PAIA manual

Prepared under section 51 of South Africa's Promotion of Access to Information Act 2 of 2000, as amended (PAIA), from the Information Regulator's template for private bodies.

Compiled: 23 October 2026. Last revised: 23 October 2026.

1. Words used in this manual

In short: The short names this manual uses. They are the ones in the Regulator's template.

• "DIO": Deputy Information Officer.
• "IO": Information Officer.
• "Minister": the Minister of Justice and Correctional Services.
• "PAIA": the Promotion of Access to Information Act 2 of 2000, as amended.
• "POPIA": the Protection of Personal Information Act 4 of 2013.
• "Regulator": the Information Regulator of South Africa.
• "Republic": the Republic of South Africa.
• "We", "us", "the company": The Doxa Way Ltd.

2. What this manual is for

In short: It tells you what records we hold and how to ask for them. It also says how we use personal information.

This manual helps you to:

• see which of our records you can get without a formal PAIA request;
• understand how to ask for a record, and what subjects and kinds of records we hold;
• know which records we keep because other laws ask us to;
• reach our Information Officer, who helps with requests;
• find the Regulator's guide on how to use PAIA;
• know why we use personal information, about whom, and what kinds;
• know who may receive personal information, and whether it goes outside the Republic;
• know how we keep personal information safe.

3. Who we are, and how to reach us

In short: The Doxa Way Ltd, a UK company that makes Wamemba me and Doxa. Our Information Officer is Garth Hilton Watson, the director.

The Doxa Way Ltd is a private company registered in England and Wales (company number 16744139). It provides two services, each with its own app, website, accounts and data: Wamemba me (wamemba.me), an app for keeping what little children say, and Doxa (doxa.app). This one manual covers the whole company.

3.1 Information Officer (the head of the company, PAIA section 1)

• Name: Garth Hilton Watson, Director
• Tel: no phone line yet; please email
• Email: garth@wamemba.me
• Fax: none

3.2 Deputy Information Officer: none appointed.

3.3 Access to information, general contact: hello@wamemba.me

3.4 Head office

• Postal and physical address: 108 Kings Road, New Haw, Addlestone, KT15 3BH, United Kingdom
• Telephone: no phone line yet; please email
• Email: hello@wamemba.me
• Websites: wamemba.me and doxa.app

We have no office in the Republic.

4. The Regulator's guide to PAIA

In short: The Regulator publishes a free guide to using PAIA and POPIA. You can get it from the Regulator, or ask us for a copy.

The Regulator has updated and published a Guide on how to use PAIA (section 10(1) of PAIA). It is available in each official language and in braille. It describes:

• the objects of PAIA and POPIA;
• the contact details of the Information Officer of every public body, and of every Deputy Information Officer of every public and private body;
• how to make a request for a record of a public body (section 11) and of a private body (section 50);
• the help available from the Information Officer of a public body, and from the Regulator;
• every remedy in law for an act or failure to act under PAIA and POPIA, including an internal appeal, a complaint to the Regulator, and an application to court;
• the duty of public and private bodies to compile a manual (sections 14 and 51), and how to get one;
• the voluntary disclosure of categories of records (sections 15 and 52);
• the notices about fees for requests (sections 22 and 54);
• the regulations made under section 92.

You can get the Guide:

• from the Regulator's website, inforegulator.org.za;
• by asking our Information Officer, who will email it to you.

We have no office in the Republic where the Guide could be inspected in person. We will email it to you in English or Afrikaans, as you prefer.

5. Records you can get without a request

In short: Our public documents are on our websites for anyone to read. Earlier versions are sent when you ask.

6. Records kept because other laws ask us to

In short: We are an English company, so most of our records are kept under UK law. South African law adds a few.

7. Subjects on which we hold records

In short: The kinds of records we keep, grouped by subject. A request must describe the record clearly enough for us to find it.

We have no employees. Garth Hilton Watson, the director, runs the company with AI tools under business terms.

8. How we use personal information

In short: We use personal information to run Wamemba me and Doxa, and to run the company. Each service's privacy policy gives the full detail.

8.1 Why we use it. To provide each service a person signs up for: keeping their account and what they save in it, syncing it between devices, membership and refunds, answering emails, keeping the services working and secure, and, with consent where the law asks, counting how the apps are used. And to run the company: paying suppliers, keeping accounts and meeting legal duties. The full purposes and legal grounds are in wamemba.me/privacy (Wamemba me) and doxa.app's privacy policy (Doxa).

8.2 Whose information, and what kinds

8.3 Who may receive it

We never sell personal information, never show ads, and never let anyone train AI on a family's data.

8.4 Information sent outside the Republic. We are based in the United Kingdom, so personal information from the Republic is sent outside it. Wamemba me stores a family's sayings, children and account in London (United Kingdom). Some of our service providers are in the European Union or the United States (crash reports and analytics in Germany; membership records in the United States). Each is bound by a contract that protects the information in a way that is substantially similar to POPIA (section 72). Doxa's privacy policy says where its data is kept.

8.5 How we keep it safe. Every connection is encrypted. Our database lets each person read only their own family's data, and we test this rule automatically on every change. Sign-ins are kept in the phone's secure keychain. Access to production systems is limited to the people who run the services. Crash reports and analytics are built so that they can't carry a family's words. We have a written breach procedure, and we tell the Regulator and the people affected when POPIA section 22 asks us to.

9. How to ask for a record

In short: Email our Information Officer with Form 2 of the PAIA regulations. We answer within 30 days, and tell you of any fee first.

• Use Form 2 (Request for access to record) of the Regulations under PAIA, from the Regulator's website, and email it to garth@wamemba.me.
• Describe the record, say which right you need it to exercise or protect (section 50), and say how you would like to receive it.
• A request for your own personal information is free under POPIA: you can also just email hello@wamemba.me and say what you want.
• We decide within 30 days (section 56), and tell you of any prescribed fee before we go on.
• If we refuse, we tell you why and how to complain to the Regulator or apply to court.

10. Getting this manual

In short: This manual is on our website at wamemba.me/paia. You can also ask us for a copy, and the Regulator can ask for one.

A copy of this manual is available:

• at wamemba.me/paia;
• at our head office (section 3.4) for inspection in normal business hours;
• to anyone who asks, by email, free of charge;
• to the Regulator, on request.

11. Keeping this manual up to date

In short: We update this manual when something in it changes. We check it at least once a year.

The head of The Doxa Way Ltd updates this manual whenever something in it changes, and checks it at least once a year.

Issued by Garth Hilton Watson, Director and Information Officer, The Doxa Way Ltd.

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