Prepared in terms of Section 51 of the Promotion of Access to Information Act 2 of 2000 (as amended). This manual explains what records we hold, how to request access, and how we protect your personal information.
| Acronym | Definition |
|---|---|
| CEO | Chief Executive Officer / Director |
| DIO | Deputy Information Officer |
| IO | Information Officer |
| NPC | Non-Profit Company |
| NPO | Non-Profit Organisation |
| PAIA | Promotion of Access to Information Act 2 of 2000 (as amended) |
| POPIA | Protection of Personal Information Act 4 of 2013 |
| Regulator | Information Regulator of South Africa |
| Republic | Republic of South Africa |
| SAPS | South African Police Service |
| GBV | Gender-Based Violence |
| API | Application Programming Interface |
This manual has been prepared by i-LEAD Self Defense NPC in accordance with Section 51 of the Promotion of Access to Information Act 2 of 2000 (PAIA). It is intended to assist members of the public to:
This manual serves as both a PAIA compliance document and a POPIA transparency statement. It is reviewed annually and updated whenever material changes occur to i-LEAD's operations or data processing activities.
| Name | Hemant Harie |
| Title | Volunteer Information Officer, i-LEAD Self Defense NPC |
| io@i-lead.org.za |
| Name | Risha Patak Harie |
| Title | Founder & Director, i-LEAD Self Defense NPC |
| info@i-lead.org.za | |
| +27 65 910 9403 |
| Organisation | i-LEAD Self Defense NPC |
| Registration No. | 2017/507664/08 |
| NPO Number | 218-034 |
| Operating City | Johannesburg, Gauteng, South Africa |
| info@i-lead.org.za | |
| Website | www.i-lead.org.za |
| WhatsApp AI Advisor | +27 65 910 9403 |
The Information Regulator has made available a guide on how to use PAIA in terms of Section 10(1) of the Act. The guide is available in all official languages and in braille.
The guide can be obtained:
The following categories of records are publicly available from i-LEAD without submitting a formal PAIA request:
| Category of Record | Description | How to Access |
|---|---|---|
| Website content | Programme descriptions, about us, team, impact statistics | Available on website |
| Privacy Policy | Full data processing disclosure | privacy.html |
| Cookie Policy | Cookie usage disclosure | cookies.html |
| Terms & Conditions | Website and service terms | terms.html |
| PAIA Manual | This document | This page / downloadable above |
| NPO Registration | NPO certificate (218-034) | Available upon written request |
| Section 18A status | Tax exemption certificate details | Available upon written request |
| Annual reports | Narrative impact reports (where published) | Available upon request |
| Workshop schedules | Publicly advertised training events | Available on website and social media |
| Record / Category | Applicable Legislation |
|---|---|
| Certificate of Incorporation / MOI | Companies Act 71 of 2008 |
| NPO Registration Certificate | Non-Profit Organisations Act 71 of 1997 |
| PAIA Manual | Promotion of Access to Information Act 2 of 2000 |
| Privacy Policy / POPIA Compliance | Protection of Personal Information Act 4 of 2013 |
| Section 18A Tax Exemption | Income Tax Act 58 of 1962 |
| Employment records (where applicable) | Basic Conditions of Employment Act 75 of 1997; Labour Relations Act 66 of 1995 |
| Donation receipts and financial records | Income Tax Act; NPO Act |
| Subject | Categories of Records |
|---|---|
| Governance & Legal | MOI, NPO registration, PAIA manual, policies, resolutions, registration documents |
| Finance & Donations | Donation records, PayFast transaction logs, Section 18A certificates, financial statements, invoices |
| Programmes & Workshops | Workshop registers, attendance records, facilitator notes, training materials, TTT programme records |
| Human Resources | Volunteer agreements, facilitator records, consultant contracts, background check consents |
| Communications | Email correspondence, social media content, press releases, marketing materials |
| Website & Technology | Website files, hosting records, domain registration, AI advisor configuration |
| Personal Information | Contact form submissions, workshop registrations, donor details, WhatsApp session data (temporary — 24-hour auto-delete) |
