PRIVACY POLICY

Introduction

Biblia Regulated Non-WDT Sacco Society Limited is a Savings and Credit Co-operative Society (SACCO) regulated by SASRA to offer financial services. We operate the https://bibliasacco.com website, which provides more information of us and our various services/facilities as well as the MBIBLIA mobile application. As an organization, we take our responsibility regarding the management of our stakeholders’ data very seriously. This document informs you of our policy as a Data Controller and data Processor regarding the collection, use and disclosure of Personal Data when you use our services. It sets out how we manage our responsibility in the use of your data and the choices you have associated with that data as the Data Subject

POLICY STATEMENT

Biblia Regulated Non-deposit taking Sacco (Referred in here as Biblia Regulated Non-WDT Sacco Society Limited) is committed to complying with all relevant Kenyan legislation and applicable global legislations. Biblia Regulated Non-WDT Sacco Society Limited recognizes that the protection of individuals through lawful, legitimate, and responsible processing and use of their personal data is a fundamental human right.

PURPOSE OF THIS POLICY

This Data Protection Policy has been developed as a guide to Biblia Regulated Non-WDT Sacco Society Limited in management of its Members, Officials, BOD & Third-party entities contracted by Biblia Regulated Non-WDT Sacco Society Limited data. Biblia Regulated Non-WDT Sacco Society Limited obtains, uses, stores personal data relating to its stakeholders such as potential and current employees, former Biblia Regulated Non-WDT Sacco Society Limited staff, Biblia Regulated Non-WDT Sacco Society Limited members, suppliers, visitors to Biblia Regulated Non-WDT Sacco Society Limited premises, contractors, and Biblia Regulated Non-WDT Sacco Society Limited website users, collectively referred to in this policy as data subjects. This Policy sets out how Biblia Regulated Non-WDT Sacco Society Limited manages those responsibilities.

In developing this Policy, Biblia Regulated Non-WDT Sacco Society Limited BOD intends to have this as the primary reference point for all matters pertaining to data management in Biblia Regulated Non-WDT Sacco Society Limited. The contents of this Policy will therefore be carefully studied and implemented, as it constitutes an integral part of Biblia Regulated Non-WDT Sacco Society Limited ’s risk management processes. The Policy will be circulated to all Biblia Regulated Non-WDT Sacco Society Limited Staff, officials and management to enable them to familiarize themselves with the provisions herein.

Biblia Regulated Non-WDT Sacco Society Limited heavily draws its data policy guidelines from the Data Protection Act, 2019. When processing personal data, Biblia Regulated Non-WDT Sacco

Society Limited is obliged to fulfil Biblia Regulated Non-WDT Sacco Society Limited Members, Staff, officials and stakeholders’ reasonable expectations of privacy by complying with the Act.

The policy document is therefore intended to ensure that Biblia Regulated Non-WDT Sacco Society Limited:

1. Is clear about how personal data must be processed and the Sacco’s expectations for all those who process personal data on its behalf.
2. Complies with existing data protection laws and with good practice.

iii.         Protects its reputation by ensuring the personal data entrusted to it is processed in accordance with data subjects’ rights;

1. Protects itself from risks of personal data breaches and other breaches of data protection law.

SCOPE

The policy applies to:

• Employees of Biblia Regulated Non-WDT Sacco Society Limited, associated parties such as vendors, contractors and any other third party who handle and use Biblia Regulated NonWDT Sacco Society Limited information (where Biblia Regulated Non-WDT Sacco Society Limited is the ‘Controller’ for the personal data being processed, be it in manual and automated forms or if others hold it on their systems for Biblia Regulated Non-WDT Sacco Society Limited).
• All personal data processing Biblia Regulated Non-WDT Sacco Society Limited carries out for others (where Biblia Regulated Non-WDT Sacco Society Limited is the ‘Processor’ for the personal data being processed) and,
• All formats, e.g., printed, digital information, text and images, documents and records, data and audio recordings.

All Biblia Regulated Non-WDT Sacco Society Limited staff and others processing personal data on Biblia Regulated Non-WDT Sacco Society Limited ’s behalf must read and comply with the provisions of this Policy. Failure to comply with this policy may result in disciplinary action.

PRINCIPLES

Personal Data Protection Principles for Biblia Regulated Non-WDT Sacco Society Limited.

