Privacy Statement

Tai Sacco Society Ltd

Tai Sacco Society Ltd is committed to keeping your personal data private and shall process any personal data collected from you in accordance with Data Protection Legislation and with provisions of our Data Privacy Policy.

Abbreviations and Acronyms

ABCAlternative Business Channels
BODBoard of Directors
CCTVClosed Circuit Television
CEOChief Executive Officer
CRBCredit Reference Bureau
DPIAData Protection Impact Assessment
DPOData Protection Officer
KYCKnow Your Customer
ODPCOffice of Data Protection Commissioner
EACCEthics and Anti-Corruption Commission
ICTInformation and Communication Technology
IDIdentification
NHIFNational Hospital Insurance Fund
NSSFNational Social Security Fund
SASRASacco Societies Regulatory Authority
SLAService Level Agreement

Definition of Terms

Anonymization: The removal of personal identifiers from personal data so that the data subject is no longer identifiable.

Biometric data: Personal data resulting from specific technical processing based on physical, physiological or behavioral characterization including blood typing, fingerprinting, earlobe geometry, retinal scanning, face recognition and voice recognition.

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, signify agreement to the processing of personal data relating to them.

Data: Information which is processed by means of equipment operating automatically in response to instructions given for that purpose or recorded with intention that it should be processed by means of such equipment or recorded as part of a relevant filing system.

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 Data Protection Act. Tai Sacco is the Data Controller of all personal data relating to it and used in facilitating its business operations.

Data Processing: Any activity that involves the use of personal data and includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organizing, 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 Impact Assessment

This is a tool or procedure of identifying and reducing risks involved in any Processing activity that will involve personal data.

Data Protection Officer

The person appointed as such under the Data Protection Act and in accordance with its requirements. A data protection officer is responsible for advising the Sacco (including employees) on their obligations under various data protection laws, for monitoring compliance with data protection law, as well as with Tai Sacco policies.

Data Subject: A living, identified or identifiable individual about whom the Sacco holds personal data.

Personal Data: Any information identifying a data subject or information relating to a data subject that the Sacco can identify (directly or indirectly) from that data alone or in combination with other identifiers the Sacco possess or can reasonably access. Personal data includes sensitive personal data and pseudonymized 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 behavior.

1. Information We Collect

2. Related Legal Entities

Corporate entities form part of our member base. These legal entities are not data subjects (i.e., natural persons to whom personal information relates). However, as part of our engagement with these members, we may receive personal information about individuals which may include but is not limited to:

  1. Full names
  2. National identity card number or passport number
  3. KRA Personal Identification Number (PIN)
  4. Date of birth
  5. Postal and business address
  6. Residential address, telephone number and email address
  7. Occupation or profession
  8. Nature of ownership or control of the company
  9. Number of Shares in the company

These examples are non-exhaustive, which is reflective of the varied nature of the personal information.

3. Use of Personal Data

This privacy statement aims to give you complete and transparent information on how Tai Sacco processes your personal data. We are committed to ensure that your personal information is processed in a way that is compatible with the specified, explicit, and legitimate purpose of collection.

Where personal data relates to a child, we will process the personal data only where parental or legal guardian consent has been given. The processing of such data will be done in a manner that protects and advances the rights and best interests of the child.

We may use personal data provided to us for any of the following purposes but are not limited to:

4. Sensitive Personal Data

We may collect Special Categories of Personal Data about you (this includes details about your race, health status, ethnic social origin, conscience, belief, genetic data, biometric data, property details, marital status, family details including details of your children, parents, spouse or spouses, sex or sexual orientation).

5. Transfer of Personal Data

Tai Sacco may transfer your personal information for the purpose of effecting/implementing, administering, and securing any product or service that you have applied for or for other purpose set out in this privacy statement. We also share data with Tai Sacco-controlled affiliates and subsidiaries; with vendors working on our behalf; when required by law or to respond to legal process; to protect our Members; to protect lives; to maintain the security of our products; to comply with regulatory requirements and to protect the rights and property of Tai Sacco and its Members.