| Legal Agreements | Shelter partnership agreements, corporate workshop contracts, sponsorship agreements |
| Intellectual Property | Programme curriculum, training materials, logo, brand assets |
i-LEAD processes personal information for the following purposes:
| Category of Data Subject | Personal Information Processed | Purpose |
|---|---|---|
| Workshop participants | Name, contact number, email, attendance date, parental consent (minors) | Programme delivery and follow-up |
| Donors | Name, email, payment details (via PayFast), physical address (where provided) | Donation processing, Section 18A receipts |
| Volunteers / Facilitators | Name, ID number, contact details, qualifications, emergency contacts | Operational management |
| Website visitors | IP address (hosting logs), email and message (if contact form used) | Communication, security, technical operation |
| AI Advisor users (website) | Message content during session (browser memory only — not stored by i-LEAD) | AI response generation via Anthropic API |
| AI Advisor users (WhatsApp) | Hashed phone identifier, message content (stored max 24 hours, then auto-deleted) | Conversation continuity; AI response generation |
| Corporate / Institutional clients | Organisation name, contact person details, billing information | Service delivery and invoicing |
| Recipient | Nature of Personal Information Shared |
|---|---|
| Anthropic, Inc. (USA) | AI Advisor message content — for generating AI responses via Claude API |
| Meta Platforms / WhatsApp | WhatsApp message metadata and content for message delivery |
| PayFast (Pty) Ltd (SA) | Donor payment details for secure donation processing |
| Google LLC (USA) | IP address transmitted as part of Google Fonts CDN requests (font delivery only) |
| SAPS / Law Enforcement | Only where legally required or to protect safety — under legal obligation only |
| Funders / Grantors | Anonymised programme impact data only — no personal information shared without consent |
| Afrihost (SA) | Website hosting provider — holds website files and temporary WhatsApp session data |
i-LEAD uses three third-party services that involve cross-border transfers of personal information outside South Africa. These are disclosed below in full compliance with Section 72 of POPIA. Full details are also available in our Privacy Policy §11.
| Recipient | Country | Nature of Transfer & Safeguards |
|---|---|---|
| Anthropic, Inc. | United States | AI Advisor message content (web and WhatsApp) transmitted for AI response generation. Anthropic maintains industry-standard data protection. |
| Meta / WhatsApp | Ireland & United States | WhatsApp message delivery infrastructure. Governed by Meta's Privacy Policy. i-LEAD does not control Meta's processing. |
| Google LLC — Fonts | United States | IP address transmitted as a technical necessity of loading Google Fonts from CDN. No personal content involved. |
| Security Measure | Description |
|---|---|
| HTTPS encryption | All website traffic encrypted via SSL/TLS. AutoSSL via Afrihost. |
| WhatsApp session hashing | Phone numbers stored as SHA-256 hashes — raw numbers never written to disk. |
| 24-hour auto-deletion | WhatsApp conversation sessions automatically and permanently deleted after 24 hours of inactivity. |
| Directory protection | Session storage folder protected via .htaccess (Deny from all) — inaccessible via web. |
| File permissions | Session files set to 640 — web-inaccessible, PHP-writable only. |
| Secure payment processing | All donations processed via PayFast — i-LEAD never handles card data. |
| Data minimisation | Only minimum necessary personal information is collected for each purpose. |
| No third-party analytics | i-LEAD does not use Google Analytics or behavioural tracking tools. |
A copy of this PAIA Manual is available:
A fee for a physical printed copy shall be payable as contemplated in Annexure B of the PAIA Regulations (per A4-size photocopy). Digital copies are provided free of charge.
i-LEAD Self Defense NPC commits to reviewing and updating this manual:
Issued by:
Hemant Harie
Volunteer Information Officer
i-LEAD Self Defense NPC
March 2026
Signature: ___________________________________________