Platform · Legal
PAIA Manual
Version of 13 August 2026
What changed: The operator is identified as a private company registered in South Africa, Dr Sophie Ramsaroop (Pty) Ltd trading as GlowFlow, with its registration number and registered office shown. The Information Regulator's contact particulars are now published. The Information Officer is named here, in the manual, as PAIA requires; no telephone number is published for her. The prescribed fee schedule is still to be confirmed.
1. Introduction
This manual is published in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 ("PAIA").
It explains:
- the particulars of GlowFlow;
- the contact details of its Information Officer;
- the categories of records held by GlowFlow;
- which records may be available without a formal request;
- how to request access to records;
- the prescribed fees that may apply;
- the grounds on which access may be refused; and
- the remedies available where access is refused or a request is otherwise not satisfactorily dealt with.
GlowFlow is a private body for purposes of PAIA.
This Manual should be read together with GlowFlow's Privacy Policy, Terms of Use and other applicable legal documents.
Important distinction concerning clinic records
GlowFlow provides software to clinics and processes certain clinic client and patient information as an operator on behalf of the relevant clinic.
Where a record relates to a clinic's patients or clients and GlowFlow holds that record only as operator, the relevant clinic is ordinarily the responsible party and the request should be directed to that clinic.
GlowFlow will not independently determine a request for access to clinic-controlled clinical records where it does not have the authority to do so.
2. Particulars of the private body
Trading name : GlowFlow
Legal entity : Dr Sophie Ramsaroop (Pty) Ltd
Legal form : Private company registered in South Africa, trading as GlowFlow.
Registration number : 2021/383189/07
Physical address :
261 Underwood Road
Glen Park, Pinetown
KwaZulu-Natal
3610
South Africa
Website : glowflow.online
General contact email : admin@glowflow.online
3. Information Officer
Information Officer : Dr Sophie Ramsaroop
Role : Information Officer
Email : admin@glowflow.online
Requests and enquiries relating to PAIA may be submitted to the Information Officer at the above email address.
No telephone number is published for the Information Officer. Written requests should be directed to the email address above.
The Information Officer is responsible for dealing with requests for access to records held by GlowFlow in accordance with PAIA.
4. The PAIA Guide
The Information Regulator has compiled a guide contemplated by section 10 of PAIA explaining how to exercise rights under PAIA.
The Guide is available from the Information Regulator and may be obtained through its website.
Information Regulator — PAIA resources
The Guide explains, among other things:
- the purpose of PAIA;
- the rights of requesters;
- how to make a request;
- the applicable forms and procedures;
- the circumstances in which access may be refused; and
- the remedies available to a requester.
5. Records held by GlowFlow
GlowFlow holds records in electronic and, where applicable, physical form.
The following table identifies the principal categories.
| Category of record | Availability |
|---|---|
| Clinic subscription records | Available on request to the relevant clinic, subject to PAIA |
| Invoices and billing records | Available on request to the relevant account holder, subject to PAIA |
| PayFast transaction records | Available on request to the relevant clinic/account holder, subject to PAIA and records held by third parties |
| Clinic owner and staff account records | Available on request to the relevant person, subject to PAIA |
| Support correspondence | Available on request to the relevant correspondent, subject to PAIA |
| Platform security, access and audit logs | May be requested, subject to PAIA and applicable grounds for refusal |
| Company statutory records | Subject to PAIA and applicable grounds for refusal |
| Tax and accounting records | Subject to PAIA and applicable grounds for refusal |
| Employment and personnel records | Subject to PAIA and applicable privacy and other grounds for refusal |
| Contracts and commercial records | Subject to PAIA and applicable grounds for refusal |
| Policies and procedures | Subject to PAIA and applicable grounds for refusal |
| Clinic client and clinical records held only as operator | Not ordinarily available from GlowFlow under the clinic's PAIA obligations; request should be directed to the relevant clinic |
The list above is not exhaustive.
PAIA applies to records in the possession or control of a private body, subject to the Act's requirements and grounds for refusal. Section 50 provides a right of access where the statutory requirements are met and access is not refused under PAIA.
6. Records available without a formal request
GlowFlow makes the following information available publicly where applicable:
- this PAIA Manual;
- its Privacy Policy;
- its Terms of Use;
- applicable cookie information;
- its current Sub-processor Disclosure;
- platform and pricing information; and
- other information that GlowFlow elects to publish.
The availability of a record without a formal PAIA request does not mean that all related underlying records are automatically available.
