PAIA and Access to Information Manual
Prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 and aligned to POPIA
| Document detail | Information |
|---|---|
| Organisation | Turning Page SA NPC |
| Registration number | 2026/710943/08 |
| Founder | Carys Lia Morkel |
| Website | www.turningpage.co.za |
| Manual owner | Information Officer / Head of the private body |
| Effective date | 04.09.2026 |
| Review cycle | Annually and when material legal, structural or processing changes occur |
| Publication status | For publication on the Turning Page SA website |
| Related documents | MOI; TP-07 POPIA & Privacy; CP-04 PAIA & Access to Information; CP-08 Records Retention; F12 Compliance Action Tracker |
1. Introduction and Legal Basis
1.1Section 32 of the Constitution of the Republic of South Africa recognises the right of access to information. The Promotion of Access to Information Act 2 of 2000 (PAIA) gives effect to that right, subject to lawful limitations.
1.2This Manual is prepared under section 51 of PAIA for Turning Page SA NPC, a non-profit private body. It must be read with the Information Regulator’s Guide on how to use PAIA and with the Protection of Personal Information Act 4 of 2013 (POPIA).
1.3A requester may obtain access to a record of a private body where the record is required for the exercise or protection of a right, the procedural requirements are met and no lawful ground of refusal applies.
1.4The description of a record in this Manual does not create an automatic right of access. Each request is considered on its facts under PAIA, POPIA and other applicable law.
2. Purpose and Turning Page SA Principles
This Manual supports Turning Page SA’s commitment to education, dignity, responsible stewardship, collaboration and transparent accountability. It enables the public to understand what information Turning Page SA holds, what is publicly available, how to request another record and how personal information is protected.
Access and transparency will be balanced with children’s best interests, privacy, donor and beneficiary confidentiality, safeguarding, intellectual property and the proper administration of Turning Page SA’s projects.
3. About Turning Page SA
Turning Page SA was founded by Carys Morkel and was registered as a non-profit company on 4 September 2026. It is established to advance education, learning, literacy, creativity and equitable educational opportunity, with priority given to under-resourced schools and communities. Its activities may include the responsible reuse of paper and suitable materials, printed and digital learning resources, school support, educational projects, fundraising, partnerships, art and creativity initiatives, and related impact reporting.
The active Directors recorded at registration are Susan Ann Petersen, Annie Moyo and Carys Lia Morkel. The Board exercises collective governance authority under the MOI.
| Required detail | Turning Page SA information |
|---|---|
| Registered name | Turning Page SA NPC |
| Registration number | 2026/710943/08 |
| Founder | Carys Morkel |
| Directors | Carys Lia Morkel; Susan Ann Petersen; Annie Moyo |
| Head of private body / Information Officer | Jean Morkel |
| Deputy Information Officer, if appointed | Susan Petersen |
| Registered / physical address | 20 Hillwood Avenue, Bishopscourt, Cape Town, Western Cape, 7708 |
| Postal address | 20 Hillwood Avenue, Bishopscourt, Cape Town, Western Cape, 7708 |
| PAIA email | info@turningpage.co.za |
| General email | info@turningpage.co.za / carys@turningpage.co.za |
| Website | www.turningpage.co.za |
| Telephone | 083 449 9112 |
Its governance and information practices are regulated by its MOI, TP-Series NPO Policy Manual, CP-Series Compliance Manual and F-Series operational records.
4. Contact Details of the Private Body
All PAIA requests should be marked “PAIA Request” and directed to the Information Officer using the details above.
5. The Information Regulator’s PAIA Guide
5.1The Information Regulator has published a Guide explaining PAIA and POPIA, how to request access, available assistance, applicable remedies, complaints, court applications, fees and prescribed forms.
5.2The Guide and prescribed forms are available from the Information Regulator’s website at inforegulator.org.za/paia/.
5.3Information Regulator contact details: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001; PO Box 31533, Braamfontein, Johannesburg, 2017; telephone 010 023 5200; toll-free 0800 017 160; email enquiries@inforegulator.org.za.
5.4Complaints concerning a PAIA request may be submitted using prescribed Form 5 to PAIAComplaints@inforegulator.org.za or through the Regulator’s available complaint channels.
6. Records Available Without a Formal PAIA Request
Subject to accuracy, confidentiality and publication decisions, the following records may be available through the website or on ordinary request without completing Form 2:
- the public-facing purpose, programmes and project information of Turning Page SA;
- published governance or registration information approved for public release;
- published policies, including this Manual and the website privacy notice;
- approved annual reports, impact summaries and general financial accountability information;
- public donor, sponsor and partner acknowledgements where publication is authorised;
- public application, nomination, donation or contact information and downloadable forms;
- news, campaigns, events and educational resources intended for public distribution; and
- contact details and information about how to make a PAIA or privacy request.
