PAIA Manual

Version 1.0, 18 October 2026

Manual of Strong Steeple, compiled under section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA), as amended by the Protection of Personal Information Act 4 of 2013 (POPIA).

1. Introduction and purpose

This manual tells you what records Strong Steeple holds, which you can get without asking, and how to request the rest under PAIA. It also describes how Strong Steeple processes personal information, as section 51(1)(c) of PAIA requires since POPIA amended it.

Strong Steeple is a software platform that churches use to share events, groups, messages, sermons, notices, resources and serving rosters with their members. It is run on the website strongsteeple.co.za, the web app app.strongsteeple.co.za, and iOS and Android apps.

This manual helps you to:

• see the categories of records available without a formal request;
• understand how to request a record, with a description of the subjects on which Strong Steeple holds records and the categories of records held on each;
• see which records are available under other legislation;
• find the contact details of the Information Officer;
• learn about the Information Regulator's Guide on how to use PAIA and how to get it;
• know whether Strong Steeple processes personal information, why, about whom, and what kinds;
• know who may receive that personal information;
• know whether personal information is sent outside South Africa, and to whom; and
• know what security measures protect it.

Abbreviations

2. Contact details of the head and Information Officer

Send all PAIA and POPIA requests to Jaco Louw, who is both the head of Strong Steeple and its Information Officer. Strong Steeple is a sole proprietorship, so the owner is the head of the private body under section 1 of PAIA. No Deputy Information Officer has been designated.

Email is the quickest way to reach us. Visits to the physical address are by appointment only, arranged by email.

3. The Regulator's Guide on how to use PAIA

The Information Regulator publishes a free Guide on how to use PAIA and POPIA rights, and you can download it from the Regulator's PAIA guidelines page. The Regulator updated it under section 10(1) of PAIA (Guide, October 2021 edition, English). It is available in all 11 official languages and in braille.

The Guide describes:

1. the objects of PAIA and POPIA;
2. the contact details of the Information Officer of every public body, and of every Deputy Information Officer of every public and private body designated under section 17(1) of PAIA and section 56 of POPIA;
3. how to request access to a record of a public body (section 11) and of a private body (section 50);
4. the help available from the Information Officer of a public body under PAIA and POPIA;
5. the help available from the Regulator under PAIA and POPIA;
6. all remedies in law for an act or failure to act regarding a right or duty under PAIA and POPIA, including how to lodge an internal appeal, a complaint to the Regulator, and an application to court;
7. the duty of public and private bodies to compile a manual (sections 14 and 51), and how to get one;
8. voluntary disclosure of categories of records (sections 15 and 52);
9. the notices on fees for access requests (sections 22 and 54); and
10. the regulations made under section 92.

You can get the Guide:

• from the Regulator's website, at the link above;
• from the Regulator's office (Woodmead North Office Park, 54 Maxwell Drive, Woodmead, Johannesburg, 2191), during normal office hours;
• on request to our Information Officer at support@strongsteeple.co.za. We will email you a copy. A printed copy can be inspected at our address by appointment.

A copy of the Guide in English and isiZulu is available from us for inspection, by appointment.

4. Records available without a request

The records below are freely available on our website or in the app, and you do not need to fill in Form 2 to get them (section 52 of PAIA). You can also ask for a copy by email.

Public church content belongs to the church that published it. Strong Steeple hosts it as the church's operator.

5. Records available under other legislation

Strong Steeple keeps the records below because the listed laws require it. Where a law gives a person a right to a record, that route can be used alongside PAIA.

This list is not complete. A record that exists under another law is still subject to the request procedure and the grounds for refusal in PAIA.

6. Subjects and categories of records held

Strong Steeple is a one-person software business, so most of its records are held electronically in the app's database and file storage. Listing a category here does not mean access will be given. Every request is still decided under PAIA, including its grounds for refusal.

7. Processing of personal information

Strong Steeple processes personal information only to run the church platform, keep it safe, answer people, and meet legal duties. It does not sell personal information, use advertising or analytics tools, or send direct marketing. Full details are in our Privacy Policy.

