PAIA Manual

Draft for NHC review. Subject to confirmation and approval by the schools.

PAIA Manual (provisional)

New Horizon College Bethlehem and New Horizon College Harrismith
Prepared under section 51 of the Promotion of Access to Information Act 2 of 2000 (“PAIA”) and the Protection of Personal Information Act 4 of 2013 (“POPIA”).
Prepared for review 7 November 2026. Not yet an approved manual of the schools.

Status: This is a provisional manual. Some information that PAIA requires, including the name and contact details of the head and Information Officer of each company, has not yet been confirmed. It will be completed and dated once each company confirms these details. Until then, the campus contacts below can be used to submit requests.

1. Introduction

New Horizon College is an independent school with two campuses, run by two separate companies: New Horizon College Bethlehem and New Horizon College Harrismith. According to the schools’ websites, each campus offers Little New Horizon, Primary School, High School and Boarding. Each company is a separate private body for PAIA purposes.

This manual explains how to request access to records held by the schools, the types of records they hold, and how they process personal information. It is published at https://nhc.co.za/paia-manual/ and copies can be requested from either campus office.

2. Abbreviations

  • PAIA: Promotion of Access to Information Act 2 of 2000
  • POPIA: Protection of Personal Information Act 4 of 2013
  • Regulator: the Information Regulator of South Africa

3. Contact details

3.1 New Horizon College Bethlehem

Company registration number: 2013/190672/08
Campus: 2 Eden Plot, Bethlehem
Postal: PO Box 2424, Bethlehem, 9700
Phone: 058 303 4714
Email: bhm@nhc.co.za

3.2 New Horizon College Harrismith

Company registration number: 2004/005915/08
Campus: Bertha Frame Avenue, Harrismith, 9880
Postal: PO Box 57, Harrismith, 9880
Phone: 058 623 1077
Email: admin@nhc.co.za

Website: nhc.co.za

3.3 Head of the private body and Information Officer

Each company is a separate private body. Under PAIA, the “head” of a company is its chief executive officer or equivalent officer, or a person duly authorised by that officer, and under POPIA that head is the company’s Information Officer. The head, any authorised Information Officer or Deputy Information Officer, and their contact details are still to be confirmed by each company and will be added here. In the meantime, requests can be sent to the campus office of the company concerned, which will forward them internally. These campus contacts are general contact points and are not a statement of who holds any PAIA or POPIA role.

4. Guide on how to use PAIA

The Information Regulator has published a Guide on how to use PAIA and POPIA, as required by section 10 of PAIA. It explains how to exercise your rights under PAIA. The Guide and the Regulator’s current contact details are available on the Regulator’s website: https://inforegulator.org.za

5. Records available without a formal request

Information published on the Websites (nhc.co.za, bethlehem.nhc.co.za and harrismith.nhc.co.za), including campus contact details, admission information, the 2027 Prospectus, this manual and the Privacy and POPIA Notice, is available without a PAIA request. Whether a notice of automatically available records has been submitted under section 52 of PAIA is still to be confirmed.

6. Records kept under other laws

The schools keep records as required by legislation that may include the following, subject to legal review:

  • South African Schools Act 84 of 1996
  • Children’s Act 38 of 2005
  • Criminal Law (Sexual Offences and Related Matters) Amendment Act 32 of 2007
  • South African Council for Educators Act 31 of 2000
  • Basic Conditions of Employment Act 75 of 1997
  • Labour Relations Act 66 of 1995
  • Employment Equity Act 55 of 1998
  • Skills Development Act 97 of 1998 and Skills Development Levies Act 9 of 1999
  • Unemployment Insurance Act 63 of 2001 and Unemployment Insurance Contributions Act 4 of 2002
  • Compensation for Occupational Injuries and Diseases Act 130 of 1993
  • Occupational Health and Safety Act 85 of 1993
  • Income Tax Act 58 of 1962, Value-Added Tax Act 89 of 1991 and Tax Administration Act 28 of 2011
  • Companies Act 71 of 2008
  • Nonprofit Organisations Act 71 of 1997, where applicable
  • Electronic Communications and Transactions Act 25 of 2002
  • Consumer Protection Act 68 of 2008
  • Protection of Personal Information Act 4 of 2013
  • Promotion of Access to Information Act 2 of 2000
  • Free State provincial education legislation applicable to independent schools

