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  • Data Collection and Sharing Policy for LibertéPay Ltd​

Date: 25th September, 2024

Data Collection and Sharing Policy

1. Introduction

The Data Collection and Sharing Policy defines how LibertePay collects, processes, stores, and shares personal and business data. It ensures compliance with legal obligations, protects individual privacy, and secures sensitive information in alignment with the Data Protection Act, 2012 (Act 843).

2. Purpose

This policy ensures:

  • Compliance with the Data Protection Act, 2012 (Act 843) and other regulations.
  • Lawful and transparent data collection, processing, and sharing.
  • Protection of customer data for legitimate business purposes.
  • Clear procedures for sharing data with third parties and regulators.
  • Protocols for consent and privacy protection.

3. Scope

This policy applies to:

  • Data collected from customers, employees, vendors, and partners.
  • All employees, contractors, and third-party service providers handling LibertePay data.
  • Personal, financial, technical, and employee data.
  • Data shared with external parties, including regulators and service providers.

4. Legal and Regulatory Framework

This policy complies with:

  • Data Protection Act, 2012 (Act 843): Governs personal data processing in Ghana.
  • Bank of Ghana (BoG) PSP Guidelines: Regulates payment service providers.
  • ISO 27001: International information security standards.
  • PCI-DSS: Payment card data security standards.

5. Data Collection Principles

LibertePay adheres to these principles:

  1. Lawfulness, Fairness, and Transparency: Data collected for legitimate purposes with transparency and consent where required.
  2. Purpose Limitation: Data used only for specified, explicit purposes.
  3. Data Minimization: Only necessary data collected.
  4. Accuracy: Data kept accurate and up-to-date.
  5. Storage Limitation: Data retained only as long as necessary.
  6. Integrity and Confidentiality: Data secured against unauthorized access.
  7. Accountability: Compliance demonstrated through documentation and audits.

6. Data Types Collected

LibertePay collects:

  • Personal Data: Names, contact details, financial information, and credentials.
  • Business Data: Company registration details, transaction records.
  • Technical Data: IP addresses, device identifiers, and system logs.
  • Employee Data: Personal details, job roles, and payroll information.

7. Data Collection Procedures

Data is collected via:

  • Direct Interaction: Application forms, onboarding processes.
  • Digital Platforms: Online forms, mobile apps, payment portals.
  • Third-Party Sources: Credit agencies, regulators, vendors.
  • Automated Tools: Cookies, analytics, and ICT systems.

8. Data Sharing Guidelines

Data is shared only under these conditions:

  • Third-Party Agreements: Governed by Data Sharing or Processing Agreements.
  • Regulatory Bodies: Shared with authorities like BoG when legally required.
  • Customer Consent: Explicit consent for non-essential sharing (e.g., marketing).
  • Security Measures: Encryption, anonymization, and secure protocols (e.g., SSL).
  • Cross-Border Transfers: Compliant with international data protection laws.

9. Consent and Legal Basis

Data is processed based on:

  • Consent: Explicit permission for specific uses.
  • Contractual Necessity: Fulfilling agreements (e.g., payments).
  • Legal Obligation: Compliance with laws (e.g., reporting to BoG).
  • Legitimate Interests: Business interests that do not infringe privacy.

10. Data Security and Protection

Security measures include:

  • Encryption: AES-256 for data in transit and at rest.
  • Access Control: Role-based access (RBAC) to sensitive data.
  • Data Anonymization: Used for analytics and research.
  • Security Audits: Regular vulnerability assessments.
  • Data Breach Response: Incident Response Plan with breach notifications.

11. Customer Rights

Customers have the right to:

  • Access their data.
  • Request corrections (rectification).
  • Request deletion (erasure).
  • Object to processing.
  • Data portability to another provider.

12. Monitoring and Review

LibertePay will:

  • Monitor compliance through audits and metrics.
  • Review this policy annually or after significant changes.

13. Policy Violations

Violations may result in:

  • Disciplinary action (up to termination).
  • Revocation of remote work privileges.
  • Legal action for severe breaches.
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