Automatically available information excludes children’s information, confidential school or beneficiary information, private donor details, security information and records protected by law or contract.
7. Records Held by Turning Page SA
| Subject | Categories of records |
|---|---|
| Corporate and governance | MOI, CIPC and NPO records, Board and committee records, resolutions, delegations, policies, registers, compliance and risk records. |
| Programmes and projects | Needs assessments, applications, nominations, approvals, project plans, resource allocations, delivery records, monitoring, evaluation and impact reports. |
| Schools and beneficiaries | School contact and needs information, eligibility and support records, consent and safeguarding records, complaints and correspondence. Access is restricted where privacy or safeguarding applies. |
| Children and artwork | Consent records, limited participation information, artwork tracking, approved images and publicity records. These records receive heightened protection. |
| Donors, sponsors and fundraising | Donor forms, agreements, restrictions, donation and sponsorship registers, campaign and event records, acknowledgements and impact reports. |
| Finance and assets | Budgets, banking records, receipts, invoices, expenditure, administrative-cost declarations, asset and inventory records, financial statements and reports. |
| People and service providers | Director, volunteer, employee, consultant, supplier and partner records; contracts; due diligence; performance and payment information. |
| Legal and compliance | Contracts, legal advice, disputes, insurance, statutory submissions, PAIA/POPIA records, incidents, complaints and corrective actions. |
| Website and communication | Website content, enquiries, mailing or campaign records, social-media content, consented photographs, analytics, technical and security logs. |
| Intellectual property and learning resources | Readers, worksheets, designs, artwork, activity materials, licences, permissions, publishing and content-development records. |
8. Records Held under Other Legislation
Where applicable to Turning Page SA’s status and activities, records may be maintained under legislation including:
- Companies Act 71 of 2008;
- Nonprofit Organisations Act 71 of 1997;
- Income Tax Act 58 of 1962;
- Protection of Personal Information Act 4 of 2013;
- Promotion of Access to Information Act 2 of 2000;
- Children’s Act 38 of 2005;
- Basic Conditions of Employment Act 75 of 1997 and Labour Relations Act 66 of 1995, where applicable;
- Occupational Health and Safety Act 85 of 1993, where applicable;
- Electronic Communications and Transactions Act 25 of 2002;
- Copyright Act 98 of 1978;
- Financial Intelligence Centre Act 38 of 2001, where applicable;
- Prevention and Combating of Corrupt Activities Act 12 of 2004; and
- any other legislation applying to a specific programme, transaction, funder, record or activity.
9. How to Request Access to a Record
9.1A requester must complete prescribed Form 2: Request for Access to Record, available from the Information Regulator, and submit it to the Turning Page SA Information Officer.
9.2The request must identify the requester and the record with sufficient detail; state the form of access required; identify the right to be exercised or protected; explain why the record is required for that purpose; and provide proof of identity and authority where acting for another person.
9.3If a disability prevents a requester from making a written request, the requester may seek reasonable assistance from the Information Officer.
9.4Turning Page SA will notify the requester of the decision within the period prescribed by PAIA, subject to any lawful extension, transfer, third-party notice process or request for clarification.
9.5Access may be provided by inspection, copy, electronic record or another reasonably available form, subject to PAIA, preservation of the record and applicable fees.
10. Fees
10.1Prescribed request, access, reproduction, search and preparation fees may apply in the amounts determined under PAIA regulations at the time of the request.
10.2Turning Page SA may require payment of the prescribed request fee before processing and a deposit where the permitted search or preparation time threshold is exceeded.
10.3A personal requester seeking their own personal information may be exempt from the request fee as provided by PAIA. Other statutory fee exemptions remain applicable.
10.4No fee will be charged merely to inspect this Manual electronically on the website.
11. Grounds for Refusal or Limited Access
A request may be refused or access limited where PAIA requires or permits refusal, including protection of:
- the privacy of a third party, particularly a child, learner, parent, employee, donor or beneficiary;
- confidential commercial, financial, technical or contractual information of a third party or Turning Page SA;
- information supplied in confidence;
- the safety of individuals, safeguarding arrangements or the security of property or systems;
- legally privileged records;
- research, intellectual property, educational content or creative material where protected;
- records whose disclosure is prohibited by law; or
- other interests protected under Chapter 4 of Part 3 of PAIA.
Where reasonably possible, access may be granted to a severable portion after protected information is removed. A refusal will state adequate reasons and available remedies, subject to lawful limitations.
