PAIA manual for LadyBugz Marketing (Pty) Ltd

This manual tells you what records LadyBugz Marketing keeps, which of them you can have without filling in anything, how to ask for the rest, what it costs, and what you can do if we turn you down. Every business in South Africa has to publish one. Ours covers the whole company, including the LadyBugz Academy. Read it with our Terms of Service, the Academy Privacy Note and the Refund and Cancellation Policy.

Compiled: 1 November 2026. Last revised: 1 November 2026. Version 1. Prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000, as amended.

1. The words used in this manual

Laws come with their own vocabulary. Here is the short version of the words you will meet below, so that nothing on this page needs a lawyer to read.

2. Who we are, and how to reach us

3. The Information Officer

We are a small company and we have not appointed a Deputy Information Officer. Send your request to the Information Officer at the address above and it will be dealt with there.

4. The Regulator's guide on how to use PAIA

You do not have to take our word for any of this. The Regulator publishes its own guide to PAIA, written for the public, under section 10 of the Act. It explains what PAIA and POPIA are for, how to make a request to a public body or a private body, what help you can get, and every remedy open to you if a request goes wrong.

The guide is published in South Africa's official languages and in braille. You can:

• download it from the Regulator at inforegulator.org.za/paia, where the English version sits alongside the others;
• ask us for a copy, by email or by phone, and we will send you one or print it for you;
• read it at our offices during normal business hours; or
• read it at the Regulator's offices during normal business hours.

5. Records you can get without making a formal request

Some things you should not have to fill in a form for. These are available already, or on a simple email.

We have not submitted a notice to the Minister under section 52(2) of PAIA listing categories of automatically available records. The table above is how we make that information available instead.

6. Records we keep because another law says we must

A record in this table exists only while the law behind it applies to us. We keep what we are required to keep, and we do not keep records we have no reason to hold. LadyBugz Marketing is not registered for value added tax, so there are no VAT records.

7. What we hold records about

PAIA asks us to describe the subjects we hold records on, and what kinds of records sit under each one, in enough detail that you can work out what to ask for.

8. How to ask us for a record

Under section 50 of PAIA, we must give you a record we hold if three things are true. The record is needed to exercise or protect one of your rights. You follow the procedure set out here. And no ground of refusal in section 9 of this manual applies.

That first condition is the one people miss. A request to a private business is not the same as a request to a government department. You have to say which right of yours is at stake and why the record is needed to exercise or protect it. Curiosity is not enough, and the law does not pretend otherwise.

Step 1: use Form 2

Requests must be made on a form that corresponds substantially with Form 2 of Annexure A to the PAIA Regulations, 2021. The Regulator publishes it as Form 02, Request for Access to Record. Older forms that other manuals still show came from the 2002 regulations, which regulation 17(1) of the 2021 Regulations repealed. Do not use one. If you cannot download Form 2, email us and we will send it to you.

Step 2: fill it in properly

Your request needs to tell us:

• enough detail for us to work out which record you mean;
• who you are, and an address, fax number or email address in South Africa where we can reach you;
• which form you want the record in, for example a printed copy or an emailed file;
• which right of yours you are exercising or protecting, and why this record is needed for that;
• whether you want to be told the outcome in any way other than in writing, and how; and
• proof that you are allowed to act for somebody else, if you are asking on their behalf.

Step 3: send it to us

Email the completed form to noleen@ladybugz.co.za, or post it to the address in section 2 of this manual. Put PAIA request in the subject line so it is not missed.

Step 4: pay the request fee

We will tell you what to pay before we start work. The fees are in section 10 of this manual. If you are asking for your own personal information, there is no request fee.

9. When we may say no

PAIA does not leave refusals to our discretion. Chapter 4 of Part 3 of the Act sets out the only grounds, and some of them oblige us to refuse whether we would like to or not. Those are the ones marked must below.

If a record contains some material we must withhold and some we do not, we hand over the part we can and tell you what we held back and why. If a record cannot be found or does not exist, section 55 requires us to tell you so on affidavit, setting out every step we took to look for it. That counts as a refusal, so the remedies in section 11 of this manual are open to you.

10. What it costs

The amounts below are fixed by Annexure B to the PAIA Regulations, 2021, published under Government Notice R.757 in Government Gazette 45057 of 27 August 2021. We do not set them and we cannot discount them.

Two things worth knowing. The first hour of searching is free, so a small, well aimed request often costs you nothing beyond the R140 and the copying. And if you pay a deposit and we then refuse the request, section 54(4) requires us to pay that deposit back.

We may hold a record until the fees on it are paid. A copy of this manual is free on our website. If you want a printed copy, the photocopy fee of R2.00 per A4 page applies.

