Using AI on client documents under POPIA
How a South African firm can let AI read client invoices and statements while meeting POPIA's security condition, and what Achekam strips or refuses.
By Achekam · · 5 min read · For Accountants & audit firms in South Africa
A bookkeeper has a pile of supplier invoices to capture before Friday and an AI tool that can read them quickly. A tax clerk wants a draft e-mail chasing a client for a missing medical aid certificate. A manager wants a summary of a long lease. None of this feels like a data protection decision, but each one sends a client's information to another company's computers.
For a South African firm, the question is not whether AI is allowed. It is whether the firm has thought about the risk and put reasonable safeguards around it, which is what POPIA's security condition asks for. This article explains that condition in practical terms and what Achekam does before any text reaches an AI vendor.
Why AI use is a security question
The Information Regulator says any organisation or individual that processes personal information, whatever its size, is a responsible party with a duty to comply with POPIA's eight conditions for lawful processing. A firm that uploads a client's payslips to an AI tool is still the responsible party for what happens to the information in those payslips.
The Act as published on the government's site requires a responsible party to secure personal information with appropriate, reasonable technical and organisational measures. Those measures include identifying foreseeable risks, maintaining safeguards against them and regularly verifying and updating them.
Applied to AI, the foreseeable risks are concrete:
- text sent to a vendor contains more than the task needs, such as identity numbers on an invoice that only needed its total;
- staff use a personal AI account the firm has no view of;
- a draft produced by AI goes out unread and says something wrong about a client;
- nobody can say afterwards which documents were sent where.
A safeguard is reasonable when it answers one of those risks directly. "We told staff to be careful" is not much of an answer to any of them.
Information that needs extra care
Some of what crosses an accountant's desk falls into categories POPIA treats more strictly. The Regulator publishes guidance notes and application forms for responsible parties that must obtain its authorisation to process special personal information, under section 27(2) of POPIA, or the personal information of children, under section 35(2).
Tax returns list dependants. Payslips can show union deductions. Medical expense claims describe treatment. Before anyone decides to run such documents through an AI tool, the firm should know which of its document types contain information in these categories and whether its own use falls within what the Act permits. Where in doubt, the Regulator's guidance notes are the place to start, not the AI vendor's terms.
What Achekam removes or refuses before text leaves
Achekam routes AI work through its own AI engine, and several safeguards sit in that engine rather than in staff discipline.
Identity numbers. By default, the engine removes South African ID numbers from text before it is sent to an AI vendor. The removal can be switched off in AI settings, so if your firm changes it, record who did so and why.
Restricted data classes. When staff upload a receipt, invoice or statement to Document Intelligence for AI to read, restricted data classes such as payroll and bank data are refused unless they have been allowed for that purpose. Achekam then re-checks totals, VAT and dates and flags any figure not found in its own transcription.
Tasks AI may not do. The engine refuses any task whose type is giving an opinion, reaching a conclusion, approving or signing. Judgement stays with the firm's people.
Drafted e-mails. When staff send a client request or a signing envelope, they can ask AI to draft the covering e-mail. A person must read and send it, and it is recorded as AI-drafted. The prompt carries no e-mail addresses, IP addresses or file contents.
Seeing what was sent and stopping it
The AI Activity Log lists every AI request with the vendor, model, tokens and an estimated cost; the cost figures are estimates from vendor list prices, not invoices. For a POPIA review, the useful part is the list itself: it answers the question "which requests went to which vendor?" without relying on memory.
A workspace administrator can also switch AI off for the whole workspace. That is a sensible step while the firm writes its policy, or immediately after a suspected incident.
If client information goes astray
The Act as published requires a responsible party that has reasonable grounds to believe personal information was accessed or acquired by an unauthorised person to notify the Information Regulator and the data subject as soon as reasonably possible. An AI tool that a staff member used outside the firm's controls is one way that can happen. Treat it like any other incident: establish what was sent, to whom and whose information it was, and let the information officer decide on notification with the reasons recorded. For the wider set of duties, see POPIA for accounting firms holding client data.
A one-page AI policy for the firm
A short written policy does more than a long one nobody reads. It might say:
- AI is used only through the firm's approved tools, never personal accounts.
- ID-number removal stays on unless a partner records a reason to change it.
- Payroll and bank documents go to AI only for purposes the firm has allowed.
- Every AI-drafted message is read by a person before it is sent.
- The AI Activity Log is reviewed monthly by the information officer.
- Special personal information and children's information are handled as the Regulator's guidance directs.
Health practices face a sharper version of the same problem; AI and patient ID numbers shows how it plays out there.
Where to read the security condition yourself
The Protection of Personal Information Act on the government's site is the official text that sets the conditions for lawful processing, including the security safeguards in section 19. Read that section with your policy draft beside it, and adjust the draft until each risk you named has a matching safeguard.
General guidance only, not advice on your own circumstances. Tax and payroll rules change: check the current position with the authority or your adviser.
