1. Introduction

We understand the importance of data protection and are committed to protecting your data and respecting your privacy. We have adopted the appropriate technical and organizational measures in handling personal data and strictly adhere to the data protection laws and internal policies.

We collect, use, store, share and dispose of data and information about you in a transparent, fair, ethical, secure and lawful way that enables us to uphold our promises to you as our client, to our employees, and the community as a whole.

This statement explains the reason for the collection and processing of your personal data, how we collect, handle and ensure protection of all personal data provided, how that information is used and what rights you have in relation to your personal data. It also specifies our contact details of the responsible data controller with whom you may exercise your rights.

2. Personal Data and How It Is Collected

Personal Data is any information that identifies you or relates to you. This includes your name, identification number, phone number, email address, physical address, social media profile information among others.

The need to collect your personal data may be in fulfilment of an obligation under law, or mutual and voluntary with your consent. Personal data may therefore be collected either directly or indirectly from you.

Collection is direct either through your active and voluntary submission upon our request, or automatically in our interactions with you through our websites and social media sites (“Sites”) that link to our comprehensive privacy statement. Our Group Data Privacy statement can be accessed here.

By accessing and browsing the Sites, you hereby consent to the collection and processing of your personal data by NTT DATA and its subsidiaries/affiliates.

Collection is indirect if:

  1. the data is in the public domain,
  2. received from other sources either with your consent, or with the necessity of prevention, detection, investigation, prosecution and punishment of crime; the enforcement of a law which imposes a pecuniary penalty; or for the protection of your interests or the interests of another person.

3. Legal Basis and Purpose of Collection and Processing of Personal Data

We collect and process personal data in accordance with the provisions of the Data Protection Act, No. 24 of 2019 of the Laws of Kenya (“Act”). Being part of the global NTT DATA business enterprise and brand, we are also compliant under the General Data Protection Regulation, 2018 (“GDPR”).

The purpose for which your data may be collected and processed will largely depend on the services requested or agreed and/or the terms of our engagement with you. At the minimum, we aim at conducting due diligence in knowing you as our customer, ensuring efficient product delivery and customer service, and other relevant activities key to ensure quality of service.

At all times, your consent is key in how we handle your data. However, note that processing of your data is lawful under the following circumstances despite your consent:

  1. for entry into and the performance of a contract with you;
  2. for compliance with any legal obligation to which NTT DATA as the controller is subject;
  3. in order to protect your vital interests or those of another person;
  4. for the performance of a task carried out in the public interest or in the exercise of official authority vested in NTT DATA as a controller;
  5. for our legitimate business interests without harm or prejudice to your rights and freedoms or legitimate interests. In particular, we rely on legitimate interests for the purpose of managing, operating or promoting our business, including direct marketing, and internal Group transfers of personal data for business and administrative purposes.

4. Your Rights

You are guaranteed and entitled to the following legal rights. We endeavor to uphold these rights and comply to your assertion of any such right.

  1. The right to be informed of the use to which your personal data is to be put.
  2. The right to access your personal data in our custody as a data controller or data processor.
  3. The right object to the processing of all or part of your personal data.
  4. The right to correction of false or misleading data.
  5. The right to deletion of false or misleading data about you.

5. Handling and Safeguarding Your Personal Data

Your personal data may be collected and processed both manually and by automated means. At all times, your right to privacy shall remain key in how we handle your data.

Your data will be processed lawfully, fairly and in a transparent manner and only for the specified and legitimate purposes intended.

We will keep your data accurate and up to date where necessary. Retention of your personal data shall be for the time necessary to fulfil the purpose of collection and processing, and in the archives for such period as mutually agreed between us or permitted under law on record keeping.

Disclosure of your personal data shall only be extended to our authorised personnel, agents, affiliates or sub-contractors assigned to the provision of the services relating to our particular engagement. These parties are bound to confidentiality and the same scrutiny applicable to us in handling your personal data.

However, please note that we may be legally required to disclose your personal data to relevant authorities in the execution of their mandate or for public interest matters. In such cases and as far as is permitted by law, we shall notify you as soon as is practical of this obligation.

We further have in place verified information security systems and controls to detect, prevent and/or address risks such as unauthorized access, loss or alteration of data.

6. Contact Information

For more information, to assert your rights or engage NTT DATA concerning your personal data, kindly reach us through the details below:

NTT DATA Middle East & Africa,
Purshottam place, 3rd, 4th & 6th floor,
Westlands Road,
Nairobi.
Tel: + 254 20 499 3000/ +254 73 213 6000/ +254 20 360 0000/ +254 20 280 1000
General Enquiries: general.inquiries.ke@global.ntt
Sales Enquiries: Ssales.inquiries.ke@global.ntt