7. Subjects and categories of records held

SubjectCategories of records
Governance and legalCompany documents, registration as an independent school, board minutes, policies, contracts, legal matters
LearnersAdmission applications, enrolment agreements, academic records and reports, attendance, discipline, learner support, health and medical records, sport and culture records, photos and video
Parents and guardiansContact details, fee accounts, payment records, custody documents, correspondence
StaffPersonnel files, contracts, payroll, tax, leave, performance, disciplinary records, qualifications, SACE registration, background checks
Job applicantsCVs, application forms, interview notes, references
FinanceFinancial statements, accounting records, bank records, budgets, tax returns, audit reports
Suppliers and service providersContracts, operator agreements, invoices
Health and safetyIncident registers, health and safety records, emergency plans
Facilities and securityAsset registers, and visitor registers or CCTV footage where kept
Marketing and communicationsWebsites, social media, newsletters, photo consents, enquiry records
IT and websitesSystem records, website form submissions, backups

Listing a category does not mean that records in it will be released. Access is subject to the grounds of refusal in PAIA.

8. Processing of personal information (POPIA)

8.1 Purposes

The schools process personal information to provide education and run the school, including admissions, teaching and assessment, learner wellbeing and safety, fee administration, communication with parents, employment, compliance with the law, security, and promotion of the school with consent. Full details are in the Privacy and POPIA Notice.

8.2 Categories of data subjects and their information

Data subjectPersonal information
Learners (mostly children)Identity, contact, academic, attendance, discipline, health and medical, learning support, photos and video, and other special personal information where lawful
Parents and guardiansIdentity, contact, relationship, custody, financial and banking details, correspondence
Staff and contractorsIdentity, contact, employment, payroll, tax, banking, qualifications, background checks, health, employment equity information
Job applicantsIdentity, contact, CV, qualifications, references
Website usersForm data, IP address, device data, cookie data
VisitorsVisitor register details and camera images, where kept
SuppliersContact persons, company and banking details

8.3 Recipients

Recipients may include education departments and examination or assessment bodies where applicable, other schools on transfer, health professionals, operators that process personal information on the schools’ behalf (where applicable), auditors, attorneys, insurers, and authorities where the law requires it.

8.4 Transfers outside South Africa

Some service providers may store information outside South Africa. Any such transfer may only take place as allowed by section 72 of POPIA. The specific providers involved are still to be confirmed.

8.5 Security measures

The schools are required by POPIA to take appropriate and reasonable technical and organisational measures to protect personal information. A general description of these measures will be added once confirmed.

9. How to request access to a record

9.1 Use the prescribed request form (Form 2: Request for Access to Record) available on the Information Regulator’s website, or ask the campus office for a copy.

9.2 Until Information Officer details are published, send the completed form to the campus office of the company concerned, by email or by hand.

9.3 Give enough detail to identify the record, say which form of access you want, and state which right you want to exercise or protect.

9.4 If you are requesting on behalf of someone else, include proof of your authority. A parent or guardian may request their child’s records, subject to PAIA.

9.5 PAIA requires a decision within 30 days of receiving the request. This period may be extended once, by up to 30 more days, in the circumstances PAIA allows, and you will be told if it is. If no decision is given within the required period, PAIA treats the request as refused.

9.6 Access may be refused only on the grounds set out in PAIA, for example to protect the privacy of another person (including another learner), commercial or confidential information, safety, or legally privileged records. Reasons will be given for any refusal.

10. Fees

PAIA allows a request fee and an access fee, as prescribed in the PAIA regulations. The current prescribed fees are published by the Information Regulator. No request fee is payable if you are asking for your own personal information, although an access fee may still apply. You will be told in writing if a fee or deposit is payable before your request is processed.

11. Remedies

PAIA does not provide a statutory internal appeal process for decisions of a private body. If you are not satisfied with a decision, you may lodge a complaint with the Information Regulator within 180 days of the decision, or apply to a court with jurisdiction within 180 days of the decision.

12. Objection, correction and deletion of personal information (POPIA)

To object to processing, use Form 1 under the POPIA regulations. To request correction or deletion, use Form 2 under the POPIA regulations. These forms are available on the Regulator’s website or from the campus office.

13. Updating this manual

This manual will be reviewed and updated when needed, and will be completed with each company’s head and Information Officer details and the date of approval once confirmed.