7. How to make a request for access
A request for access to a record held by GlowFlow must comply with section 53 of PAIA and the applicable prescribed form.
A requester should:
- complete the prescribed Form 2 — Request for Access to Record of Private Body;
- send the completed form to the Information Officer at admin@glowflow.online;
- provide sufficient information to identify the requester;
- identify the record or records requested;
- state the form of access required;
- provide a postal address or other required contact details in the Republic;
- identify the right the requester seeks to exercise or protect;
- explain why the requested record is required for that purpose; and
- where the request is made on behalf of another person, provide proof of the authority or capacity in which the requester is acting.
Section 53 specifically requires sufficient particulars to identify both the requester and the record, the requested form of access, the right being exercised or protected and the reason the record is required for that purpose.
GlowFlow may request reasonable proof of identity or authority where necessary to verify the requester or protect personal information.
8. Processing of a request
Upon receiving a valid request, GlowFlow will process it in accordance with PAIA.
GlowFlow will ordinarily make a decision within 30 days after receipt of the request.
Where PAIA permits the period to be extended by a further period of up to 30 days, GlowFlow may extend the period and will notify the requester of the extension in accordance with PAIA.
The decision will be communicated to the requester in writing.
Where access is granted, GlowFlow will provide access in the form requested where reasonably practicable and subject to PAIA.
Where access is refused, GlowFlow will provide the requester with the reasons for the refusal and information concerning the remedies available under PAIA.
9. Fees
PAIA permits a private body to charge prescribed fees in connection with certain requests.
The fees applicable to a private body are prescribed by the regulations made under PAIA. GlowFlow will not create or substitute its own tariffs for the prescribed fees.
9.1 Request fee
A request fee of R140.00 is payable by a requester where the applicable PAIA provisions require a request fee.
A requester requesting access to their own personal information is not required to pay the request fee applicable to a non-personal requester.
The request fee must be paid before further processing of a chargeable request, subject to the applicable provisions of PAIA.
Section 54 expressly permits the prescribed request fee to be required before further processing a request, while the current regulations prescribe the private-body request fee at R140.
9.2 Reproduction and access fees
Where access is granted, the requester may be required to pay the prescribed access fees applicable to:
- reproduction of the record;
- search and preparation of the record;
- time reasonably required for search and preparation beyond the prescribed free period; and
- postage or other permitted delivery costs.
The following prescribed private-body tariffs apply:
| Item | Description | Prescribed fee |
|---|---|---|
| 1 | Request fee | R140.00 |
| 2 | Photocopy or printed black-and-white copy of an A4 page or part thereof | R2.00 per page |
| 3 | Printed copy of an A4-size page or part thereof | R2.00 per page |
| 4 | Copy in computer-readable form — flash drive supplied by requester | R40.00 |
| 5 | Copy in computer-readable form — CD supplied by requester | R40.00 |
| 6 | Copy in computer-readable form — CD supplied by GlowFlow | R60.00 |
| 7 | Transcription of visual images, per A4 page or part thereof | Fee based on reasonable outsourced service-provider quotation |
| 8 | Copy of visual images | Fee based on reasonable outsourced service-provider quotation |
| 9 | Transcription of an audio record, per A4 page or part thereof | R24.00 |
| 10 | Copy of an audio record — flash drive supplied by requester | R40.00 |
| 11 | Copy of an audio record — CD supplied by requester | R40.00 |
| 12 | Copy of an audio record — CD supplied by GlowFlow | R60.00 |
| 13 | Search and preparation — each hour or part thereof, excluding the first hour | R145.00 |
| 14 | Maximum search and preparation charge | R435.00 |
| 15 | Deposit where the search is expected to exceed six hours | One-third of the estimated access fee, calculated in accordance with the prescribed tariff |
| 16 | Postage, email or other electronic transfer | Actual expense, where applicable |
The current prescribed private-body tariff is reflected consistently in current PAIA manuals applying the 2021 Regulations, including the R140 request fee, R2 A4 reproduction fee, R145 search/preparation rate and R435 maximum.
9.3 Personal information requests
Where the requester seeks access to their own personal information, no PAIA request fee is payable.
This does not necessarily mean that every form of reproduction, search or preparation will be free where PAIA permits an applicable access fee.
GlowFlow will advise the requester of any fee that is lawfully payable before the relevant chargeable step is taken.