11. When we must answer, and what you can do if we say no

We must decide on your request and tell you the outcome as soon as we reasonably can, and in any event within 30 days of receiving it. If we miss that altogether, the law treats our silence as a refusal.

Section 57 lets us take longer, but only once, and only by up to another 30 days. The grounds are fixed by the Act and there are five of them:

• the request is for a large number of records, or needs a search through a large number of records, and keeping to the first 30 days would unreasonably interfere with running the business;
• the records have to be found at, or collected from, an office of ours that is not in the same town or city as the office of the head of the business, and that cannot reasonably be done in time;
• we need to consult among our own divisions, or with another private body, to decide the request, and that cannot reasonably be done in time;
• more than one of the three above applies, which makes the first 30 days not reasonably possible; or
• you agree in writing to the extension.

Nothing else lets us delay. If we do extend, section 57 gives you three things in writing, within 30 days of us receiving your request: how long the extension is, proper reasons for it naming the part of the Act we are relying on, and notice that you may take the extension itself to court, with the procedure and the time limit for doing so.

When we refuse, we have to give you adequate reasons and name the section of the Act we are relying on.

Complain to the Information Regulator

There is no internal appeal against a private business. Section 74 of PAIA gives that right against public bodies only. What you have instead, and it costs nothing, is a complaint to the Information Regulator under section 77A.

• Use Form 05, the PAIA complaint form.
• Send it to PAIAComplaints@inforegulator.org.za.
• Do it within 180 days of our decision, or of the date we should have answered and did not.
• You must have made a proper request to us on Form 2 first. The Regulator will ask to see it.

The Regulator can try to settle the matter between us, or investigate it.

Go to court

Court comes after the Regulator, not instead of it. Section 78(1) says a requester may apply to a court for relief under section 82 only once the section 77A complaints procedure has been exhausted. Section 78(2) then gives you 180 days from our decision to bring that application. A court can order us to hand over the record, and it can rule on the fee we charged, on an extension we took, and on the form in which we gave you the record, because that subsection names those decisions too.

Before any of that, please try us directly. Write to noleen@ladybugz.co.za and say what went wrong. Most refusals we expect to see will come down to a record we could not match to the description, and a second email usually fixes that faster than a form does.

12. How we handle personal information

Section 51 of PAIA, as amended, requires this manual to describe how we process personal information. The Academy side of the business is set out at greater length in the Academy Privacy Note, which is the fuller document if you are a member. What follows covers the whole company.

12.1 Why we process personal information

• To do the marketing work our clients contract us for, and to run the LadyBugz Academy.
• To quote, invoice, take payment and keep the accounting records the law requires.
• To support clients and members, answer questions and fix faults.
• To keep accounts and systems secure, and to investigate misuse.
• To market our own services to people who asked to hear from us, and to stop as soon as they ask us to.
• To employ and pay the people who work with us.
• To meet duties placed on us by tax, company, employment and consumer law.

12.2 Whose information we hold, and what

12.3 Who else may receive it

We do not sell personal information. We do not add anybody to another business's mailing list, and we do not send mail on a partner's behalf to their list.

12.4 Information that leaves South Africa

Yes, some of it does. The AI providers, and some of our hosting and email providers, process information outside the country, mostly in the United States and in Europe. POPIA permits this where the receiving party is bound by a law or a contract that protects the information in substantially the same way POPIA does, or where the transfer is needed to perform the contract you have with us. Both apply here. The work the Academy does cannot be done without sending questions to AI systems, and those systems sit overseas.

12.5 How we keep it safe

Access to client and member records is limited to the people at LadyBugz who need it for their work, and we review that list. Passwords are stored scrambled, so nobody here can read yours. Connections to the portal are encrypted. We keep the member database backed up.

No system is perfectly safe, and we would rather say so than imply otherwise. If we have reasonable grounds to believe somebody reached your information without permission, POPIA requires us to tell you and the Regulator as soon as we reasonably can, and we will.

13. Where to get this manual

• On this page, free, at any time.
• At our address in section 2 of this manual, for inspection during normal business hours.
• By email to anyone who asks us for it.
• As a printed copy, on payment of the R2.00 per A4 page photocopy fee in section 10 of this manual.
• To the Information Regulator, on request.

14. Keeping this manual current

Section 51(2) of PAIA requires us to update this manual regularly. We review it at least once a year, and sooner whenever our contact details change, the Information Officer changes, the prescribed fees change, or we start holding a new category of record. The compilation and revision dates at the top of the page tell you which version you are reading.

15. The Information Regulator

The Regulator enforces both PAIA and POPIA. You can approach it about an access request we refused, or about how we have handled your personal information.

16. Issued by

Noleen Thompson
Director and Information Officer
LadyBugz Marketing (Pty) Ltd
Date: 1 November 2026