12. Remedies and Complaints
12.1Turning Page SA, as a private body, does not have a PAIA internal appeal procedure. A requester should first raise concerns with the Information Officer so the matter can be reconsidered or clarified.
12.2A requester or affected third party may lodge a complaint with the Information Regulator using prescribed Form 5 within the applicable period, or approach a competent court as provided by PAIA.
12.3Information about complaint procedures is available from the Information Regulator at inforegulator.org.za/paia/.
13. Processing of Personal Information under POPIA
| Category | Turning Page SA position |
|---|---|
| Purposes | School and project assessment; resource delivery; donor and sponsorship administration; fundraising; safeguarding and consent; volunteer, supplier and partner administration; governance; legal compliance; communication; website operation; monitoring and impact reporting. |
| Data subjects | Children and learners; parents or guardians; school representatives and educators; donors and sponsors; website users and enquirers; Directors and office-bearers; volunteers, employees and applicants; suppliers, contractors and partners. |
| Information | Identity and contact details; school, grade and needs information; consent and participation records; donation and transaction information; correspondence; contractual and compliance information; images or artwork where lawfully authorised; online identifiers and technical data. |
| Recipients | Authorised Turning Page SA personnel; schools; approved service providers; banks and payment providers; auditors and advisers; donors or partners for authorised reporting; regulators, public bodies or law-enforcement agencies where lawfully required. |
| Cross-border processing | Personal information will not be transferred outside South Africa unless the requirements of POPIA are satisfied and appropriate protection is in place. Website, cloud, email or technology providers must be assessed for hosting and transfer arrangements. |
| Security safeguards | Role-based access, confidentiality duties, secure storage, appropriate passwords and technical controls, backups, service-provider safeguards, breach response, retention controls and secure destruction, proportionate to the sensitivity and risk. |
| Children’s information | Processed only where necessary and lawful, with heightened safeguards, appropriate consent or authorisation, minimal identification and priority given to the child’s best interests. |
14. Website-specific Transparency
14.1This Manual must be published on www.turningpage.co.za together with, or clearly linked to, the website privacy notice and relevant PAIA forms.
14.2Website contact, donation, nomination, application or newsletter facilities must state what information is collected and why. Optional marketing consent must not be bundled with necessary project communication.
14.3Cookies and analytics must be described in the website privacy or cookie notice. Non-essential technologies should be managed through an appropriate consent mechanism where required.
14.4Public impact stories must use proportionate, verified and consented information. Children should not be unnecessarily identified and safeguarding must take priority over promotional value.
14.5Online publication does not make underlying confidential records automatically available.
15. Availability and Updating of This Manual
15.1This Manual is available free of charge on the Turning Page SA website, for inspection at the confirmed principal place of business during reasonable hours, and electronically on request from the Information Officer.
15.2A reasonable reproduction charge may apply where a physical copy is requested, subject to PAIA.
15.3The Manual will be reviewed at least annually and whenever there is a material change to the organisation, its Information Officer, records, website, programmes, processing activities or applicable law.
15.4The Board approval and version history must be recorded through TP-01, CP-04 and F12.
16. Approval and Version Control
| Control | Detail |
|---|---|
| Approved by | Turning Page SA Board of Directors |
| Resolution number | 001 |
| Approval date | 04.09.2026 |
| Effective date | 04.09.2026 |
| Version | 1 |
| Next review date | 03.09.2027 |
| Document owner | Information Officer |
Annexure A - PAIA Request Checklist
- Use prescribed Form 2 from the Information Regulator.
- Attach proof of identity.
- If acting for another person, attach proof of authority.
- Describe the record clearly.
- State the right to be exercised or protected.
- Explain why the record is required for that right.
- Select the required form of access and preferred notice method.
- Submit the form to the Turning Page SA Information Officer.
- Pay any prescribed fee when formally requested.
- Retain proof of submission and correspondence.
Annexure B - Internal Request Register Fields
| Field | Record |
|---|---|
| Reference number | |
| Date received | |
| Requester and capacity | |
| Record requested | |
| Right identified | |
| Identity / authority verified | |
| Fee notice / payment | |
| Third-party notice required | |
| Decision and date | |
| Access form / redactions | |
| Reasons and remedy notice | |
| Closure date |
Reference Basis
Prepared with reference to the Constitution of the Republic of South Africa, 1996; PAIA, including sections 50, 51, 52, 54 and the grounds of refusal applicable to private bodies; POPIA; the Information Regulator’s current private-body PAIA Manual template, Guide and prescribed Forms 2 and 5; and Turning Page SA’s MOI, TP-07, CP-04, CP-08 and F12. This Manual is tailored solely to Turning Page SA’s educational purpose, records, governance and child-safeguarding obligations.