Responsibility for personal information on the platform is split between each church and Strong Steeple, as below. Where the church is the responsible party, Strong Steeple is its operator under sections 20 and 21 of POPIA. It processes that data only on the church's instructions and keeps it secure.

For PAIA, records Strong Steeple holds as an operator are still records it holds, and they are covered by this manual.

7.1 Purposes of processing

1. Running the Service: accounts, church membership, groups, events, rosters, messages, sermons, notices, resources and notifications. This is necessary to provide the Service. For religious belief (see 7.2), we rely on explicit consent, asked for at sign-up.
2. Keeping the Service safe: securing accounts, stopping abuse and spam, and handling content reports. This is in our and our users' legitimate interest.
3. Answering people: support questions, account deletion requests and website enquiries.
4. Meeting legal duties, including tax, PAIA and POPIA obligations.

7.2 Categories of data subjects and their information

Special personal information. Belonging to a church on Strong Steeple reveals something about a person's religious beliefs. POPIA treats this as special personal information (section 26). We process it with the data subject's explicit consent and only to run the Service.

Children. Users must be 18 or older. Church admins may not add anyone younger without a parent's or guardian's consent.

7.3 Recipients of personal information

Notifications and emails can include a church's name and part of a message, so the delivery providers handle that content. Bible audio streams directly from bible.helloao.org to the user's device. That service sees the device's IP address, but we send it nothing about the user.

7.4 Planned transborder flows

Most personal information is stored and processed outside South Africa. We send it only to providers bound by data protection laws or agreements that give protection similar to POPIA's, as section 72 of POPIA requires.

7.5 Security measures

Strong Steeple uses these safeguards to protect the confidentiality, integrity and availability of personal information:

• all traffic is encrypted with HTTPS;
• passwords are stored only as hashes;
• the hosting provider encrypts the database and stored files at rest;
• only the Information Officer can reach production systems, using individual keys;
• church admins can see only their own church's members;
• database backups are kept by the hosting provider and roll off after about 7 days;
• personal information is deleted on a schedule: sign-in sessions 6 months after last use; notifications 90 days after sending, or when they expire if that is later; website enquiries after 2 years; content reports 1 year after we last acted on them; shared files 30 days after they expire; deletion request emails once the request is done; and every account deletion, in the app or by request, leaves only a deletion record (the old account number and the date), kept as proof the deletion was done for 5 years, then deleted; and
• security compromises are reported to affected people and the Regulator under section 22 of POPIA.

8. How to request access to a record

To request a record, email a completed Form 2 to support@strongsteeple.co.za with proof of identity. We will reply within 30 days. Section 50 of PAIA gives a requester access to a private body's record only if it is needed to exercise or protect a right, the procedure is followed, and no ground for refusal applies.

If you only want your own personal information, you can simply email us from the address on your account. We won't insist on Form 2, but we will ask for proof of identity (POPIA section 23 requires it, and section 25 applies the PAIA request procedure to these requests). Under section 23(1)(a), confirming whether we hold personal information about you is free by law. Section 23(1)(b) allows a prescribed fee for a copy, but Strong Steeple gives copies free because our Privacy Policy promises it.

Requests about church-register data. For data a church is responsible for (see section 7), such as membership, groups, rosters or content posted in the church's spaces, we may refer your request to that church or handle it together with the church.

Correcting or deleting your information. You can correct most of your details yourself in your profile. You can delete your own account at any time in the app (Settings → Delete account), and the deletion takes effect immediately. If you can't sign in, ask at https://strongsteeple.co.za/account-deletion or email support@strongsteeple.co.za. Every deletion leaves only a deletion record: the old account number and the date.

8.1 Making the request

1. Download Form 2 (Request for Access to Record, Regulation 7) from the Regulator's forms page (direct PDF), or ask us for a copy.
2. Fill it in fully, including:
   • enough detail for us to find the record;
   • the form and manner of access you want (for example, an emailed copy);
   • the right you want to exercise or protect, and why the record is needed for it;
   • your preferred way to receive our reply.
3. Attach proof of identity. If you are asking for someone else, attach proof that you may act for them.
4. Email it to support@strongsteeple.co.za, or post or deliver it to 15A Dovehouse Road, Gillitts, Durban, 3625.