9.4 Deposits
Where the search and preparation of records is expected to require more than the prescribed period, GlowFlow may require a deposit in accordance with section 54 and the prescribed regulations.
The deposit may not exceed the prescribed portion of the estimated access fee.
Section 54 expressly provides for a deposit where the search and preparation requirements exceed the prescribed threshold.
9.5 Payment before access
Where an access fee is payable, GlowFlow may withhold access to the record until the applicable fee has been paid, subject to PAIA.
The requester will be notified of the applicable fee and payment arrangements.
10. Grounds for refusal
GlowFlow may refuse access to a record where PAIA permits or requires refusal.
These grounds include, where applicable:
- protection of the privacy of another person;
- protection of confidential information;
- protection of commercial information;
- protection of third-party commercial information;
- protection of legally privileged information;
- protection of the safety of individuals or property;
- protection of the security of the platform or computer system;
- protection of research and development information;
- records whose disclosure would prejudice lawful commercial interests; and
- other grounds provided for in Chapter 4 of Part 3 of PAIA.
Where only part of a record is subject to refusal, GlowFlow will consider whether the remainder of the record can lawfully be disclosed.
Where access is refused, the requester will receive written reasons and information concerning the available remedies.
11. Third-party and clinic records
GlowFlow may hold records that relate to another person, clinic or organisation.
A request for such records does not automatically entitle the requester to access them.
GlowFlow must consider the applicable privacy, confidentiality, commercial and other grounds for refusal under PAIA.
In particular, clinic client and clinical records held by GlowFlow only in its capacity as operator for a clinic remain subject to the clinic's responsible-party obligations.
Where the requester seeks access to such records, GlowFlow may refer the requester to the relevant clinic.
GlowFlow may also assist the clinic in dealing with the request where appropriate and where this is consistent with its obligations as operator.
12. Personal information and POPIA
PAIA must be read together with POPIA.
Where a requester seeks access to personal information concerning themselves, the request may also engage the rights and procedures contained in POPIA.
GlowFlow will apply the appropriate statutory framework according to the nature of the request.
Where GlowFlow is merely the operator for a clinic, a request concerning the clinic's client information will ordinarily be referred to the clinic as the responsible party.
The clinic's own PAIA Manual and Privacy Notice should therefore be consulted where the requested information concerns the clinic's patients or clients.
13. Security and confidentiality
GlowFlow will take reasonable steps to protect records against unauthorised access or disclosure.
The fact that a record exists does not mean that it is automatically accessible.
PAIA contains mandatory and discretionary grounds for refusing access, and GlowFlow will apply those provisions when considering a request.
GlowFlow may redact portions of a record where necessary to comply with PAIA.
14. Remedies
If GlowFlow refuses a request, delays a decision improperly or otherwise fails to deal with the request in accordance with PAIA, the requester may exercise the remedies available under PAIA.
A requester may, where applicable:
- lodge a complaint with the Information Regulator;
- seek relief from a court with jurisdiction; or
- exercise another remedy available under applicable law.
Section 78 of PAIA provides for court proceedings concerning decisions of a private body in the circumstances contemplated by the Act.
Information Regulator
Information Regulator (South Africa)
Woodmead North Office Park
54 Maxwell Drive
Woodmead
Johannesburg
2191
Telephone: 010 023 5200
Toll-free: 0800 017 160
PAIA complaints: PAIAComplaints@inforegulator.org.za
General enquiries: enquiries@inforegulator.org.za
Information Regulator — official website
15. Availability of this Manual
This Manual is available:
- on the GlowFlow website;
- for inspection at GlowFlow's physical address during reasonable business hours, subject to reasonable arrangements;
- by email request to admin@glowflow.online; and
- through any other method permitted by PAIA.
The Manual itself is available without charge.
PAIA requires a private body to make its manual available in the manner contemplated by section 51, and section 51 distinguishes the availability of the manual from charges that may apply to reproduction of records.
16. Updates to the Manual
GlowFlow may amend this Manual where:
- its organisational structure changes;
- its Information Officer changes;
- the categories of records it holds materially change;
- the applicable law or regulations change; or
- other information contained in the Manual requires updating.
The version date will be updated whenever the Manual is materially amended.
17. Contact details
For PAIA requests and enquiries:
Information Officer
Dr Sophie Ramsaroop
Dr Sophie Ramsaroop (Pty) Ltd t/a GlowFlow
261 Underwood Road
Glen Park, Pinetown
KwaZulu-Natal
3610
South Africa
Email: admin@glowflow.online