Draft for NHC review. Subject to confirmation and approval by the schools.
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.
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.
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
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
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.
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
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.
The schools keep records as required by legislation that may include the following, subject to legal review:
| Subject | Categories of records |
|---|---|
| Governance and legal | Company documents, registration as an independent school, board minutes, policies, contracts, legal matters |
| Learners | Admission applications, enrolment agreements, academic records and reports, attendance, discipline, learner support, health and medical records, sport and culture records, photos and video |
| Parents and guardians | Contact details, fee accounts, payment records, custody documents, correspondence |
| Staff | Personnel files, contracts, payroll, tax, leave, performance, disciplinary records, qualifications, SACE registration, background checks |
| Job applicants | CVs, application forms, interview notes, references |
| Finance | Financial statements, accounting records, bank records, budgets, tax returns, audit reports |
| Suppliers and service providers | Contracts, operator agreements, invoices |
| Health and safety | Incident registers, health and safety records, emergency plans |
| Facilities and security | Asset registers, and visitor registers or CCTV footage where kept |
| Marketing and communications | Websites, social media, newsletters, photo consents, enquiry records |
| IT and websites | System 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.
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.
| Data subject | Personal 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 guardians | Identity, contact, relationship, custody, financial and banking details, correspondence |
| Staff and contractors | Identity, contact, employment, payroll, tax, banking, qualifications, background checks, health, employment equity information |
| Job applicants | Identity, contact, CV, qualifications, references |
| Website users | Form data, IP address, device data, cookie data |
| Visitors | Visitor register details and camera images, where kept |
| Suppliers | Contact persons, company and banking details |
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.
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.
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.
9.1 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.
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.
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.
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.
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.