We may transfer or disclose the personal data we collect to regulatory, fiscal or supervisory authority, correspondent Saccos on transaction enquiries, third party contractors, subcontractors, and/or their subsidiaries and affiliates who provide support to Tai Sacco in providing its services. The third-party providers may use their own third-party subcontractors that have access to personal data (sub-processors). It is our policy to use only third-party providers that are bound to maintain appropriate levels of security and confidentiality, to process personal information only as instructed by Tai Sacco, and to flow those same obligations down to their sub-processors.

6. Cross-Border Transfers

Tai Sacco membership is beyond Kenya's boundaries. We serve diaspora members that we may need to transfer personal information outside the country to where a member is located. This includes countries that do not have laws that provide specific protection to your personal data.

Where we send your information outside the country, we will make sure that there is proof of adequate data protection safeguards in the recipient country or consent from you on transfer of your personal information.

7. Other Disclosures

We may also disclose your personal information where required by law, to enforce other agreements, or to protect the rights, property, or safety of our business, our members, employees, or others.

Tai Sacco may disclose, respond, advise, exchange and communicate personal data and/or information in the Sacco's possession relating to you outside Tai Sacco whether such personal data and/or information is obtained after you cease to be the Sacco's Member or during the continuance of the Sacco-Member relationship or before such relationship was in contemplation, provided that such personal information is treated in confidence by the recipient:

9. Direct Marketing

From time to time, Tai Sacco may also use your personal information to contact you for market research or to provide you with information about other services we think would be of interest to you. You may be required to opt-in or give any other form of explicit consent before receiving marketing messages from us. We respect your right to control your personal data depending on which of our products you use. Therefore, at a minimum, we will always give you the opportunity to opt-out of receiving such direct marketing or market research communications. You may exercise this right to opt-out at any time.

10. Retention of Personal Data

Tai Sacco will retain your personal data only for as long as is necessary to achieve the purpose for which they were collected. We may retain your personal data and/or information for a period of up to seven (7) years or as may be required by law and maintains specific records management and retention policies and procedures, so that personal data are deleted after a reasonable time according to the following retention criteria:

11. Data Subject Rights

You have the right (in the circumstances and under the conditions, and subject to the exceptions, set out in applicable law) to:

  1. Be informed that we are collecting personal data about you.
  2. Request access to your personal information that we have on record. This right entitles you to know whether Tai Sacco holds personal data of you and, if so, obtain information on and a copy of those personal data.
  3. Request Tai Sacco to rectify any of your personal data that is incorrect or incomplete.
  4. Object to and withdraw your consent to processing of your personal data. This right entitles you to request that Tai Sacco no longer processes your personal data. The withdrawal of your consent shall not affect the lawfulness of processing based on prior consent before its withdrawal. We may also continue to process your personal information if we have a legitimate or legal reason to do so.
  5. Request the erasure of your personal data. This right entitles you to request the erasure of your personal data, including where such personal data would no longer be necessary to achieve the purposes.
  6. Request the restriction of the processing of your personal data. This right entitles you to request that Tai Sacco only processes your personal data in limited circumstances, including with your consent.
  7. Request portability of your personal data. This right entitles you to receive a copy (in a structured, commonly used, and machine-readable format) of personal data that you have provided to Tai Sacco, or request Tai Sacco to transmit such personal data to another data controller in an electronic format.

Contact Us

Please contact our Data Protection Officer if you have any questions or concerns about how Tai Sacco processes your personal data or you want to exercise any of your rights in relation to your personal data, on 0202010334 or by writing to us on email: dpo@taisacco.coop.

Amendments to this Statement

Tai Sacco reserves the right to amend or modify this privacy statement from time to time. Patronizing our products and services will constitute your agreement to be bound by the terms of any such amendment or variation. This privacy notice should be read together with the Terms and Conditions. Where in conflict, the privacy notice shall prevail.