PAIA Manual

Manual prepared in terms of section 51 of the Promotion of Access to Information Act, 2000 (Act 2 of 2000) ("PAIA") · Last updated: 15 April 2026 · Version 1

1. About mybill.city

mybill.city is a free web application operated by Ryan Roseveare in his personal capacity as a sole proprietor. The service allows individuals to upload municipal billing statements from the City of Johannesburg and view, analyse, and export the data extracted from those statements.

For the purposes of POPIA and PAIA, the Responsible Party / Private Body is:

2. Information Officer

The Information Officer is responsible for ensuring compliance with PAIA and POPIA, dealing with access requests, and acting as the point of contact for the Information Regulator.

All requests, queries, and correspondence relating to records held by mybill.city should be sent to the email address above.

3. Guide on how to use PAIA

The South African Human Rights Commission has prepared an official Guide on how to use PAIA, in terms of section 10 of the Act. The Guide explains the purpose of PAIA, how to lodge an access-to-information request, the rights of requesters, and the remedies available if a request is refused.

The Guide is available in all official languages from the South African Human Rights Commission and from the Information Regulator's website at inforegulator.org.za.

4. Records held by mybill.city

mybill.city holds the following categories of records:

4.1 Records about users of the service

• User identifier — the Microsoft Entra "object identifier" (oid) of each signed-in user. We do not store names, email addresses, or other personal information except as described below.
• Consent record — for each user who has accepted the Privacy Policy and Terms & Conditions: the user identifier, the date and time of acceptance, the document version numbers accepted, and the email address and display name supplied by Microsoft at the moment of acceptance. This record exists solely as audit-defensible evidence of consent under POPIA.
• Account list — for each user, the list of City of Johannesburg account numbers and nicknames that the user has registered with the service.

4.2 Records about municipal statements

• Parsed statement data — the structured data extracted from each municipal statement PDF the user has uploaded: statement date, billing period, consumption figures (kWh and kL), unit charges, service charges, VAT, totals, and other line items appearing on the statement.
• Original PDF files — original PDFs are not retained. Each PDF is deleted from storage immediately after parsing succeeds or fails, in line with our data minimisation policy.

4.3 Records about service operation

• Operational logs — short-lived technical logs generated by Cloudflare and Microsoft Azure for the purposes of operating the service. These logs are retained according to those providers' standard retention periods.

5. Records that are automatically available

The following records are made publicly available without the need for a formal PAIA request:

• The Privacy Policy at /privacy.html
• The Terms & Conditions at /terms.html
• This PAIA Manual at /paia.html

6. How to request access to records

6.1 Request for your own records

You can already access most of the records mybill.city holds about you directly through the application:

• Sign in at https://mybill.city with your Microsoft account
• Use the "Export to Excel" button to download all parsed statement data we hold for you
• Use the "Delete my data" button to delete all records about you, in exercise of your POPIA right to erasure

If you require records that are not accessible through the application interface (for example, the contents of your consent record), email support@mybill.city with the subject line "PAIA access request" and we will respond within 30 days.

6.2 Formal PAIA request

Formal access requests under PAIA must be made on the prescribed Form 2 (request for access to records of a private body), available from the Information Regulator's website at inforegulator.org.za.

Submit the completed Form 2 by email to support@mybill.city. We will acknowledge receipt within 5 working days and respond substantively within 30 days, as required by section 56 of PAIA.

6.3 Fees

mybill.city does not charge any fees for PAIA access requests. We waive both the request fee and any access fees that would otherwise be payable under section 54 of PAIA. This may change in future, in which case this Manual will be updated.

7. Grounds for refusal of access

Access to a record may be refused only on grounds permitted by Chapter 4 of PAIA, including:

• Mandatory protection of the privacy of a third party (section 63)
• Mandatory protection of commercial information of a third party (section 64)
• Protection of the safety of individuals or property (section 66)
• Protection of records privileged from production in legal proceedings (section 67)
• Protection of commercial information of the private body (section 68)
• Protection of research information (section 69)

Where access is refused, we will provide written reasons and inform you of your right to lodge a complaint with the Information Regulator.

8. Remedies available

If your request for access is refused, or you are not satisfied with the response, you have the following remedies:

• Internal request for reasons — request written reasons for the refusal from the Information Officer.
• Complaint to the Information Regulator — lodge a complaint with the Information Regulator using the prescribed form. Contact details and forms are available at inforegulator.org.za.
• Application to court — apply to the High Court for appropriate relief, after exhausting the complaint process with the Information Regulator.

9. Information Regulator contact details

10. Updates to this Manual

This Manual will be reviewed and updated from time to time. The version and "last updated" date at the top of this page will reflect the most recent revision. The current Manual will always be available at https://mybill.city/paia.html.