Our VaaKenya Data Protection Policy refers
to our commitment to treat information of employees, customers, stakeholders
and other interested parties with the utmost care and confidentiality.
With this policy, we
ensure that we gather, store and handle data fairly, transparently and with respect
towards individual rights.
A.
Scope
This policy refers to
all parties (employees, job candidates, customers, suppliers etc.) who provide
any amount of information to us.
B.
Definition
of Key Terms
Consent:
agreement which must be freely given, specific, informed and be an unambiguous
indication of the data subject’s wishes by which they, by a statement or by a
clear positive action, signifies agreement to the processing of personal data
relating to them.
Data
Controller: the person or organization that determines when,
why and how to process personal data. It is responsible for establishing
practices and policies in accordance with the Law. VaaKenya is the Data
Controller of all personal data relating to it and used in facilitating market
systems development, conducting research and all other purposes connected with
its business purposes.
Data
Processing: any activity that involves the use of personal
data. It includes obtaining, recording or holding the data, or carrying out any
operation or set of operations on the data including organising, amending,
retrieving, using, disclosing, erasing or destroying it. Processing also
includes transmitting or transferring Personal Data to third parties. In brief,
it is anything that can be done to personal data from its creation to its
destruction, including both creation and destruction.
Data
Protection Officer (DPO): the person appointed as such
under the GDPR and in accordance with its requirements. A DPO is responsible
for advising the organization (including its employees) on their obligations
under various data protection laws, for monitoring compliance with data
protection law, as well as with VaaKenya’s polices, and providing advice.
Data
Subject: a living, identified or identifiable individual
about whom we hold personal data.
Personal
Data:
any information identifying a data subject or information relating to a data
subject that we can identify (directly or indirectly) from that data alone or
in combination with other identifiers we possess or can reasonably access.
Personal data includes sensitive personal data and pseudonymised personal data
but excludes anonymous data or data that has had the identity of an individual
permanently removed. Personal data can be factual (for example, a name, email
address, location or date of birth) or an opinion about that person’s actions
or behaviour.
Personal
Data Breach: any breach of security resulting in
the accidental or unlawful destruction, loss, alteration, unauthorised
disclosure of, or unauthorised access to, personal data, where that breach
results in a risk to the data subject. It can be an act or omission.
Profiling:
any form of automated processing of personal data consisting of the use of
personal data to evaluate certain personal aspects relating to an individual, in
particular to analyse or predict aspects concerning that individual’s
performance at work, economic situation, health, personal preferences,
interests, reliability, behaviour, location or movements. Profiling is an
example of automated processing.
C.
Terms
of the .Privacy Policy
Employees of our
Company and its subsidiaries must follow this policy. Contractors, consultants,
partners and any other external entity are also covered. Generally, our policy
refers to anyone we collaborate with or acts on our behalf and may need
occasional access to data.
As part of our
operations, we need to obtain and process information. This information
includes any offline or online data that makes a person identifiable such as
names, addresses, usernames and passwords, digital footprints, photographs,
social security numbers, financial data etc.
Our Company collects
this information in a transparent way and only with the full cooperation and
knowledge of interested parties. Once this information is available to us, the
following rules apply.
Our data will be:
●
Accurate and kept up-to-date
●
Collected fairly and for lawful
purposes only
●
Processed by VaaKenya within its legal
and moral boundaries
● Protected
against any unauthorized or illegal access by internal or external parties
Our data will
not be:
Communicated
informally
●
Stored for more than a specified
amount of time
●
Transferred to organizations, states
or countries that do not have adequate data protection policies
● Distributed
to any party other than the ones agreed upon by the data's owner (exempting
legitimate requests from law enforcement authorities)
In addition to ways
of handling the data the VaaKenya has direct obligations towards people to whom
the data belongs. Specifically we must:
●
Let people know which of their data is
collected
●
Inform people about how we'll process
their data
●
Inform people about who has access to
their information
●
Have provisions in cases of lost,
corrupted or compromised data
● Allow
people to request that we modify, erase, reduce or correct data contained in
our databases
To
exercise data protection we're committed to:
●
Restrict
and monitor access to sensitive data
●
Develop
transparent data collection procedures
●
Train
employees in online privacy and security measures
●
Build
secure networks to protect online data from Cyber Attacks
●
Establish clear procedures for reporting
privacy breaches or data misuse
●
Include contract clauses or
communicate statements on how we handle data
● Establish data
protection practices (document shredding, secure locks, data encryption,
frequent backups, access authorization etc.)
Our data
protection provisions will appear on our website.
All
principles described in this policy must be strictly followed. A breach of
data protection guidelines will invoke disciplinary and possibly legal
action. D.
Rights of the Data
Subject - Every
data subject has the following rights. Their assertion is to be handled
immediately by the responsible unit and cannot pose any disadvantage to the
data subject.
E. How we use personal information We
will only use your personal information for the purpose which it was provided
to us for and in ways that you would reasonably expect. F. Partnership agreements with organizations
and individuals We
collect and use personal information from organizations and individuals who: ·
Are interested in applying for a
partnership opportunity with us ·
Apply for a partnership opportunity ·
Enter into a partnership agreement
with us ·
We process this personal information
to pursue our legitimate interests (and your interests as an applicant) and
fulfil our strategic aims. ·
The prime use of the personal
information is to conduct research, and to process and manage partnership
opportunities between us. We also use it for monitoring, evaluation and
reporting purposes so that we can consider important factors such as trends
in funding areas, the impact and reach of our funding, and the demographic
make-up of funding areas. ·
When legally obliged, we may share
our partners’ personal information with relevant statutory bodies as
required. ·
We may need to share it with
external reviewers and advisors (e.g. funding partners, program monitors,
evaluation specialists) to review, monitor or evaluate these partnership
opportunities. ·
We may need to share your contact
details with suppliers.
G. Raising awareness of our work We
will collect personal information from our existing partners and the public
domain to research and identify potential new funders and partners. Our legal
basis for using your personal information in this way is legitimate interest. We
will use the contact details of new and existing supporters to inform you
about our work. We will send you relevant information by email. Our legal
basis for using your personal information in this way is legitimate interest.
You can opt out or unsubscribe from receiving these communications at any
time. If
you opt in to our mailing list we will use the information that you provide
to email you information about our work, events, campaigns and other items of
interest. You can opt out or unsubscribe from receiving this information at
any time if you wish. Our legal basis for using your personal information in
this way is your consent |
H. For how long do we keep your personal information?
We will hold your
personal information for as long as is necessary. We will not retain your
personal information if it is no longer required. In some circumstances, we may
legally be required to retain your personal information, for example for
finance, employment or audit purposes.
I.
Changes
to this policy
This Data Protection
and Privacy Policy may change from time to time. Please visit this web page
periodically to keep up- to-date with the changes in this policy.
SEALED by )
VAAKENYA LIMITED )
)………………vaakenya ltd……………….
) PVT27B6DK
In the
presence of: - )
Advocate