Carlow Translations

PAIA Manual

Prepared in accordance with section 51 of the Promotion of Access to Information Act 2 of 2000 (“PAIA”) and sections 23 and 24 of the Protection of Personal Information Act 4 of 2013 (“POPIA”).

Effective date: 01 August 2026
Last reviewed: 01August 2026
Version: 1.0

1. Introduction

This Manual has been prepared for Carlow Translations in accordance with section 51 of PAIA.

PAIA gives effect to the constitutional right of access to information. It permits a person to request access to records held by a private body where the record is required for the exercise or protection of a right, subject to the requirements and grounds for refusal contained in PAIA.

This Manual explains:

The records held by Carlow Translations;
Which records may be available without a formal request;
How to request access to a record;
The purposes for which personal information is processed;
The categories of people whose personal information may be processed;
When information may be shared with third parties or transferred internationally;
The security measures used to protect information; and
The remedies available if a request is refused.

This Manual should be read with Carlow Translations’:

Privacy Policy;
POPIA Compliance Declaration;
Terms and Conditions; and
Cookie Notice.

2. Details of the private body

Trading name: Carlow Translations
Legal name or owner: Lance Gert Carlow
Business type: Sole proprietorship
Physical address: Port Edward, Kwa-Zulu Natal, 4184
Postal address: Port Edward, Kwa-Zulu Natal, 4184
Telephone: +27 84 756 5504
Email: admin@carlowtranslations.com
Website: www.carlowtranslations.com

Head of the private body and Information Officer

Name: Marjorie Constance Carlow
Position: Owner / Director / Head of Private Body
Telephone: +27 84 756 5504
Email: admin@carlowtranslations.com

For a sole proprietor, the owner will ordinarily be the head of the private body and Information Officer.

All PAIA requests and enquiries about this Manual must be directed to the Information Officer.

3. Nature of the business

Carlow Translations provides professional language and document-related services, including:

General and specialised translation;
Legal, medical, immigration, educational, financial and business translation;
Proofreading and editing;
Marketing translation and copywriting;
Document formatting; and
Other language-related services agreed with clients.

Carlow Translations may work with associate translators, editors, proofreaders and other language professionals situated in South Africa and other countries.

4. Purpose of this Manual

The purpose of this Manual is to:

Assist members of the public in identifying records held by Carlow Translations;
Explain how a person may request access to those records;
Describe records that may be available without a formal request;
Explain the fees and procedures applicable to a request;
Describe how Carlow Translations processes personal information;
Facilitate the exercise of rights under PAIA and POPIA; and
Promote transparency and accountability.

This Manual does not guarantee that every requested record will be disclosed. Access remains subject to PAIA, POPIA and other applicable law.

5. The Information Regulator’s PAIA Guide

The Information Regulator has published a guide explaining how to exercise rights under PAIA. The guide contains information about:

The purpose of PAIA;
How to submit an access request;
Assistance available from Information Officers and the Information Regulator;
The applicable forms and fees;
The remedies available when a request is refused;
Complaints to the Information Regulator; and
Applications to court.

The guide is available in South Africa’s official languages and may be obtained from the Information Regulator or accessed through its website.

Information Regulator (South Africa)
Website: Information Regulator – PAIA
PAIA forms: Information Regulator – prescribed PAIA forms
Telephone: 010 023 5200
Toll-free: 0800 017 160
PAIA complaints email: PAIAComplaints@inforegulator.org.za
Postal address: P.O. Box 31533, Braamfontein, Johannesburg, 2017
Physical address: Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191

The Regulator’s details should be checked periodically because they may change.

A copy of the PAIA Guide may also be requested from Carlow Translations’ Information Officer during normal business hours.

6. Records automatically available

The following records may be available without submitting a formal PAIA request, depending on their nature and whether they contain confidential or personal information:

Category	Records potentially available
Website information	Service descriptions, contact information, published pricing and website content
Legal notices	Privacy Policy, POPIA Compliance Declaration, Terms and Conditions, Cookie Notice and this PAIA Manual
Marketing material	Public advertisements, brochures, social-media posts and service announcements
Client-specific records	Quotations, invoices, receipts, correspondence and completed work available to the relevant client, subject to identity verification
Prescribed information	Records required to be made publicly available under applicable legislation
PAIA resources	Prescribed request forms and information about submitting an access request

Publication on the website or inclusion in this section does not mean that confidential information, another person’s personal information, intellectual property or privileged material will be disclosed without restriction.

