the current Guide and prescribed forms from the Information Regulator. Bowker Attorneys will provide reasonable assistance regarding the process applicable to requests directed to the Firm.

Information Regulator - PAIA resources and forms

Information Regulator - PAIA forms

The following records may be accessed without a formal PAIA application where they have been intentionally made public or are otherwise suitable for informal disclosure. Availability does not extend to client-confidential, privileged or protected records.

The Firm may create, receive or retain records under legislation and professional rules including the following, to the extent applicable. Listing legislation does not mean that every record is automatically accessible: access remains subject to PAIA, POPIA, legal professional privilege, confidentiality and other applicable restrictions.

A requester is entitled to access a record of a private body only if the requirements of section 50 of PAIA are met. In summary, the record must be required for the exercise or protection of a right; the requester must comply with PAIA’s procedural requirements; and access must not be refused under a ground of refusal in PAIA.

A PAIA request is a request for an existing record. It is not a mechanism to require the Firm to answer general questions, create a new document, provide legal advice or waive legal professional privilege.

A requester should complete the prescribed Form 2 (Request for Access to Record) and submit it to the Head / Information Officer using the contact details in section 3 of this Manual. The requester must provide enough information to identify the requester and the record, specify the required form of access, identify the right to be exercised or protected, and explain why the record is required for that purpose.

Bowker Attorneys may request adequate proof of identity or authority to act for another person. The Firm will process a properly made request within the periods prescribed by PAIA, subject to any lawful extension, third-party notification process or other statutory procedure.

Official PAIA Form 2 - Request for Access to Record

A requester may be required to pay the request, reproduction, search, preparation, access, postage or other fees prescribed under PAIA and the applicable Regulations. Bowker Attorneys will use the prescribed process to notify a requester of fees where payable. Because prescribed fees may be amended, the current official fee schedule published by the Information Regulator should be consulted at the time of the request.

Information Regulator - current PAIA forms and fee information

Access is not automatic. Bowker Attorneys will consider each request under PAIA and may or must refuse access where a statutory ground applies. Without limiting PAIA, relevant issues may include:

• mandatory protection of the privacy of third parties;
• commercial information of third parties or of the private body;
• confidential information protected by agreement or law;
• safety of individuals and protection of property;
• records privileged from production in legal proceedings;
• research information protected under PAIA;
• information whose disclosure is otherwise prohibited or restricted by law; and

legal professional privilege, professional confidentiality and duties owed to clients or third parties.

Where a record contains severable information, the Firm will consider whether access can lawfully be granted to a portion while protecting the remainder, as required by PAIA.

If all reasonable steps have been taken to locate a requested record and there are reasonable grounds to believe that it is not in the Firm’s possession, cannot be found or does not exist, the Head / Information Officer will deal with the request in the manner required by PAIA, including any affidavit or affirmation required by law.

A private body does not have the same mandatory internal-appeal process applicable to certain public bodies. A requester who is dissatisfied with a refusal, failure to respond or other PAIA decision may use the remedies provided by PAIA, which may include a complaint to the Information Regulator and/or an application to court, subject to statutory requirements and time limits.

The Information Regulator currently requires PAIA complaints to be made on prescribed Form 5. The Regulator’s published information indicates that a complaint concerning a private body should generally be lodged within 180 days of the relevant refusal or non-response, subject to any condonation process permitted by law.

Information Regulator - complaints

Bowker Attorneys processes personal information for purposes including receiving enquiries, conflict checks, client onboarding and FICA compliance, providing legal services, establishing/exercising/defending legal rights, litigation and dispute resolution, communications, billing and trust accounting, tax and regulatory compliance, professional risk management, supplier management, information security and Website operation.

The Firm may use email, cloud, hosting, backup or software services that process information outside South Africa. Any transfer will be assessed under section 72 of POPIA. Special personal information or children’s information will not be transferred to a third party in a foreign country in a manner requiring prior authorisation under section 57 without that prior authorisation having been obtained.

Website hosting / location: Cloudflare Pages / Cloudflare global edge network, including South African points of presence

Email / cloud services: Google Workspace (Google Ireland/LLC) — data region per the Firm’s Workspace configuration

Bowker Attorneys uses or intends to use reasonable safeguards proportionate to the sensitivity and risk of the information processed, including:

• user-access controls and least-privilege principles;
• strong passwords and multi-factor authentication where available;
• secure devices, endpoint protection, anti-malware and software updates;
• encryption in transit and at rest where appropriate and supported;
• secure backup and recovery arrangements;
• confidentiality duties and controlled disclosure;
• written operator/security terms where required;
• incident-response and security-compromise procedures;
• secure retention, archiving and destruction practices; and

periodic review of foreseeable internal and external security risks.

The current version of this Manual will be made publicly available on the Bowker Attorneys Website and will also be available from the Head / Information Officer upon request. A copy will be supplied to the Information Regulator upon request and otherwise made available as PAIA requires. Any prescribed copying fee may be charged where lawful.

The Head will review this Manual regularly and update it when there is a material change to the Firm’s processing activities, contact details, records, information systems, applicable law or other information required by section 51 of PAIA.

Issued by: Candice Bowker, Head of the private body / Information Officer

Date: 12 August 2026