PAIA Manual

1Introduction

This manual is published by Atrium Capital (Pty) Ltd, trading as BriefCounsel (“Atrium”, “we”, “us”), in terms of 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”). It describes the records we hold and explains how a person may request access to them. It should be read with our Privacy Policy and Terms of Service.

2About Atrium Capital

Name

Atrium Capital (Pty) Ltd, trading as BriefCounsel

Registration number

2026/343577/07

Information Officer

Daniël Francois Rheeder

Address

8 Harfield Road, Claremont, Cape Town, 7708

Email

franco@briefcounsel.ai

Telephone

+27 73 956 7459

Website

briefcounsel.ai

3The Regulator’s Guide on how to use PAIA

The Information Regulator has compiled a guide, in terms of section 10 of PAIA, on how to use the Act. It is available from the Regulator at: The Information Regulator (South Africa), JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001; enquiries@inforegulator.org.za; PAIAComplaints@inforegulator.org.za; www.inforegulator.org.za.

4Records available in terms of other legislation

Some of our records are kept, and may be accessed, in terms of other laws, including:

• •Companies Act 71 of 2008
• •Tax Administration Act 28 of 2011 and Value-Added Tax Act 89 of 1991
• •Protection of Personal Information Act 4 of 2013
• •Basic Conditions of Employment Act 75 of 1997 and Labour Relations Act 66 of 1995 (where we have employees)
• •Electronic Communications and Transactions Act 25 of 2002

5Records held by Atrium

We hold records in the following broad categories. Listing a category does not mean access will be granted — every request is considered against the grounds for refusal in clause 7.

• •Statutory and company records (incorporation documents, Memorandum of Incorporation, director and shareholder records).
• •Financial and tax records (accounting records, invoices, bank and payment records, tax returns).
• •Customer and account records (name, email address, firm or practice name, subscription and payment status, payment-processor customer reference, and support correspondence).
• •Supplier, operator and other contracts (service-provider agreements, non-disclosure agreements, and the Operational Agreement and Terms of Service with users).
• •Product and technical records (software, the Redaction Engine, system designs and documentation — confidential and proprietary to Atrium).
• •Marketing and website records.
• •Employee and human-resources records (where applicable).

6Voluntary disclosure of records

We do not, at present, make any category of record automatically available for inspection without a formal PAIA request under section 52. All access requests must follow the procedure in clause 8.

7Processing of personal information (POPIA)

Atrium is the responsible party for the personal information it processes. This is set out in full in our Privacy Policy; in summary:

7.1Purpose. We process personal information to create and manage user accounts, provide BriefCounsel, take payment, give support, and comply with the law.

7.2Data subjects. Users of BriefCounsel (legal practitioners and firms), prospective customers, suppliers and service providers, and employees where applicable.

7.3Categories of personal information. Name, email address, firm or practice name, subscription and payment status, a payment-processor customer reference (we do not receive or store card details), and communications with us.

7.4Recipients (operators). Railway (cloud hosting and infrastructure, on servers outside South Africa — currently the United States); Anthropic (AI provider, which receives only redacted content); Paystack (payment processing); and Postmark (transactional email).

7.5Cross-border transfers. Where processing takes place outside South Africa, we rely on the data subject’s consent and on the necessity of the transfer to perform our contract, and we put in place agreements requiring a level of protection substantially similar to POPIA.

7.6Security. We apply reasonable technical and organisational safeguards. BriefCounsel runs locally on the practitioner’s device; personal and identifying information is redacted on the device before any content is transmitted, and the Restoration Map never leaves the device.

8How to request access to a record

8.1Complete the prescribed form (the Request for Access to Record of a Private Body, Form 2 under the PAIA Regulations, 2021) and send it to the Information Officer at the address in clause 2.

8.2Give enough detail to identify the record and yourself, state the right you seek to exercise or protect and why the record is required for that purpose, and state the form of access and how you wish to be notified.

8.3Pay the prescribed request fee and, where applicable, the access fee, as set out in the PAIA Regulations. The access fee must be paid before access is given.

8.4We will decide on the request within 30 days of receiving it (this period may be extended in the circumstances allowed by PAIA), and will notify you of the decision and of any fee payable.

9Grounds for refusal

Access may be refused on any ground set out in Chapter 4 of PAIA. These include the mandatory protection of the privacy of a third party, the commercial information of Atrium or a third party (including trade secrets and information about the Redaction Engine and our software), confidential information held about a third party, records privileged from production in legal proceedings, and research information.

10Remedies

There is no internal appeal against a decision of a private body. A requester or affected third party who is dissatisfied with a decision may lodge a complaint with the Information Regulator, or apply to a court (a Magistrate’s Court or the High Court) within 180 days of the decision, as provided in section 78 of PAIA.

11Availability of this manual

This manual is available free of charge on our website at briefcounsel.ai, and on request from the Information Officer. Copies are also lodged with the Information Regulator.

12Updates

We review and update this manual as necessary. The current version, with its “last updated” date, is the one published on our website.