SAFE WAY RIGHT WAY PRIVACY POLICY

Introduction

This Data Protection and privacy policy (the “Policy”) applies to all information that you disclose to us, and/or that we collect from or regarding you as a user of our services or our website. In the collection, control and/or even processing of your data and/or special personal data, we use utmost care and are guided by ethical considerations and data protection principles laid out in the governing law.  Here, you can read about the data we collect, how we process it and for how long we retain your data.

You should read this Policy and contact us if there is any information in this Policy about which you have questions or do not accept.

Who are we?

We are Safe Way Right Way Initiative Limited.

In this policy, ‘SWRW’, ‘we’, ‘us’ and ‘our’ all refer to Safe Way Right Way Initiative Limited.

Who does this policy apply to?

This policy applies to individuals who are our:

  • Employees;
  • Customers;
  • Community person of interest;
  • Project beneficiary;
  • Stakeholders; and
  • Social media and website users

What important terms do I need to know?

Data Subject

An individual from whom or in respect of whom personal information has been requested, collected, collated, processed or stored.

Personal Data

Any form of information concerning an identified or identifiable natural person. This means all information that directly or indirectly, alone or in combination, may identify a specific natural person. Personal data may include:

  • a name,
  • date of birth,
  • nationality,
  • marital status;
  • educational level or occupation of the person;
  • any identifying number, symbol;
  • contact information (e.g., e-mail address, postal address, telephone number);
  • location data or physical address;
  • online identifier or other assignment to the person;
  • correspondence sent by the Data Subject that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence.

Processing

Any activity or series of activities involving the use of Personal Data, such as registration, systematisation, changes, searches, compilation, transfer or disclosure to authorities.

 

What personal data does SWRW collect?

To run our activities, we may be required to collect, use, store and otherwise process your Personal Data in order to comply with particular statutory obligations and also examine the impact of our activities and/or interventions. This data will vary depending on the circumstances and the nature of relationship between SWRW and the subjects. Generally, the personal data collected may include:

  • Your name;
  • Contact information (email address, postal address, residential address, telephone number);
  • Date of birth;
  • Identifying numbers (identity document number, passport numbers, Tax Identification number and/or other national ID numbers as required);
  • Financial or billing information;
  • Any other information required to comply with regulatory requirements.

 

For what purposes does SWRW use my Personal Data?

In every case in which we collect Personal Data about you, we will inform you of the purpose of processing your Personal Data. Nonetheless, your data will be used for purposes connected or incidental to our work.

 

Is SWRW allowed to collected and process your data?

Yes, the Data Protection and Privacy Act Cap 97 permits us to collect and process your data long for lawful purposes.

 

Is your data processed automatically?

No. SWRW does not use any perform any automated decision making or profiling using your data at all. Should this change in the future, SWRW undertakes to notify you of the said changes.

 

Does SWRW transfer my Personal Data to third parties?

Yes, under particular instances we may share Personal Data with affiliated third parties, as necessary for our activities and interventions. These affiliated 3rd parties may include donors and partner entities.

 

Does SWRW transfer my personal data outside Uganda?

No. SWRW does not transfer your personal data outside Uganda. In the event that the necessity to transfer your personal data outside Uganda arises, we shall take reasonable steps to notify you.

 

How long does SWRW keep my Personal Data for?

We will not retain your Personal Data for any longer than is necessary for achieving the purpose(s) for which the Personal Data is processed except where;

  • retention of the Personal Data is required or authorised by Local laws;
  • you have consented to the retention of the Personal Data; or the
  • Personal Data is required for historical, statistical or research purposes and provided that we have established appropriate safeguards against the Personal Data being used for any other purposes.

SWRW will ensure that Personal Data which is no longer required, or which we are no longer authorised to retain, is as soon as reasonably practicable destroyed through permanent erasure by effective mechanisms.

 

How does SWRW handle Personal Data Breaches?

SWRW endeavors to implements reasonable measures to minimize the likelihood of Personal Data Breaches. If SWRW becomes aware of or reasonably suspects that a Breach has occurred or that the integrity or confidentiality of Personal Data has been compromised, SWRW will immediately notify the Data Protection Office and the data subject, additional to ad hoc incident management action procedures. 

 

What are my rights?

The Data Subject has the following rights:

  1. Right to information – meaning you have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
  2. Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
  3. Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
  4. Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.
  5. Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
  6. Right to object to processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.
  7. Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
  8. Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
  9. Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled, please contact us
  10. Right for the help of supervisory authority – meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages. The regulatory Authority is National Information Technology Authority – Uganda (NITA-U)
  11. Right to withdraw consent – you have the right withdraw any given consent for Processing of your Personal Data.

 

How to contact us?

You may exercise any of these rights above by contacting SWRW through:

You may also exercise your rights by complaining and/or appealing to the Personal Data Protection Office (PDPO) through:

  • Email: info@pdpo.go.ug
  • Call : +256 417 801 008
    • +256 417 801 009
    • +256 417 801 011