Carlow Translations has not necessarily submitted a notice of voluntary disclosure under section 52 of PAIA. The categories above identify information that may practically be supplied without requiring a formal PAIA process.

7. Records held in accordance with legislation

Where applicable to its activities, Carlow Translations may hold records required under legislation including:

Basic Conditions of Employment Act 75 of 1997;
Companies Act 71 of 2008;
Compensation for Occupational Injuries and Diseases Act 130 of 1993;
Consumer Protection Act 68 of 2008;
Copyright Act 98 of 1978;
Electronic Communications and Transactions Act 25 of 2002;
Employment Equity Act 55 of 1998;
Income Tax Act 58 of 1962;
Labour Relations Act 66 of 1995;
Occupational Health and Safety Act 85 of 1993;
Protection of Personal Information Act 4 of 2013;
Promotion of Access to Information Act 2 of 2000;
Tax Administration Act 28 of 2011;
Unemployment Insurance Act 63 of 2001;
Unemployment Insurance Contributions Act 4 of 2002; and
Value-Added Tax Act 89 of 1991.

The inclusion of legislation does not mean that every listed Act necessarily applies to Carlow Translations or that records exist under every Act. The list must be adjusted according to the business’s actual legal structure, staffing and tax status.

8. Categories of records held by Carlow Translations

The following records may be held electronically or in physical form.

8.1 Business and corporate records

Founding, ownership or registration documents;
Business licences and registrations;
Information Officer registration records;
Internal policies and procedures;
Business plans and operational records;
Meeting notes and resolutions, where applicable;
Insurance policies;
Supplier and service-provider agreements;
Intellectual-property records; and
Professional-adviser correspondence.

8.2 Client and project records

Client names and contact details;
Enquiries and quotation requests;
Accepted quotations and project instructions;
Translation briefs;
Source documents submitted by clients;
Draft and completed translations;
Proofreading and editing records;
Terminology lists, glossaries and style instructions;
Quality-review records;
Project correspondence;
Delivery confirmations;
Revision and correction requests;
Client approvals;
Complaints and dispute records; and
Confidentiality agreements.

Client source documents may contain identity, immigration, medical, legal, educational, financial, employment and other sensitive information.

8.3 Associate translator and contractor records

Names and contact details;
Qualifications and professional experience;
Language combinations and areas of specialisation;
Applications and selection records;
Contracts and confidentiality agreements;
Project allocations and instructions;
Work-product and quality-review records;
Invoices and payment details;
Tax and accounting records; and
Performance-related correspondence.

8.4 Financial records

Quotations;
Invoices and credit notes;
Receipts;
Bank records;
Transaction references;
Payment-provider records;
Accounting records;
Tax returns and supporting documents;
Expense records;
Debtor and creditor records; and
Financial correspondence.

Carlow Translations does not ordinarily receive or retain complete payment-card numbers, PINs or card security codes when payments are processed by an independent payment provider.

8.5 Personnel records, where applicable

Employment applications and curricula vitae;
Identity and contact information;
Employment contracts;
Payroll and remuneration records;
Leave and attendance records;
Performance and disciplinary records;
Training records;
Health and safety records;
Statutory employment records; and
Termination records.

8.6 Website and electronic-system records

Website content;
Contact-form submissions;
Document-upload records;
Server and security logs;
IP addresses and device information;
Cookie and consent records;
Website analytics;
Email and electronic communications;
Access-control records;
Backup records;
Cybersecurity and incident records; and
Hosting, storage and maintenance records.

8.7 Marketing records

Marketing plans and material;
Social-media content;
Mailing lists and communication preferences;
Direct-marketing consent records;
Opt-out and objection records;
Client testimonials used with permission;
Advertising reports; and
Website performance information.

8.8 Legal and compliance records

Privacy and data-protection policies;
POPIA compliance assessments;
Personal-information impact assessments;
PAIA requests and responses;
Data-subject requests;
Operator and confidentiality agreements;
Security-incident and breach records;
Legal opinions and privileged communications;
Complaints and investigations;
Regulatory correspondence; and
Records of information retention and destruction.

9. Processing of personal information

Carlow Translations processes personal information in accordance with POPIA and its Privacy Policy.

