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LBVC PAIA Manual

​Prepared in terms of section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA), read with the Protection of Personal Information Act 4 of 2013 (POPIA).

Last revision: 18 June 2026

1) Introduction

This manual is published by La Bonne Vie Consulting (Pty) Ltd, trading as LBVC, in accordance with section 51 of the Promotion of Access to Information Act 2 of 2000 (“PAIA”). It explains the records LBVC holds, how a person may request access to them, and the fees that apply. It also sets out the information required by section 51(1)(c) of PAIA about LBVC’s processing of personal information under the Protection of Personal Information Act 4 of 2013 (“POPIA”).


PAIA gives effect to the constitutional right of access to information held by public and private bodies that is required for the exercise or protection of any right. LBVC is a private body as defined in PAIA. LBVC supports the right of access to information and will deal with every request fairly, promptly, and in accordance with the law. This manual is available on LBVC’s website and at its business address for inspection during normal business hours, free of charge.

2) Particulars of LBVC (section 51(1)(a)(i))

Name of private body: La Bonne Vie Consulting (Pty) Ltd, trading as LBVC
Company registration number: 2006/004816/07
Business address: 80 Strand St, Cape Town City Centre, Cape Town, 8000
Postal address: 80 Strand St, Cape Town City Centre, Cape Town, 8000
Information Regulator registration number: 2026-027889

3) The Information Officer and how to reach us

Requests under this manual must be directed to LBVC’s Information Officer:

 

Information Officer: Dr Clifford P Lewis

Email: clif@lbvc.co.za

 

For data subjects in the European Union, LBVC’s EU representative under Article 27 of the GDPR is Stefan H van Eeden (stefan@lbvc.co.za); EU-related enquiries may be directed to him.

4) The PAIA Guide (section 51(1)(b)(i))

The Information Regulator has, under section 10 of PAIA, compiled a guide on how to use PAIA. The guide explains, in plain language, how to exercise the rights PAIA and POPIA give you. It is available in each of the official languages and may be obtained from the Information Regulator:

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The Information Regulator (South Africa)

JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001 (P.O. Box 31533, Braamfontein, 2017)

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Website: https://inforegulator.org.za

General email: enquiries@inforegulator.org.za

PAIA email: PAIAComplaints@inforegulator.org.za

5) Records available without a formal request (section 51(1)(b)(ii))

Some records may be obtained without a formal PAIA request. These include:

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  • Records that LBVC provides to a client as part of a service, such as reports, psychometric profiles, dashboards, and similar deliverables, which are made available to that client in the ordinary course of the engagement.

  • LBVC’s published data policy and this PAIA manual.

  • Marketing and promotional material, and the content of LBVC’s website.

  • Any information that LBVC is required by law to make freely available.

 

A person who is the subject of personal information held by LBVC may also request a copy of their own information through the subject-access route described in LBVC’s data policy, which is usually quicker than a formal PAIA request.

6) Records available in terms of other legislation (section 51(1)(b)(iii))

Records may be accessed in terms of, among others, the Companies Act 71 of 2008, the Income Tax Act 58 of 1962, the Tax Administration Act 28 of 2011, the Labour Relations Act 66 of 1995, the Basic Conditions of Employment Act 75 of 1997, the Employment Equity Act 55 of 1998, and POPIA. Access under another law is subject to the requirements of that law.

7) Subjects and categories of records held (section 51(1)(b)(iv))

LBVC holds records, in electronic and where applicable paper form, in the following categories. Listing a category does not mean that access will be granted; every request is considered against the grounds for refusal in PAIA.

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  • Client and project records: correspondence, proposals, engagement agreements, deliverables, reports, and project files.

  • Assessment records: psychometric and other assessment data, results, profiles, and the related consent records, handled by registered professionals.

  • Consent records: records of consent obtained from clients and participants for the processing of personal information.

  • Billing and financial records: invoices, payment records, tax records, and accounting records.

  • Marketing records: mailing lists, subscriptions, and campaign records.

  • Employee and human-resources records: records relating to LBVC’s own personnel.

  • Company statutory records: registration documents, records required under the Companies Act, and governance records.

  • Supplier and service-provider records: contracts and correspondence with sub-operators and other suppliers.

8) Processing of personal information under POPIA (section 51(1)(c))

LBVC processes personal information as both a responsible party and, in client engagements, an operator. The categories of data subjects and of personal information, the purposes of processing, and the recipients of personal information are described in detail in LBVC’s data policy, which forms part of the information required by section 51(1)(c) and should be read with this manual.

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In summary, LBVC processes the personal information of clients, prospective clients, participants in assessments and research (including, in defined circumstances, minors), suppliers, and its own personnel; for the purposes of providing its services, running its business, meeting legal obligations, and conducting research on a de-identified basis. Personal information may be shared with the sub-operators listed in LBVC’s sub-operator list and with professional advisers and authorities as the data policy describes.

9) How to make a request for access to a record (section 53)

A request for access to a record that is not available without a formal request must be made on the prescribed form (Form 2 of the PAIA Regulations) and sent to the Information Officer at the email address in section 3. The request must:

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  • give enough detail to identify the record and the requester;

  • identify the right the requester seeks to exercise or protect, and explain why the record is required to exercise or protect that right;

  • state the form of access required and the manner in which the requester wishes to be notified.

 

If a request is made on behalf of another person, the requester must submit proof of the authority to act on that person’s behalf.

10) Fees (section 54)

Two kinds of fee may apply, both prescribed in Annexure B to the PAIA Regulations:

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  • A request fee of R140.00, payable by every requester (other than a personal requester seeking their own personal information) before the request is processed.

  • An access fee, calculated on the time and materials needed to prepare and provide the record, for example R2.00 per A4 photocopy or printed page, R40.00 for a copy on a flash drive provided by the requester, R60.00 for a copy on a flash drive provided by LBVC, R30.00 per A4 page for transcription of an audio record, and the reproduction or outsourced-service cost for other formats.

 

Where the preparation of a record will take more than the prescribed number of hours, LBVC may require a deposit. LBVC will notify the requester of any fee or deposit payable before proceeding, and the requester may lodge an internal or external complaint about the fee.

11) Decision, and grounds for refusal

LBVC will decide on a request within 30 days and notify the requester of the decision, the fee (if any), and the form of access. LBVC may refuse access on any ground set out in Chapter 4 of Part 3 of PAIA, which includes the mandatory protection of the privacy of a third party, of commercial information of a third party, and of certain confidential, legally privileged, or research information. Where part of a record may be withheld, access will be given to the remainder.

12) Records that cannot be found or do not exist (section 55)

If LBVC has searched for a record and believes it does not exist or cannot be found, it will notify the requester by affidavit or affirmation describing the steps taken to locate it. If the record is later found, access will be given, subject to the grounds for refusal.

13) Remedies and complaints

A requester who is dissatisfied with a decision may lodge a complaint with the Information Regulator, on a form corresponding to Form 5 of the PAIA Regulations, within 180 days of the decision. The Regulator’s contact details appear in section 4. A requester may also apply to a court as PAIA allows. LBVC asks that a requester first raise the matter with the Information Officer, so that it may be resolved directly where possible.

14) Availability and updates

This manual is available on LBVC’s website and at its business address for public inspection during normal business hours, in English, free of charge. LBVC will update the manual when its particulars or the law change.

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