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Statutory Section 51 Manual

Promotion of Access to Information Act (PAIA) Manual

Private Body: Red Alchemy (Reg: 2026/237102/07) • Governing Statute: PAIA (Act 2 of 2000) & POPIA • Effective Date: November 2026
Draft for Legal Review: This Manual is compiled in accordance with Section 51 of the Promotion of Access to Information Act (PAIA, Act 2 of 2000), as amended by the Protection of Personal Information Act (POPIA, Act 4 of 2013). It gives practical effect to the constitutional right of access to information held by private bodies.

1. Introduction to Red Alchemy

Red Alchemy ("the Practice") is an independent private practice established in South Africa, providing specialized subconscious regression therapy, personal transformation coaching, and somatic nervous system regulation led by Anita Munsamy.

This manual informs members of the public of the categories of records held by Red Alchemy, the procedure required to request access to these records, and the grounds on which requests may be granted or refused.

2. Contact Details of the Information Officer

The designated Information Officer of Red Alchemy is:

Information Officer Anita Munsamy
Entity Legal Name Red Alchemy
Registration Number 2026/237102/07
Physical Address Umhlanga Ridge, Durban, KwaZulu-Natal, 4319, South Africa
Postal Address Postnet Suite 142, Private Bag X01, Umhlanga Rocks, 4320
Telephone / WhatsApp +27 82 000 0000
Official Email anita@redalchemy.co.za
Website URL https://redalchemy.co.za

3. Guide of the Information Regulator

The Information Regulator of South Africa has compiled a comprehensive guide on how to exercise rights under PAIA in all 11 official South African languages. Members of the public can inspect or obtain a copy of this guide at:

The Information Regulator (South Africa)
JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
P.O. Box 31533, Braamfontein, Johannesburg, 2017
Website: https://inforegulator.org.za
General Inquiries: enquiries@inforegulator.org.za

4. Records Automatically Available (Section 51(1)(c))

The following records are available without formal request under PAIA:

  • Information published on the public website (redalchemy.co.za);
  • Public marketing brochures, service overviews, and fee guidelines;
  • The online Subconscious Pattern Assessment tool;
  • The official Privacy Policy, Terms of Service, and this PAIA Manual.

5. Records Kept in Accordance with Other Legislation (Section 51(1)(d))

Where applicable, records are held in accordance with the following South African statutory acts:

  • Basic Conditions of Employment Act (No. 75 of 1997)
  • Companies Act (No. 71 of 2008)
  • Consumer Protection Act (No. 68 of 2008)
  • Electronic Communications and Transactions Act (No. 25 of 2002)
  • Income Tax Act (No. 58 of 1962)
  • Protection of Personal Information Act (No. 4 of 2013)
  • Tax Administration Act (No. 28 of 2011)
  • Value-Added Tax Act (No. 89 of 1991)

6. Schedule of Records Held by Category (Section 51(1)(e))

Please note that listing a category of records below does not imply that a request for access will automatically be granted. Access to records is subject to the statutory limitations and refusal grounds set out in Chapter 4 of PAIA.

Category Subject / Record Description
Company Records Statutory incorporation documents, CIPC certificates, directorship registers, and resolutions.
Financial & Tax Invoices, statements of account, banking statements, proof of payment receipts, and tax returns.
Client Records Confidential intake forms, assessment diagnostic responses, appointment schedules, session observation notes, and custom 21-day audio tracks.
(Strictly protected under professional therapeutic confidentiality and POPIA Section 26 Special Personal Information).
Intellectual Property Proprietary session methodologies, hypnotic scripting frameworks, audio compositions, and branding assets.

7. Procedure to Request Access to Records (Section 53)

To request access to a record not automatically available, the requester must follow this statutory procedure:

  1. Complete Form 2: Download and complete the prescribed Form 2: Request for Access to Record of Private Body (available on the Information Regulator's website).
  2. Provide Sufficient Detail: The request must clearly identify:
    • The specific record(s) requested;
    • The full identity, physical address, and contact details of the requester;
    • The form of access required (e.g. digital copy, inspection);
    • The right that the requester is seeking to exercise or protect, and an explanation of why the requested record is necessary to exercise that right.
  3. Submit to the Information Officer: Deliver the completed Form 2 to Anita Munsamy via email at anita@redalchemy.co.za.
  4. Prescribed Fees: A non-refundable statutory request fee (R140.00 for private bodies) is payable upon submission, unless the requester is legally exempt. Access fees (for copying, reproduction, and search time) will be calculated and invoiced in accordance with prescribed PAIA fee regulations.

8. Decision & Notice Period

The Information Officer will evaluate the request and notify the requester of the decision within 30 calendar days of receiving the request and fee. This period may be extended once for a further period of up to 30 days if the request requires searching through a large volume of records or consultation with external parties.

9. Grounds for Refusal of Access to Records (Chapter 4)

PAIA establishes mandatory and discretionary grounds on which a private body must or may refuse access to records:

  • Protection of Privacy of Third Parties (Section 63): Mandatory refusal to disclose personal information about another natural person to prevent unreasonable disclosure.
  • Protection of Commercial Information (Section 64): Mandatory refusal to disclose trade secrets, financial calculations, or commercial data belonging to third parties.
  • Protection of Confidential Information (Section 65): Mandatory refusal if disclosure would constitute a breach of a duty of confidence owed to a third party (including therapeutic non-disclosure agreements).
  • Protection of Safety of Individuals (Section 66): Mandatory refusal if disclosure could reasonably be expected to endanger the life or physical safety of any person.
  • Protection of Privileged Records (Section 67): Mandatory refusal of records protected by legal or statutory professional privilege.
  • Commercial Activity of the Private Body (Section 68): Discretionary refusal of proprietary methodologies, internal coaching frameworks, or custom audio engineering scripts.

10. Remedies Available Upon Refusal

If a requester is dissatisfied with a decision to refuse access or the fees assessed, they may, within 180 calendar days of receiving notice, lodge an internal complaint with the Information Regulator or apply to a court of competent jurisdiction (e.g. the Magistrates' Court or High Court of South Africa) for appropriate relief.

11. Availability of this Manual

This manual is available for inspection free of charge on the Red Alchemy website at https://redalchemy.co.za/paia-manual.html and at our physical practice suites in Umhlanga Ridge during standard consultation hours.

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