9.1 Purposes of processing

Personal information may be processed to:

Respond to enquiries;
Examine documents and prepare quotations;
Confirm client instructions;
Provide translation, proofreading, editing and related services;
Allocate work to suitably qualified language professionals;
Perform quality checks;
Communicate with clients and associates;
Process payments and maintain financial records;
Deliver completed work;
Handle revisions, complaints and disputes;
Manage the website and document-upload facility;
Maintain system and information security;
Prevent fraud and unlawful activity;
Comply with legal, tax and regulatory obligations; and
Establish, exercise or defend legal rights.

9.2 Categories of data subjects and information processed

Data subject	Personal information that may be processed
Clients and prospective clients	Names, contact details, identity information, project instructions, correspondence, payment and transaction information
People named in client documents	Identity, family, immigration, legal, educational, medical, employment, financial and other information contained in submitted records
Children	Birth, identity, educational, medical, family and immigration information submitted by an authorised adult
Associate translators and contractors	Contact details, identity information, qualifications, banking information, tax information, contracts and performance records
Employees and applicants	Identity, contact, employment, payroll, qualification and statutory information
Suppliers and service providers	Contact, contractual, billing, banking and tax information
Website visitors	IP address, device and browser details, cookie identifiers, usage, security and diagnostic information
Complainants and requesters	Identity, contact information, request details, supporting evidence and correspondence

Some documents may contain special personal information, information about criminal conduct or personal information concerning children.

9.3 Recipients or categories of recipients

Personal information may be shared with:

Authorised Carlow Translations personnel;
Associate translators, proofreaders and editors;
Website-hosting and technical-support providers;
Cloud-storage and file-transfer providers;
Email and communication providers;
Payment processors and banks;
Accounting, tax and administrative providers;
Attorneys, insurers and other professional advisers;
Regulators, courts and public authorities where required or permitted by law; and
Other persons authorised by the client or data subject.

Information is only shared when reasonably necessary and subject to appropriate legal, confidentiality and security requirements.

9.4 Cross-border transfers

Carlow Translations may use associate translators and service providers located outside South Africa.

Personal information may therefore be accessed, stored or processed in another country when required for a language combination, specialist service, storage, communication or another legitimate operational purpose.

Cross-border transfers will only take place where a condition under section 72 of POPIA is satisfied, such as:

Adequate protection under applicable law or a binding agreement;
Consent from the data subject where appropriate;
Necessity for the performance of a contract;
Necessity for a contract concluded in the data subject’s interests; or
Another lawful condition recognised by POPIA.

9.5 Security measures

Carlow Translations uses reasonable technical and organisational measures appropriate to the sensitivity of the information processed. These may include:

Password-protected accounts and devices;
Secure website connections;
Access controls;
Reputable hosting and cloud-storage systems;
Malware protection and software updates;
Secure file-transfer arrangements;
Confidentiality obligations;
Operator agreements;
Data backups where appropriate;
Incident-response procedures; and
Secure deletion or destruction practices.

No electronic system can be guaranteed to be completely secure.

10. How to request access to a record

A requester seeking access to a record must complete the prescribed Form 2: Request for Access to Record.

The current form can be downloaded from the Information Regulator’s PAIA Forms page.

The completed form must be submitted to the Information Officer using the contact details in section 2 of this Manual.

A request should:

Provide sufficient information to identify the requester;
Describe the record clearly enough for it to be located;
State the preferred form of access;
Identify the right the requester seeks to exercise or protect;
Explain why the requested record is required to exercise or protect that right;
Identify the person on whose behalf the request is made, if applicable;
Include proof of authority when acting for another person;
Provide contact details for correspondence; and
Include proof of payment of any prescribed request fee when required.

Carlow Translations may request reasonable proof of identity or authority before processing or granting access.

Applicants should not send unnecessary identity documents through unsecured ordinary email. The Information Officer may specify an appropriate verification method.

11. Requirements for access to records of a private body

Access to a private body’s record is not automatic merely because the record exists.

A requester must generally establish that:

The record is required for the exercise or protection of a right;
The procedural requirements of PAIA have been met; and
No lawful ground for refusal applies.

The Information Officer will consider each request individually under PAIA and POPIA.

A requester seeking their own personal information may also have access rights under section 23 of POPIA. The prescribed PAIA process may be used to facilitate that access.

12. Fees

PAIA permits certain request, search, preparation, reproduction, deposit and delivery fees to be charged.

The applicable fees are those prescribed by law at the time the request is made.

Important principles include:

A personal requester seeking access to a record containing their own personal information may be exempt from the request fee;
Other requesters may be required to pay the prescribed request fee before the request is processed;
An access fee may be charged for searching, preparing, reproducing and delivering the record;
A deposit may be required if the search and preparation are expected to exceed the prescribed time;
Actual postage or delivery expenses may be charged where applicable; and
Access may be withheld until applicable fees have been paid.