If you need help with the form, for example because you cannot read or write or have a disability, the Information Officer will help you. The Regulator can also help, free of charge.

8.2 Fees

Private body fees are set by the Regulations (Annexure B). The figures below are from the Regulator's PAIA fee structure (PDF, March 2026).

How fees work:

1. Unless you are a personal requester, we will send you a notice asking for the request fee before we process the request (section 54(1)).
2. If access is granted, we will tell you the access fee (Form 3). You pay it before access is given.
3. If we ask for a deposit and then refuse the request, we refund the deposit.
4. Fees are paid by EFT. We send our banking details with the fee notice.

Records sent by email usually cost only the request fee and any search time.

8.3 Timelines

• We decide within 30 days of receiving a complete request and tell you the outcome (section 56).
• We may extend this once, by up to 30 more days, for example if the request covers many records or a large search. We will tell you why before the first 30 days end (section 57).
• If we do not reply in time, the request is treated as refused (a "deemed refusal", section 58), and you can use the remedies in section 9.
• If the record is about a third party, we will tell that person and give them a chance to object (sections 71 to 73).

8.4 Grounds for refusal

PAIA requires or allows refusal in limited cases (sections 63 to 69). In summary, we must or may refuse access to protect:

• the privacy of a third party who is a natural person, including another member's personal information;
• commercial information of a third party, or of Strong Steeple, such as trade secrets or source code whose release would cause harm;
• information given in confidence, where release would breach a duty of confidence;
• the safety of individuals and the security of property or systems;
• records privileged from production in legal proceedings; and
• research information of a third party or of Strong Steeple.

Where only part of a record is protected, we will remove that part and give access to the rest. A record must be released, despite these grounds, if it would reveal a serious breach of law or an imminent public safety or environmental risk, and the public interest clearly outweighs the harm (section 70). If we refuse, we will give reasons and explain your remedies.

9. Remedies

If you are unhappy with our decision, you can complain to the Information Regulator or apply to court, each within 180 days. Strong Steeple is a private body, so there is no internal appeal.

You can challenge a decision of the head of Strong Steeple to:

• refuse your request;
• ask for a request fee or a deposit;
• extend the time to deal with your request; or
• give access in a particular form.

A deemed refusal (no reply in time) can be challenged in the same way. A third party can challenge a decision to give access to a record about them.

9.1 Complaint to the Information Regulator

Lodge a complaint on Form 5 within 180 days of receiving our decision (section 77A of PAIA). Form 5 is on the Regulator's forms page.

9.2 Application to court

You can apply to a court for relief within 180 days of our decision (sections 78 and 82). You may go to court without first complaining to the Regulator. If you do complain, you cannot go to court while the complaint is pending: the complaint must be finished or withdrawn first (section 78; Regulator's Guide, paragraph 24.1.3). Applications under PAIA are heard by the High Court or a Magistrates' Court with jurisdiction.

10. Availability and updating of this manual

This manual is free to read on our website, and free by email on request.

A copy is available:

1. on our website at https://strongsteeple.co.za/paia;
2. at 15A Dovehouse Road, Gillitts, Durban, 3625, for inspection during normal business hours, by appointment;
3. to anyone on request. An emailed copy is free. A printed copy costs R2.00 per A4 page, as set in Annexure B of the Regulations; and
4. to the Information Regulator on request.

The head of Strong Steeple will review this manual at least once a year, and whenever our records, service providers or processing change. The date of the latest revision is shown below.

Date of compilation

Issued by

Jaco Louw, owner, head of the private body and Information Officer, Strong Steeple

Sources

• PAIA Manual Template: Private Body, Information Regulator, dated 1 October 2021
• PAIA Guide (English), October 2021, and PAIA guidelines page, Information Regulator
• Form 2: Request for Access to Record, and PAIA forms page, Information Regulator
• PAIA Fees Structure and fee schedule PDF, Information Regulator, March 2026
• Information Regulator contact details
• Tax Administration Act 28 of 2011, section 29, Acts Online
• Strong Steeple Privacy Policy