In processing personal data, Biblia Regulated Non-WDT Sacco Society Limited shall be guided by the principles of data protection as captured in the Data Protection Act, and requires Biblia Regulated Non-WDT Sacco Society Limited to ensure that personal data is:

1. Processed in accordance with the right to privacy of the data subject.
2. Processed lawfully, fairly and in a transparent manner in relation to any data subject.

iii.         Collected for explicit, specified, and legitimate purposes and not further processed in a manner incompatible with those purposes.

1. Adequate, relevant, limited to what is necessary in relation to the purposes for which it is processed.
2. Collected only where a valid explanation is provided whenever information relating to family or private affairs is required;
3. Accurate and, where necessary, kept up to date, with every reasonable step being taken to ensure that any inaccurate personal data is erased or rectified without delay;

vii.       Kept in a form which identifies the data subjects for no longer than is necessary for the purposes which it was collected; and

viii.       Not transferred outside Biblia Regulated Non-WDT Sacco Society Limited and the country unless there is proof of adequate data protection safeguards or consent from the data subject.

In complying with the stated data protection principles, Biblia Regulated Non-WDT Sacco Society Limited will observe the following:

1. Fairness and lawfulness

Biblia Regulated Non-WDT Sacco Society Limited in processing or while allowing processing of personal data, the individual rights of the data subjects must be protected and Personal data will only be collected and processed in a legal and fair manner.

2. Restriction to a specific purpose

Within Biblia Regulated Non-WDT Sacco Society Limited and as part of Biblia Regulated Non-WDT Sacco Society Limited procedures & processes, Personal data will be processed only for the purpose that was defined before the data was collected for instance; data collected for loan processing will only be used for the purpose of loan processing etc. Subsequent changes to the purpose are only possible to a limited extent and require substantiation by Biblia Regulated Non-WDT Sacco Society Limited and with consent from the data Subject.

3. Transparency

Biblia Regulated Non-WDT Sacco Society Limited data subject must be informed of how his/her data is being handled. In general, personal data must be collected directly from Biblia Regulated Non-WDT Sacco Society Limited Member or Staff concerned. When the data is collected, the data subject must either be aware of, or informed of:

1. The identity of the Data Controller- in this case it is Biblia Regulated Non-WDT Sacco Society Limited
2. The purpose of data processing e.g loans processing, Marketing of Sacco products,etc.

iii.         Third parties or categories of third parties to whom the data might be transmitted, if any.

4. Data reduction and data economy

Before processing personal data, Biblia Regulated Non-WDT Sacco Society Limited will determine whether and to what extent the processing of personal data is necessary in order to achieve the purpose for which it is undertaken. Where the purpose allows and where the expense involved is in proportion with the goal being pursued, anonymized or statistical data must be used. In the day-to-day operations of Biblia Regulated Non-WDT Sacco Society Limited, Personal data may not be collected in advance and stored for potential future purposes unless required or permitted by national law.

5. Deletion

Biblia Regulated Non-WDT Sacco Society Limited will make sure that Personal data that is no longer needed after the expiration of legal or business process related periods must be deleted. There may be an indication of interests that merit protection or historical significance of this data in individual cases. If so, Biblia Regulated Non-WDT Sacco Society Limited will ensure that the data remains on file until the interests that merit protection have been clarified legally, or Biblia Regulated Non-WDT Sacco Society Limited has evaluated the data to determine whether it must be retained for historical purposes.

6. Factual accuracy; up-to-date data

Biblia Regulated Non-WDT Sacco Society Limited will ensure that Personal data on file must be correct, complete, and – if necessary – kept up to date. Biblia Regulated Non-WDT Sacco Society Limited will ensure Suitable steps are taken to ensure that inaccurate or incomplete data are deleted, corrected, supplemented or updated.

7. Confidentiality and data security

Biblia Regulated Non-WDT Sacco Society Limited upholds that Personal data is subject to data secrecy. It must be treated as confidential on a personal level and secured with suitable organizational and technical measures to prevent unauthorized access, illegal processing, or distribution, as well as accidental loss, modification, or destruction within Biblia Regulated Non-WDT Sacco Society Limited and by all Biblia Regulated Non-WDT Sacco Society Limited Staff, officials, and stakeholders.