Carlow Translations will issue the prescribed notice explaining the outcome and applicable fees. Requesters should consult the Information Regulator’s current PAIA forms and fee information rather than relying on an outdated fee table.

13. Time period for responding

Carlow Translations will ordinarily notify the requester of its decision within 30 calendar days after receiving a valid request.

The response period may be extended once for up to an additional 30 days where PAIA permits, including where:

The request concerns a large number of records;
A search through a large number of records is required;
The records are held at another location;
Consultation with another person or body is reasonably necessary; or
The requester agrees to an extension.

If the period is extended, the requester will be notified of the extension and the reasons for it.

Failure to respond within the applicable statutory period may constitute a deemed refusal.

14. Forms of access

Where access is granted, it may be provided by:

Allowing inspection of the record;
Providing a printed copy;
Providing an electronic copy;
Providing a transcription;
Allowing the requester to listen to or view a record;
Supplying another form permitted by PAIA; or
Providing access in the reasonable form requested, where practicable.

Access may be given in another form if providing it in the requested form would unreasonably interfere with business operations, damage the record or infringe copyright.

15. Grounds for refusing access

Access may be refused where PAIA requires or permits refusal. Grounds may include protecting:

Another person’s privacy;
Commercial information of another person;
Confidential information supplied by another person;
The safety of individuals or security of property;
Legally privileged information;
Carlow Translations’ commercial information;
Research information;
Copyright and intellectual property;
Confidential client documents;
Associate translators’ personal or commercial information; and
Records whose disclosure is prohibited by law.

Access may also be refused if a request is manifestly frivolous or vexatious or would require an unreasonable diversion of resources.

Where practicable, Carlow Translations may sever protected information and provide access to the remainder of a record.

Mandatory disclosure provisions contained in PAIA will be applied where relevant.

16. Third-party notification

If a requested record contains information concerning another person, Carlow Translations may be required to notify that person and allow them an opportunity to make representations concerning disclosure.

This process may affect the time required to decide the request.

17. Notice of the decision

The requester will be notified in writing whether the request has been granted or refused.

If granted, the notice may state:

The applicable access fee;
Any required deposit;
The form in which access will be provided;
The arrangements for providing access; and
Any lawful limitations applying to disclosure.

If refused, the notice will ordinarily state:

Adequate reasons for the refusal;
The relevant PAIA provisions relied upon; and
The remedies available to the requester.

The prescribed Form 3: Outcome of Request and Fees Payable may be used for this purpose.

18. Records that cannot be found or do not exist

If reasonable steps have been taken to locate a requested record and it cannot be found, or there are reasonable grounds to believe it does not exist, the Information Officer may provide the requester with an affidavit or affirmation explaining:

The steps taken to locate the record;
The locations searched;
Relevant communications made during the search; and
The reasons the record cannot be found or is believed not to exist.

If the record is later located, the requester will be notified and the request will be reconsidered, subject to PAIA.

19. Remedies available to a requester

A private body does not have PAIA’s internal-appeal procedure that applies to certain public bodies.

A requester who is dissatisfied with a decision, fee, delay or deemed refusal may:

First contact the Carlow Translations Information Officer to seek clarification or resolution;
Submit a complaint to the Information Regulator using prescribed Form 5; or
Apply to a competent court for appropriate relief, subject to PAIA’s requirements and time limits.

The Information Regulator generally expects the requester to have first submitted Form 2 to the private body and allowed the body an opportunity to respond.

Complaint information and Form 5 are available from the Information Regulator.

20. Availability of this Manual

This Manual is available:

On the Carlow Translations website at www.carlowtranslations.com;
From the Information Officer, subject to reasonable identity and access arrangements;
For inspection at Carlow Translations’ physical address during normal business hours by prior appointment; and
In electronic form upon request.

Electronic copies will ordinarily be supplied without charge. Reasonable reproduction or delivery costs may be charged where permitted by law.

21. Updating this Manual

Carlow Translations will review and update this Manual when necessary, including when there are material changes to:

Its legal or contact details;
The categories of records held;
Its information-processing practices;
Its associate-translator arrangements;
Its website, upload, payment or storage systems; or
Applicable legal requirements.

The most recent version will be published on the website.

22. Approval

Approved by: Lance Gert Carlow
Capacity: Owner / Head of Private Body / Information Officer